Finding Text
Finding 2023-001: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA).Agency and Award: U.S. Department of State, Assistance Listing Number 19.345.Criteria: Under the requirements of the FFATA (Pub. L. No. 109‑282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the Transparency Act that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the Federal Acquisition Regulation.Condition and context: The Endowment works with sub awardees and some of its awards require compliance with the FFATA requirement. Even though the Endowment is aware of the FFATA requirement, the Endowment does not report its subawards in the required system.Cause: The Endowment works with many grantees that work in high-risk countries and concluded that complying with the requirement, would put its grantees at risk.Questioned costs: None.Effect: The Endowment is in non-compliance with FFATA reporting requirements. No other reporting issues noted.Repeat finding: Yes, reported as Finding 2022-001.Recommendation: We recommend management continues to work with its grant officers to obtain a waiver and implement procedures to ensure grants are evaluated for reporting requirements under FFATA and the reporting is completed within the required timeframe.View of responsible officials and planned corrective actions: Management acknowledges the FFATA requirement and will continue working with the grant officers. See corrective action plan 2023.