Finding Text
Grant Program: Department of Housing and Urban Development HUD Counseling Program – Assistance Listing # 14.169
Condition: As a result of our audit procedures, we noted the following exceptions with reporting submissions for the Federal Funding Accountability and Transparency Act (FFATA) reporting for fiscal year ended September 30, 2023:
Criteria: The Code of Federal Regulations (2 CFR 170, Appendix A((I)(a)(2)(ii)) states a subaward must be reported in FSRS by the last day of the month following the obligation date, which is defined as the date the subaward is signed.
The Code of Federal Regulations (2 CFR 170, Appendix A(I)(b)(1)(i)) sets forth the reporting requirements of the Transparency Act that related to subawards under grants. Direct recipients of grants who make first-tier subawards equal to or exceeding $30,000 are required to report each subaward obligating action equal to $30,000 or more in Federal funds.
Effect: Failure to report subawards greater than $30,000 under FFATA is considered noncompliance. Continued noncompliance could result in a loss of funding.
Context: Pass through payment to subrecipients subject to FFATA reporting was $201,484.
Cause: NWMT was not aware of the reporting requirements.
Recommendation: We recommend that NWMT update its current practices for managing subaward reporting under FFATA to ensure applicable subawards are properly identified and the required submissions are made timely.
Management Response: See Corrective Action Plan.