Finding 974774 (2023-002)

Significant Deficiency/Other Compliance Matter Finding 2023-002: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA) Identification of federal program: Program Title: Affordable Connectivity Outreach Grant Program Assistance Listing Number: 32.011 Award Identification: ACOGP2340190-00 Federal Agency: Federal Communications Commission Criteria or Specific Requirement: Under the requirements of the Federal Funding and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred to as the Transparency Act that is 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 (FSRS). 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 (FAR). Condition: The Organization works with subrecipients and some of its subawards require compliance with the FFATA requirement. The Organization did not complete required FFATA reporting for the Affordable Connectivity Outreach Grant Program during 2023. Cause: Supervision controls failed to detect that FFATA reporting was not completed, thus, controls over compliance did not operate effectively. The Organization’s program staff is aware of the FFATA reporting requirement and has complied with FFATA reporting for other recurring grants, however, the Affordable Connectivity Outreach Grant Program was a new program for the Organization during 2023. Effect: The Organization is not in compliance with FFATA reporting requirements as they relate to the Affordable Connectivity Outreach Grant Program. Questioned Costs: None Context: The Organization did not report its subawards as required to the FSRS system. Repeat finding: No Recommendation: We recommend that the Organization strengthen supervision and review controls over evaluating subawards for reporting requirements under FFATA and tracking whether reporting occurs timely and accurately. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.