EIN: 131840489
UEI: VD9ST5ZPM5P4
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 30, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 30, 2026 (151 days ago).
What is a management decision? →NUL did not complete and submit the FY 2022 and FY 2024 HUD CPF Grant financial and progress reports by the required due dates. Per our review of correspondence between NUL and HUD, it does not appear that NUL can file the reports with HUD through its DRGR system at this time. Cause: It appeared that staff turnover and unfamiliarity with reporting requirements of the new grant contributed to the condition noted above. Effect: NUL was not in compliance with the reporting requirements noted above. Questioned Costs: None. Repeat Finding: Not a repeat finding. Recommendation: We recommend that NUL submit the required FY 2022 and FY 2024 HUD CPF Grant financial and progress reports when HUD’s DRGR system is able to support the submissions. Additionally, all financial reporting requirements should be identified at contract signing. NUL should consider developing a financial reporting calendar that identifies the nature and timing of all federal reporting requirements to assist with meeting its federal financial reporting obligations. View of Responsible Officials: See management’s corrective action plan.
Show full finding ▾Hide full finding ▴Finding: 2024-001 Reporting Finding Type: Noncompliance, Significant Deficiency Identification of the Federal Program(s): U.S. Department of Housing and Urban Development: Federal Assistance Listing #14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Criteria: Per Article VI. Program-Specific Reporting Requirements of the FY 2022 Community Project Funding (CPF) Grant Agreement No. B-22-CP-NY-0711 and the FY 2024 CPF Grant Agreement No. B-24-CP-NY-1727 with the U.S. Department of Housing and Urban Development (HUD): “The grantee must submit a performance report in the Disaster Recovery Grant Reporting system (DRGR) on a semi-annual basis and must include a completed Federal financial report as an attachment to each performance report in DRGR. Performance reports shall consist of a narrative of work accomplished during the reporting period. During the period of performance, the grantee must submit these reports in the DRGR no later than 30 calendar days after the end of the six-month reporting period. The first of these reporting periods begins on the first of January or June (whichever occurs first) after the date this Grant Agreement is signed by HUD.” Per the DRGR, the FY 2022 HUD CPF Grant financial reports and progress reports for January 1, 2023 through June 30, 2023, July 1, 2023 through December 31, 2023, January 1, 2024 through June 30, 2024, and July 1, 2024 through December 31, 2024 were due on July 30, 2023, January 30, 2024, July 30, 2024, and January 30, 2025, respectively. Per the DRGR, the FY 2024 HUD CPF Grant financial reports and progress reports for July 1, 2024 through December 31, 2024 were due on January 30, 2025. Condition: NUL did not complete and submit the FY 2022 and FY 2024 HUD CPF Grant financial and progress reports by the required due dates. Per our review of correspondence between NUL and HUD, it does not appear that NUL can file the reports with HUD through its DRGR system at this time. Cause: It appeared that staff turnover and unfamiliarity with reporting requirements of the new grant contributed to the condition noted above. Effect: NUL was not in compliance with the reporting requirements noted above. Questioned Costs: None. Repeat Finding: Not a repeat finding. Recommendation: We recommend that NUL submit the required FY 2022 and FY 2024 HUD CPF Grant financial and progress reports when HUD’s DRGR system is able to support the submissions. Additionally, all financial reporting requirements should be identified at contract signing. NUL should consider developing a financial reporting calendar that identifies the nature and timing of all federal reporting requirements to assist with meeting its federal financial reporting obligations. View of Responsible Officials: See management’s corrective action plan.
Audit Finding Reference: 2024-001 (Reporting) Planned Corrective Action: NUL acknowledges the reporting requirements outlined in Article VI of the FY22 and FY24 CPF Grant Agreements with HUD. We respectfully note, however, that while we are fully aware of these reporting requirements, we were unable to submit the required reports because the Disaster Recovery Grant Reporting (DRGR) system was not available for submissions during the relevant periods. As such, even if we had attempted to file, submission could not have occurred due to the system’s unavailability. We were in contact with the administrators of HUD on a regular basis during the reporting period. Both HUD and NUL were fully aware of the DRGR system short falls. We emphasize that NUL maintains a strong record of timely and accurate federal reporting and does not typically experience issues with missed or late submissions. This instance is an isolated occurrence and is not reflective of our overall compliance practices. Once the DRGR system becomes available, NUL will promptly submit all required FY22 and FY24 reports to ensure compliance. To further strengthen our processes, NUL is committed to implementing a financial reporting calendar to supplement our existing internal controls and ensure continued timely compliance with all reporting obligations. This reporting calendar will be disseminated to all NUL departments that work with and are responsible for federal grant reporting.
During our review of three contractors (from a population of six contractors), we noted the following: For all three contractors, there was no evidence to support that a SAM.gov suspension and debarment verification had been performed by NUL prior to commencement of work or that a suspension and debarment clause was included in the original contracts. For two contractors subject to BABA requirements, there was no evidence of BABA requirements in the original contracts, or evidence that the contractors were monitored, during the contract term to ensure that all iron, steel, and manufactured products used in the project were produced in the United States and all construction materials were manufactured in the United States. For one contractor, while NUL provided a letter of intent, we were not provided with a copy of the executed contract to verify the federal funds awarded to the contractor. It should be noted that NUL, in 2025, amended (or fully executed) its contracts to include the suspension and debarment clauses and BABA requirements, and obtained representations from contractors that materials manufactured in the United States were used, as applicable. Cause: NUL indicated that certain agreements with contractors were executed prior to the execution of the related federal awards. Effect: NUL was not in compliance with the requirements noted above. Questioned Costs: None. Repeat Finding: Not a repeat finding. Recommendation: We recommend that all compliance requirements be identified at the time of contract signing. Further, those requirements should be documented and distributed to all NUL personnel responsible for ensuring and monitoring compliance with those provisions. Any actions necessary to ensure compliance should be undertaken in a timely manner. Documentation supporting compliance with said requirements should be maintained. View of Responsible Officials: See management’s corrective action plan.
Show full finding ▾Hide full finding ▴Finding: 2024-002 Procurement and Suspension and Debarment Finding Type: Noncompliance, Significant Deficiency Identification of the Federal Program(s): U.S. Department of Housing and Urban Development: Federal Assistance Listing #14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Criteria: Suspension and Debarment The code of federal regulations – 2 CFR section 180.300 states that: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified from receiving federal funds. You do this by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Build America, Buy America Per Article IV. General Federal Requirements of the FY 2024 Community Project Funding (CPF) Grant Agreement No. B-24-CP-NY-1727 with the U.S. Department of Housing and Urban Development (HUD): “The Grantee must comply with the requirements of the Build America, Buy America (BABA) Act, 41 USC 8301 note, and all applicable rules and notices, as may be amended, if applicable to the Grantee’s infrastructure project.” Under Section 70914 of the BABA Act each covered federal agency must ensure that “none of the funds made available for a federal financial assistance program for infrastructure may be obligated for a project unless all of the iron, steel, manufactured products, and construction materials used in the project are produced in the United States.” Effective May 14, 2022, the non-federal entity must comply with BABA requirements for all applicable federal awards subject to those requirements. The non-federal entity must ensure that the following conditions are met for any funds (including federal funds and non-federal funds) used for an infrastructure project that receives a federal award subject to BABA requirements: 1. All iron and steel used in the project are produced in the United States; 2. All manufactured products used in the project are produced in the United States; and 3. All construction materials are manufactured in the United States. The non-federal entity must also incorporate these Buy America Preference requirements in all applicable subawards, contracts, and purchase orders for the work performed, or products supplied under a federal award with an infrastructure project. Condition: During our review of three contractors (from a population of six contractors), we noted the following: For all three contractors, there was no evidence to support that a SAM.gov suspension and debarment verification had been performed by NUL prior to commencement of work or that a suspension and debarment clause was included in the original contracts. For two contractors subject to BABA requirements, there was no evidence of BABA requirements in the original contracts, or evidence that the contractors were monitored, during the contract term to ensure that all iron, steel, and manufactured products used in the project were produced in the United States and all construction materials were manufactured in the United States. For one contractor, while NUL provided a letter of intent, we were not provided with a copy of the executed contract to verify the federal funds awarded to the contractor. It should be noted that NUL, in 2025, amended (or fully executed) its contracts to include the suspension and debarment clauses and BABA requirements, and obtained representations from contractors that materials manufactured in the United States were used, as applicable. Cause: NUL indicated that certain agreements with contractors were executed prior to the execution of the related federal awards. Effect: NUL was not in compliance with the requirements noted above. Questioned Costs: None. Repeat Finding: Not a repeat finding. Recommendation: We recommend that all compliance requirements be identified at the time of contract signing. Further, those requirements should be documented and distributed to all NUL personnel responsible for ensuring and monitoring compliance with those provisions. Any actions necessary to ensure compliance should be undertaken in a timely manner. Documentation supporting compliance with said requirements should be maintained. View of Responsible Officials: See management’s corrective action plan.
Audit Finding Reference: 2024-002 (Procurement, Suspension and Debarment, and Build America, Buy America) Planned Corrective Action: Certain and key contracts were executed prior to the execution of the related U.S. Department of Housing and Urban Development: Federal Assistance Listing #14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants awards or contained clerical omissions, resulting in the absence of suspension and debarment verification, BABA clauses, or documentation in some agreements. These issues have since been corrected—NUL amended or executed contracts in 2025 to include the required suspension and debarment provisions, incorporated BABA requirements where applicable, and obtained contractor representations to ensure compliance. While, the amendments occurred after the initial execution of the contract, NUL has taken the necessary effort to include this language in all contracts, regardless of funded with federal funds or not. To prevent recurrence, NUL will: • Perform and document SAM.gov suspension and debarment check prior to contract execution, • Incorporate suspension and debarment clauses and BABA provisions into all applicable contracts at the outset, • Use a contract compliance checklist to ensure all required federal clauses are present before execution, and • Provide staff training and implement a centralized tracking system to monitor compliance. NUL remains committed to maintaining strong internal controls and ensuring full compliance with federal reporting and procurement requirements.
During our review of two contractors (from a population of six contractors), we noted the following: For one contractor, NUL did not provide any evidence to support that a SAM.gov suspension and debarment verification had been performed or that a suspension and debarment clause was included in the contract. It should be noted that NUL, in 2025, amended the contract to include the suspension and debarment clause. Cause: NUL indicated that this issue occurred due to a clerical error, whereby the suspension and debarment clause was initially included in the draft contract but was accidentally omitted while other updates were being incorporated into the contract. Effect: NUL was not in compliance with the requirements noted above. Questioned Costs: None. Repeat Finding: Not a repeat finding. Recommendation: We recommend that NUL ensure that personnel responsible for compliance and contracting are familiar with all suspension and debarment requirements. We recommend that NUL develop control procedures to ensure that contractor compliance reviews are timely performed and documented, with evidence of such maintained. Evidence of such reviews may include, but not be limited to, the existence of the appropriate clause in contracts, copies of suspension and debarment certifications from contractors, and/or documentation of verification via the SAM.gov website. View of Responsible Officials: See management’s corrective action plan.
Show full finding ▾Hide full finding ▴Finding: 2024-003 Procurement and Suspension and Debarment Finding Type: Noncompliance, Significant Deficiency Identification of the Federal Program(s): U.S. Department of Health and Human Services: Federal Assistance Listing #93.185 – COVID-19 – Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects Criteria: The code of federal regulations – 2 CFR section 180.300 states that: “When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified from receiving federal funds. You do this by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Condition: During our review of two contractors (from a population of six contractors), we noted the following: For one contractor, NUL did not provide any evidence to support that a SAM.gov suspension and debarment verification had been performed or that a suspension and debarment clause was included in the contract. It should be noted that NUL, in 2025, amended the contract to include the suspension and debarment clause. Cause: NUL indicated that this issue occurred due to a clerical error, whereby the suspension and debarment clause was initially included in the draft contract but was accidentally omitted while other updates were being incorporated into the contract. Effect: NUL was not in compliance with the requirements noted above. Questioned Costs: None. Repeat Finding: Not a repeat finding. Recommendation: We recommend that NUL ensure that personnel responsible for compliance and contracting are familiar with all suspension and debarment requirements. We recommend that NUL develop control procedures to ensure that contractor compliance reviews are timely performed and documented, with evidence of such maintained. Evidence of such reviews may include, but not be limited to, the existence of the appropriate clause in contracts, copies of suspension and debarment certifications from contractors, and/or documentation of verification via the SAM.gov website. View of Responsible Officials: See management’s corrective action plan.
Audit Finding Reference: 2024-003 (Procurement and Suspension and Debarment) Planned Corrective Action: One of the twenty-nine agreements issued under the U.S. Department of Health and Human Services: Federal Assistance Listing #93.185 – COVID-19 – Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Project contained a clerical omission of the required suspension and debarment provisions. NUL amended the executed contract in 2025 to include the required suspension and debarment provisions. To prevent recurrence, NUL will: • Perform and document SAM.gov suspension and debarment check prior to contract execution, • Incorporate suspension and debarment clauses and BABA provisions into all applicable contracts at the outset, • Use a contract compliance checklist to ensure all required federal clauses are present before execution, and • Provide staff training and implement a centralized tracking system to monitor compliance. NUL remains committed to maintaining strong internal controls and ensuring full compliance with federal reporting and procurement requirements. Name and Title of Contact Persons: Sidney Evans Jr. Sr. Vice President/Chief Financial Officer
FAC accepted this audit on July 19, 2024 — management decision was due January 19, 2025.
NUL has an obligation to report subaward data as required under the FFATA. This includes subawardee information, such as subaward amount, subawardee DUNS or UEI number, and relevant executive compensation, if applicable. We selected six AL# 17.235 subawards for testing from a population of fourteen subawards. For three of the six subawards tested, NUL reported the subaward amount incorrectly, whereby they incorrectly included the non-federal match amount in the amount reported on the FFATA report via the FSRS system. The total federal funds of the three subawards is $6,423,181.48 per the subaward agreements. The total subaward amount for the three subawards was reported as $7,214,253.03, which incorrectly included $791,071.55 of non-federal match funds. When we brought these exceptions to NUL’s attention, NUL immediately corrected the FFATA report to reflect the correct federal subaward amounts for all three subawards. The exceptions are summarized in the chart below. See Schedule of Findings and Questioned Costs for charts. Cause: Due to oversight, for three subawards, NUL included both the federal award amount and the nonfederal match amount as the amount of subaward on the FFATA report via the FSRS system. Effect: NUL did not submit subaward information in certain FFATA reports accurately. Questioned Costs: None. Repeat Finding: Repeat finding of 2022-001 Recommendation: We noted significant improvement in the progress NUL has made toward addressing the prior year finding. Going forward, we recommend that, as part of NUL’s review of the FFATA reports prior to submission, NUL ensures that the subaward amount reported on the FFATA report reflects only the total federal subaward amount, excluding the non-federal matching amount. View of Responsible Officials: See management’s corrective action plan.
Show full finding ▾Hide full finding ▴Finding: 2023-001 Reporting Finding Type: Noncompliance, Significant Deficiency Identification of the Federal Program(s): U.S. Department of Labor: 17.235 – Senior Community Service Employment Program Criteria: Federal Funding Accountability and Transparency Act Aspects of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), as amended by Section 6202 of Pub. L. No. 110-252, that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). 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 FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient); however, the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement. Direct recipients are required to report each first-tier subaward or subaward amendment that results in an obligation of $30,000 or more in federal funds. Prime contractors are required to report each first-tier subcontract award of $30,000 or more in federal funds. Grant and cooperative agreement recipients and contractors are required to register in FSRS and report subaward data through FSRS. To do so, they will first be required to register in the System for Award Management (SAM) (if they have not done so previously for another purpose (e.g., submission of applications through Grants.gov) and actively maintain that registration. Prime contractors have previously been required to register in SAM. Information input to FSRS is available at USASpending.gov as the publicly available website for viewing this information (https://www.usaspending.gov/search). Certain key data elements are required to be reported on the Federal Funding Accountability and Transparency Act (FFATA) report via the FSRS system. Per the 2023 OMB Compliance Supplement, the amount of subaward is defined as, “the net dollar amount of federal funds awarded to the subawardee including modifications.” Condition: NUL has an obligation to report subaward data as required under the FFATA. This includes subawardee information, such as subaward amount, subawardee DUNS or UEI number, and relevant executive compensation, if applicable. We selected six AL# 17.235 subawards for testing from a population of fourteen subawards. For three of the six subawards tested, NUL reported the subaward amount incorrectly, whereby they incorrectly included the non-federal match amount in the amount reported on the FFATA report via the FSRS system. The total federal funds of the three subawards is $6,423,181.48 per the subaward agreements. The total subaward amount for the three subawards was reported as $7,214,253.03, which incorrectly included $791,071.55 of non-federal match funds. When we brought these exceptions to NUL’s attention, NUL immediately corrected the FFATA report to reflect the correct federal subaward amounts for all three subawards. The exceptions are summarized in the chart below. See Schedule of Findings and Questioned Costs for charts. Cause: Due to oversight, for three subawards, NUL included both the federal award amount and the nonfederal match amount as the amount of subaward on the FFATA report via the FSRS system. Effect: NUL did not submit subaward information in certain FFATA reports accurately. Questioned Costs: None. Repeat Finding: Repeat finding of 2022-001 Recommendation: We noted significant improvement in the progress NUL has made toward addressing the prior year finding. Going forward, we recommend that, as part of NUL’s review of the FFATA reports prior to submission, NUL ensures that the subaward amount reported on the FFATA report reflects only the total federal subaward amount, excluding the non-federal matching amount. View of Responsible Officials: See management’s corrective action plan.
Audit Finding Reference: 2023-001 Planned Corrective Action: This finding represents a typo and is attributable to a human error. The error was corrected immediately after the auditor brought it to our attention. The League has strengthened its internal controls over timely submission of subaward data in FFATA (Federal Funding Accountability and Transparency Act) reports. NUL Legal Department used to be responsible for generating FFATA reports, as they are authorized with review of new grant agreements as well as related contracts/subrecipients agreements submitted for approval. In prior years some reports were not submitted in time because of continuous turnover in the department in 2021-22. The regular workflow was sometimes interrupted, and new appointees had to catch up following their priority lists. Eventually, at the end of February 2023, the function was moved to the Finance department and a specific position designated for completing FFATA reports. All pending FFATA reports have been completed immediately after that. We keep submitting FFATA reports for new grants as soon as subaward amounts are finalized. In view of the above error, we will establish an additional layer of control over FFATA report accuracy, so the reports are thoroughly reviewed, once entered into the system, and approved by either VP/Director, Budget & Grants or CFO. Overall, we believe the strength of our internal control ensures a timely and complete submission of FFATA reports. Name and Title of Contact Persons: Sidney Evans, Chief Financial Officer; Lisa Davis, Vice-President for Financial Operations; Triva John, Vice-President for Budget & Grants, Konstantin Yurashkevich, Director for Budget & Grants Name of Official: Sidney Evans Title: Chief Financial Officer Date: 05/30/2024
2022-001
FAC accepted this audit on August 14, 2023 — management decision was due February 14, 2024.
NUL has an obligation to report subaward data as required under the Federal Funding Accountability and Transparency Act (FFATA). This includes subawardee information, subawardee DUNS or SAM number, and relevant executive compensation, if applicable. Based on our selection of these subawards for testing (five for each major program), the following was noted: See Schedule of Findings and Questioned Costs for charts. Cause: Due to turnover in the Legal department, NUL did not consistently have personnel in place to ensure they submitted subaward information in FFATA reports accurately and timely. Effect: NUL did not submit subaward information in certain FFATA reports accurately or timely. Questioned Costs: None. Repeat Finding: Repeat finding of 2021-001 Recommendation: We recommend that NUL implement procedures to ensure accurate and timely reporting of all required subawards on FFATA reports prior to submission. View of Responsible Officials: See management?s corrective action plan.
Show full finding ▾Hide full finding ▴Finding: 2022-001 Reporting Finding Type: Noncompliance, Significant Deficiency Identification of the Federal Program(s): U.S. Department of Housing and Urban Development: 14.169 ? Housing Counseling Assistance Program U.S. Department of Justice: 16.726 ? Juvenile Mentoring Program U.S. Department of Labor: 17.261 ? WIOA Pilots, Demonstrations, and Research Projects Small Business Administration: 59.077 ? COVID-19 ? Community Navigator Pilot Program U.S. Department of Health and Human Services: 93.011 ? COVID-19 ? National Organizations of State and Local Officials Criteria: Federal Funding Accountability and Transparency Act Aspects of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), as amended by Section 6202 of Pub. L. No. 110-252, that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). 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 FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient); however, the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement. Direct recipients are required to report each first-tier subaward or subaward amendment that results in an obligation of $30,000 or more in federal funds. Prime contractors are required to report each first-tier subcontract award of $30,000 or more in federal funds. Grant and cooperative agreement recipients and contractors are required to register in FSRS and report subaward data through FSRS. To do so, they will first be required to register in the System for Award Management (SAM) (if they have not done so previously for another purpose (e.g., submission of applications through Grants.gov) and actively maintain that registration. Prime contractors have previously been required to register in SAM. Information input to FSRS is available at USASpending.gov as the publicly available website for viewing this information (https://www.usaspending.gov/search). Condition: NUL has an obligation to report subaward data as required under the Federal Funding Accountability and Transparency Act (FFATA). This includes subawardee information, subawardee DUNS or SAM number, and relevant executive compensation, if applicable. Based on our selection of these subawards for testing (five for each major program), the following was noted: See Schedule of Findings and Questioned Costs for charts. Cause: Due to turnover in the Legal department, NUL did not consistently have personnel in place to ensure they submitted subaward information in FFATA reports accurately and timely. Effect: NUL did not submit subaward information in certain FFATA reports accurately or timely. Questioned Costs: None. Repeat Finding: Repeat finding of 2021-001 Recommendation: We recommend that NUL implement procedures to ensure accurate and timely reporting of all required subawards on FFATA reports prior to submission. View of Responsible Officials: See management?s corrective action plan.
Audit Finding Reference: 2022-001 Planned Corrective Action: This is a repeat finding from 2021 audit which was properly addressed and fully resolved by March 2023. The League has strengthened its internal controls over timely submission of subaward data in FFATA (Federal Funding Accountability and Transparency Act) reports. NUL Legal Department used to be responsible for generating FFATA reports, as they are authorized with review of new grant agreements as well as related contracts/subrecipients agreements submitted for approval. Some reports were not submitted in time because of continuous turnover in the department in 2021-22. The regular workflow was sometimes interrupted, and new appointees had to catch up following their priority lists. Eventually, at the end of February 2023, the function was moved to the Finance department and a specific position designated for completing FFATA reports under supervision of VP, B&G/Director, B&G. All pending FFATA reports have been completed immediately after that. We keep submitting FFATA reports for new grants as soon as subaward amounts are finalized. Name and Title of Contact Persons: Paul Wycisk, Interim Chief Financial Officer; Lisa Davis, Vice-President for Financial Operations; Triva John, Vice-President for Budget & Grants, Konstantin Yurashkevich, Director for Budget & Grants
2021-001
FAC accepted this audit on September 28, 2022 — management decision was due March 28, 2023.
The League has an obligation to report subaward data as required under the Federal Funding Accountability and Transparency Act (FFATA). This includes subawardee information, subawardee DUNS or SAM number, and relevant executive compensation, if applicable. Based on our selection of these subawards for testing (five for 17.270 and six for 93.185), the following was noted: See Schedule of Findings and Questioned Costs for charts. Cause: Due to turnover in the Legal department, the League did not consistently have personnel in place to ensure they submitted subaward information in FFATA reports accurately and timely or at all. Effect: The League did not submit subaward information in certain FFATA reports accurately or timely or at all. Questioned Costs: None Recommendation: We recommend that the League implement procedures to ensure accurate and timely reporting of all required subawards on FFATA reports prior to submission. View of Responsible Officials: See management?s corrective action plan.
Show full finding ▾Hide full finding ▴Finding: 2021-001 Reporting Finding Type: Noncompliance, Significant Deficiency Identification of the Federal Program(s): U.S. Department of Labor: 17.270 ? Reentry Employment Opportunities U.S. Department of Health and Human Services: 93.185 ? COVID-19 ? Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Criteria: Federal Funding Accountability and Transparency Act Aspects of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), as amended by Section 6202 of Pub. L. No. 110-252, that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). 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 FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement. Direct recipients are required to report each first-tier subaward or subaward amendment that results in an obligation of $30,000 or more in federal funds. Prime contractors are required to report each first-tier subcontract award of $30,000 or more in federal funds. Grant and cooperative agreement recipients and contractors are required to register in FSRS and report subaward data through FSRS. To do so, they will first be required to register in the System for Award Management (SAM) (if they have not done so previously for another purpose (e.g., submission of applications through Grants.gov) and actively maintain that registration. Prime contractors have previously been required to register in SAM. Information input to FSRS is available at USASpending.gov as the publicly available website for viewing this information (https://www.usaspending.gov/search). Condition: The League has an obligation to report subaward data as required under the Federal Funding Accountability and Transparency Act (FFATA). This includes subawardee information, subawardee DUNS or SAM number, and relevant executive compensation, if applicable. Based on our selection of these subawards for testing (five for 17.270 and six for 93.185), the following was noted: See Schedule of Findings and Questioned Costs for charts. Cause: Due to turnover in the Legal department, the League did not consistently have personnel in place to ensure they submitted subaward information in FFATA reports accurately and timely or at all. Effect: The League did not submit subaward information in certain FFATA reports accurately or timely or at all. Questioned Costs: None Recommendation: We recommend that the League implement procedures to ensure accurate and timely reporting of all required subawards on FFATA reports prior to submission. View of Responsible Officials: See management?s corrective action plan.
Audit Finding Reference: 2021-001 Planned Corrective Action: The League is strengthening its internal controls over timely submission of subaward data in FFATA (Federal Funding Accountability and Transparency Act) reports. The Legal and Finance departments conduct check-up meetings on regular basis to review the status of grants with FFATA reporting requirements. The backup plan has been implemented to ensure timely and comprehensive submission of the required data in case one of the positions responsible for the submission becomes vacant or an employee holding the position remains out of office for a prolonged time. Specific focus will now be directed to ensuring that all subrecipients of federal awards are promptly registered with SAM (System for Award Management). Name and Title of Contact Persons: Paul Wycisk, Chief Financial Officer; Lisa Davis, Vice-President for Financial Operations; Triva John, Vice-President for Budget & Grants, Konstantin Yurashkevich, Director for Budget & Grants; Danielle Cooper Daughtry, General Counsel.
FAC accepted this audit on September 30, 2018 — management decision was due March 30, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2016-001
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on September 28, 2017 — management decision was due March 28, 2018.
GSA_MIGRATION
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GSA_MIGRATION
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