PYXERA Global, Inc.Non-Profit

Item 2021-001, Reporting, USAID Foreign Assistance for Programs Overseas: Delivering Regional Instruction Vital to Entrepreneurial Success - Belarus (DRIVES) CFDA 98.001 Criteria or specific requirement: Under the requirements of the Federal Funding Accountability and Transparency Act ("Transparency Act") that are codified in 2 CFR Part 170, recipients (i.e. direct recipients) of grants or cooperative agreements who make a first tier subaward of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) by the last day following the month in which the award was signed through FSRS. Statement of condition and context: During our testing of the reporting compliance requirement, it was noted that PYXERA Global had one first tier subaward that was required to be reported in the FSRS, however PYXERA Global did not report the subaward information timely. See Schedule of Findings and Questioned Costs for chart/table. Statement of cause: Management was aware that they were required to register and report subaward information in the FSRS related to the first tier subaward given to another entity that was over $30,000, however due to the subrecipient not having a DUNS number, they were unable to file the report on a timely basis and PYXERA Global did not apply for an exemption. PYXERA Global was able to file the report in April 2022. Effect: PYXERA Global did not comply with the reporting compliance requirement as required by the Transparency Act. Questioned costs: None. Identification of repeat finding: No. Recommendation: We recommend that PYXERA Global implement controls and procedures to ensure that all required FFATA reports are timely filed. Views of responsible official: Though no report was submitted prior to the end of the program, PYXERA Global demonstrated its best efforts to comply with the requirement and kept the Mission appraised of issues it was facing. PYXERA Global informed the subrecipient of the need to register with Dun & Bradstreet (D&B) to be issued a DUNS number so the appropriate FFATA reporting could be completed. The Subrecipient made the first attempt on their own at the beginning of the program, but the process stalled with D&B. The second attempt, at the end of the program was coordinated with PYXERA Global, and we assisted in submitting the request. D&B once again was unable to provide a DUNS number and provided its rejection in early 2021 (a copy of which was provided to the Auditors). Shortly thereafter the situation in Belarus deteriorated and Belarussian organizations, including our subrecipient, were no longer willing to be publicly linked to US Government funding for fear of forced dissolution and/or arrest of their leadership. This spring, after our subrecipient's situation had improved, we reached out once again to see if they would agree to us submitting the report (without the DUNS number), they agreed, but were unwilling to attempt to register for a Unique Entity Identifier/DUNS number. USAID was aware of our attempts to have a DUNS number issued and the difficulties were facing; the matter was discussed at several meetings, including those for the award of the follow-on activity. The issue of a waiver was discussed in general terms, but no waiver was officially requested or provided for the program. USAID has since issued FFATA waivers for all active programs recognizing the heightened risk to subrecipients. We chose not to pursue a retroactive waiver this spring as the program had been managed from the Regional Mission in Kiev, and we did not feel it rose to a level that should require the attention of Mission staff responding to the evacuation command from the State Department.