PATH

Finding 2024-001 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Malaria Vaccine Assistance Listing Number: 98.AID-7200AA20C00017 Award Number: 7200AA20C00017 Award Period: 06/18/2020 through 06/17/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization has an established a process by which to perform FFATA reporting. Among the 10 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Transactions tested 10, Sub-Award Not Reported 0, Reported Not Timely 2, Sub-Award Amount Incorrect N/A, Sub-Award Missing Key Elements N/A Dollar Amount of Tested Transactions $11,068,072, Sub-Award Not Reported $-, Reported Not Timely $204,097, Sub-Aard Amount Incorrect N/A, Sub-Award Missing Key Elements N/A Cause The late submissions were due to the Organization’s periodic review process not effectively identifying and resolving delinquent FFATA filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding Elements of this finding are a repeat of some of the matters noted in Finding 2023-002. Recommendations We recommend management review the timing and frequency of its review process over FFATA filings to ensure all filings are submitted in a timely manner. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2019-001 Significant deficiency in internal control over compliance with allowable cost principles. Federal Agency: United States Agency for International Development CFDA Number: 98.001 Program Name: USAID Foreign Assistance for Programs Overseas Award Numbers: AID-660-A-17-00001, award period March 1, 2017 through February 28, 2022 Criteria Compensation-personal services requirements contained in Title 2 US Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E - Cost Principles, Section 200.430 - Standards for Documentation of Personnel Expenses, and 22 CFR 226, Administration of Assistance Awards to U.S. Non-Governmental Organizations, requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition/Context/Questioned Costs The Organization?s internal control over salaries costs charged to a Federal awards requires that only allowable time be charged and also requires that timesheets be completed by each employee and reviewed and approved by the appropriate supervisor for accuracy; changes to timesheets after the original approval is made must be documented and approved in writing. During our audit we tested 60 salaries costs. Of the salaries costs tested we noted four instances where employees in the Organization?s offices in Democratic Republic of Congo (DRC) appeared to have more salary charged to the Federal award than the time sheet indicated by $71.47 in the aggregate. Upon further analysis by the Organization it was identified that employees in DRC did not record any hours on their timesheet for national holidays. The Organization has an automated system that takes the approved timesheet and applies the percentage worked to the employees authorized salary to allocate salary costs to projects. As the holiday hours were not recorded on the timesheet, the projects the employees worked on in a month with a holiday were overcharged. The Organization performed an analysis and identified the Federal Program was overcharged by $48,378.21. Cause The Organization?s internal controls over review and approval of hours reported on timesheets lead to overcharges to Federal awards. Effect The effect is that salary costs were overcharged to the Federal award. Repeat Finding Not applicable, as Finding 2019-001 is not a repeat finding. Recommendation We recommend management correct the salary costs incorrectly charged to the Federal award. We also recommend management provide training to enforce its time sheet procedures to ensure accurate salary charges to the Federal awards. Views of Responsible Officials Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2019-002 Significant deficiency in internal control over compliance with subrecipient monitoring and management. Federal Agency: United States Agency for International Development CFDA Number: 98.001 Program Name: USAID Foreign Assistance for Programs Overseas Award Numbers: AID-OAA-A-14-00028 award period March 17, 2014 through November 30, 2019, and AID-OAA-A-17-00015 award period August 1, 2017 through July 31, 2021 Criteria Requirements for pass-through entities contained in Title 2 US Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart D ? Post-Award Requirements, Section 200.331(a)(xii) states all pass-through entities must ensure subawards include identification of whether the award is R&D. Condition/Context/Questioned Costs The Organization?s internal control over subrecipient monitoring include a template for issuing subaward agreements. The template includes a section to identify if the award is R&D. This field is input by staff in the Office of Grants and Contract and/or Legal departments of the Organization. During our audit we tested 25 subrecipient agreements for CFDA 98.001 and found three of the agreements identified the agreement as R&D in error. Cause The Organization?s internal controls over the R&D classification did not properly detect the incorrect indentification being included. Effect The effect is that three subawards were improperly identified as R&D awards by the Organization. Repeat Finding Not applicable, as Finding 2019-002 is not a repeat finding. Recommendation We recommend management update the template and related procedures for subaward agreements to clarify that the designation as an R&D subaward is based on the designation in the related prime award received by PATH. Views of Responsible Officials Management agrees with the finding and has provided the accompanying corrective action plan.

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