Published: March 23, 2022
Almost every federal program, including new programs related to COVID-19 economic relief, has reporting requirements for recipients. That’s because federal granting agencies rely on your reports to ensure you are using funds to achieve program objectives and to make future funding decisions.
Reporting can be challenging for federal program recipients, regardless of whether the reports are financial, performance related or for other special purposes. From 2015 to 2019, 27 percent of all SAO Single Audit findings involved issues over reporting. The issues ranged from reporting inaccurate information and missing deadlines to not filing a report at all.
Your internal control system must include steps to ensure you comply with the reporting requirements of your federal program, and auditors need to see evidence that management established internal controls and employees practiced them.
Here’s some advice to help you with your reporting requirements:
- Identify the required reports and establish an annual reporting calendar. Carefully read each federal award’s terms and conditions to know what reports to file and when. If the compliance supplement includes your specific program, use it as an additional source to confirm your understanding of the reporting requirements. You can find the 2021 compliance supplement here and its addenda here. Ideally, you should establish an annual reporting calendar detailing all required reports and their deadlines throughout the year.
- Put mechanisms in place to meet reporting deadlines. If you choose to use an annual reporting calendar, periodically review that it is complete, accurate and followed. Remember, submitting a report on time is not enough evidence of an effective control system. Keep documentation of whatever control mechanism you choose to use to achieve this objective.
- Train staff on reporting requirements. A common cause for missed reports is staff turnover. For experienced and new staff alike, make sure your employees receive adequate training, guidance and oversight. This is where written policies, procedures and checklists can be helpful. Grantors also might provide instructions for each report. If they do, make sure staff know about them and use them.
- Supervisors should review to check completeness and accuracy. Ideally, employees who prepare the reports should not be the ones who review and submit them (segregation of duties principles). Knowledgeable supervisors should review and approve reports for completeness and accuracy, including comparing them to source documentation. Make sure to keep documentation that supports a review took place and when.
- Give yourself plenty of time to file. Don’t wait until the last minute! Today, many of your reports are submitted electronically. You may face technical issues, system glitches, or a learning gap using the grantor’s website or submission portal. Also, users can overwhelm reporting systems near the reporting deadline.
- Take steps if you’re going to miss the deadline. Reach out to your grantor to seek approval for a late submission. If the grantor’s system won’t let you file, contact the grantor and ask what you should do. Demonstrate that you made every effort to submit the report and communicate with your grantor every step of the way. As always, keep documentation to show the steps you have taken.
- Keep support of what you submitted. As proof that you submitted it on time, you should keep a copy of each report you have sent and the supporting records you used to prepare the report—regardless of whether it was in electronic or paper format. You should compile and store your reporting documentation in a secure, central location so it is readily available for interested parties like auditors or an oversight agency to review.
- Contact your grantor with questions or concerns. Your grantor is there to help you and is the best source of information about your award. Don’t hesitate to reach out to your grantor for guidance.
Additional reading and resources
Looking for more SAO resources relating to Single Audits and federal program compliance? Check out some of our other articles:
- Lack of subrecipient monitoring is leading to an increase in audit issues. Learn what you can do today
- Is your contractor banned from receiving federal funds? Don’t wait to find out.
- Sharing your federal money with other agencies? Do your homework first
Remember, SAO is here to help. While your grantor is the best source for information about a federal program, you can also submit technical questions about federal awards to our HelpDesk in the client portal.
If you have other questions, comments or suggestions, feel free to email us at Center@sao.wa.gov.