Are your federal program reports accurate, complete and on time? Here are tips to improve your odds

As you enter into new federal award agreements this year, keep in mind they will likely have reporting requirements. We first ran this article in March 2022, but due to its importance, we're republishing it as a reminder. 

Almost every federal program award requires recipients to file reports, which could include financial, performance and other special purpose reporting. Awarding agencies rely on these reports to ensure recipients used federal funds to achieve program objectives, which helps them make future funding decisions. 

Governments commonly struggle with federal reporting requirements. The issues range from reporting inaccurate information and missing deadlines to not filing reports at all. Based on audit findings issued between 2018 to 2022, reporting is ranked fifth in the top five findings by compliance requirement nationwide. 

When was the last time you reviewed your internal controls over meeting federal reporting requirements? Since it is a common audit issue, the State Auditor’s Office has gathered eight tips to help governments review and improve their controls. Even if you are confident in your control system, we recommend reading our tips for some important advice.  

• 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. Then, establish an annual reporting calendar detailing all required reports and their deadlines throughout the year. 

You might review the Compliance Supplement and compare it to your understanding of reporting requirements for each federal award. (The Compliance Supplement is designed to help auditors, but you will find information about compliance requirements for many programs in Part 4). 

• Put mechanisms in place to meet reporting deadlines. If you choose to use an annual reporting calendar, periodically review that it is complete and accurate. Also, regularly verify that the assigned staff member adhered to the calendar and filed each report on time. Your auditor will likely appreciate a well-documented reporting calendar – and documented supervisory checks – as evidence of a key control. Your auditor cannot use the fact that you submitted all reports on time as evidence of a key control. Whatever key control(s) you use to ensure you meet the compliance objective, you should document how you practice it. 

• Train staff on reporting requirements. When governments miss filing reports, they often cite employee turnover as the primary cause. You should provide oversight, ensure that you reassign reporting duties when staff leave, and monitor to ensure the new staff perform them properly. You should also ensure all employees with reporting responsibilities receive adequate training and guidance. If the awarding agency provides reporting instructions, then someone should make sure your staff know about them and apply them. You might also update your policies and procedures and provide written checklists to help guide staff. 

• Review reports properly. Employees who prepare the reports should not also review and submit them (segregation of duties principles). Knowledgeable supervisors should review and approve reports for completeness and accuracy, as well as compare them to source documentation. Make sure you document all reviews, including who reviewed the report and when. 

• Give yourself plenty of time to file. Don't wait until the last minute! Today, many governments submit their reports online. You may face technical issues or need help using the awarding agency’s website or submission portal. Users can overwhelm reporting systems as the deadline nears, which could result in technical issues that prevent you from filing on time. 

• Take steps if you’re going to miss the deadline. Reach out to your awarding agency to seek approval for a late submission. If the reporting system won't let you file, contact the awarding agency and ask what you should do. Demonstrate that you made every effort to submit the report and communicate with the awarding agency every step of the way. As always, keep documentation to show the steps you took. 

• Keep copies of reports. As proof that you submitted on time, you should keep a copy of each report you have sent and the supporting records you used to prepare it—regardless of whether you filed a printed or digital copy. You should compile and store your reporting documentation in a secure, central location so you can provide it to auditors or the awarding agency. 

• Contact your awarding agency with questions or concerns. Your best source of information is your awarding agency. Don't hesitate to contact them for guidance. 

Additional federal program-related resources 

• The Office of Federal Financial Management’s annual Compliance Supplement, Part 6 –Internal Control, Appendix 2, contains information about suggested controls for meeting the reporting requirements. While this resource is intended for auditors, you may also find it helpful. The information in this article is consistent with this guidance. 

• State Auditor’s Office: Federal programs risk assessment tool – Use this tool each year to help you assess risk or challenges related to meeting the objectives of federal programs. Read this article for more information on how to use the tool. 

Want help? 

Remember, we are here to help. While your awarding agency 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. 

For training on federal award requirements, see the Washington Finance Officers Association’s non-conference training schedule. Our Office will be offering a virtual course on federal award requirements on April 16 and May 14, from 8 a.m. to 3 p.m. Other organizations also offer training, such as Government Finance Officers Association, American Institute of Certified Public Accountants, and the National Grants Management Association. 

If you have other questions, comments or suggestions, feel free to email us at Center@sao.wa.gov.