2022-003 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Information on the Federal Program(s): United States Department of State Assistance Listing Number: 19.345 Assistance Listing Name: International Programs to Support Democracy, Human Rights and Labor Award Number: Direct Award Number Award Period SLMAQM20GR2250 September 8, 202 through June 30, 2023 United States Department of State Assistance Listing Number: 19.415 Assistance Listing Name: Professional and Cultural Exchange Programs ? Citizen Exchanges Pass-through Award: Pass-through Entity Pass through Award Number Award Period The Aspen Institute SI_SOL4_SubR-2021 April 1, 2021 through June 30, 2023 Criteria or Specific Requirement: In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Additionally, ?200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Organization has documented expenditure policies and procedures. However, as identified below, the review and approval process did not operate as designed. The Organization?s policies are designed to ensure expenses are reviewed and approved timely to ensure proper recording in the books and records. The following errors were identified during our testing of payroll and non-payroll expenditures: ? For AL# 19.345 we tested 40 non-payroll samples and identified one error. The expense was allocated between two projects based on preliminary estimates. The preliminary budgeted expense allocation was not corrected based on the actual allocation from the underlying documentation, representing $45 in questioned costs. ? For AL# 19.415 we tested 40 non-payroll samples and identified one error. The expense was related to depreciation which requires the Organization to maintain adequate property records and take a physical inventory at least once every two years to ensure that the assets exist and are usable, used, and needed. The documentation provided to support the charge to the award was not sufficient to meet the requirements above resulting in $3,046 in questioned costs. Questioned Costs: The items above represents questioned costs totaling $3,091. Context: This is a condition identified per review of the Organization?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: The Organization has documented expenditure policies and procedures regarding the timely processing and approval of expenditures. However, as identified above, the review and approval process did not operate as designed resulting in errors noted. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major programs. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: BDO recommends that the Organization adhere to its documented policies and procedures regarding authorization final invoices and recording of expenditures and not using preliminary budgeted expense allocations.
Information on the Federal Program(s): United States Department of the State Assistance Listing Number: 19.345 Assistance Listing Name: International Programs to Support Democracy, Human Rights and Labor Award Number:Direct Award Number Award Period SLMAQM21GR3097 July 15, 2021 through December 31, 2022 United States Department of the State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Number: Direct Award Number Award Period SLMAQM20CA2264 September 28, 2020 through September 30, 2024 Criteria or Specific Requirement: The Federal Funding Accountability and Transparency Act, as codified in 2 CFR Part 170, requires prime awardees awarded a federal grant to file a Federal Funding Accountability and Transparency Act (FFATA) report when the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: During our subrecipient testing for the major programs, we determined management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during BDO?s testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization did not comply with FFATA reporting requirements as there was not a control in place to ensure FFATA reporting was completed when required by 2 CFR Part 170. Effect: Failure to comply with the FFATA requirement may out the grant funding at risk due to noncompliance under the Uniform Guidance. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2021- 003 in the 2021 schedule of findings and questioned costs. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings in arrears are immediately filed.
2022-003 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Information on the Federal Program(s): United States Department of State Assistance Listing Number: 19.345 Assistance Listing Name: International Programs to Support Democracy, Human Rights and Labor Award Number: Direct Award Number Award Period SLMAQM20GR2250 September 8, 202 through June 30, 2023 United States Department of State Assistance Listing Number: 19.415 Assistance Listing Name: Professional and Cultural Exchange Programs ? Citizen Exchanges Pass-through Award: Pass-through Entity Pass through Award Number Award Period The Aspen Institute SI_SOL4_SubR-2021 April 1, 2021 through June 30, 2023 Criteria or Specific Requirement: In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Additionally, ?200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Organization has documented expenditure policies and procedures. However, as identified below, the review and approval process did not operate as designed. The Organization?s policies are designed to ensure expenses are reviewed and approved timely to ensure proper recording in the books and records. The following errors were identified during our testing of payroll and non-payroll expenditures: ? For AL# 19.345 we tested 40 non-payroll samples and identified one error. The expense was allocated between two projects based on preliminary estimates. The preliminary budgeted expense allocation was not corrected based on the actual allocation from the underlying documentation, representing $45 in questioned costs. ? For AL# 19.415 we tested 40 non-payroll samples and identified one error. The expense was related to depreciation which requires the Organization to maintain adequate property records and take a physical inventory at least once every two years to ensure that the assets exist and are usable, used, and needed. The documentation provided to support the charge to the award was not sufficient to meet the requirements above resulting in $3,046 in questioned costs. Questioned Costs: The items above represents questioned costs totaling $3,091. Context: This is a condition identified per review of the Organization?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: The Organization has documented expenditure policies and procedures regarding the timely processing and approval of expenditures. However, as identified above, the review and approval process did not operate as designed resulting in errors noted. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major programs. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: BDO recommends that the Organization adhere to its documented policies and procedures regarding authorization final invoices and recording of expenditures and not using preliminary budgeted expense allocations.
Information on the Federal Program: United States Department of State Assistance Listing Number: 19.415 Assistance Listing Name: Professional and Cultural Exchange Programs ? Citizen Exchanges Pass-through Awards: Pass-through Entity Pass through Award Number Award Period The Aspen Institute SI_SOL4_SubR-2021 April 1, 2021 through June 30, 2023 The Aspen Institute SI_SOL3_SubR-2020 April 1, 2021 through June 30, 2023 Criteria or Specific Requirement: In accordance with ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to 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. All procurement transactions must be conducted in a manner providing full and open competition consistent in accordance with ?200.319 and must be performed using the appropriate procurement method as outlined in ?200.320. In accordance with ?200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135.Condition: During our testing of compliance, we identified the following matters: ? The Organization?s subsidiary Soliya did not have a written procurement policy that complied with the federal requirements presented above. ? For three procurement samples of a total of nine items teested for AL# 19.415, management did not provide adequate supporting documentation for the procurement transaction. BDO was only provided a copy of the authorized contract between the consultant and Soliya. No other information to support compliance with federal procurement requirements was provided. Questioned Costs: Total known questioned costs are $6,656. Context: This is a condition based on testing of Soliya?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: Soliya did not adopt a written procurement policy that was compliant with the Uniform Administrative Requirements. In addition Soliya was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: We recommend management of Soliya adopt Search for Common Ground?s procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff of Soliya are trained on this policy to help ensure compliance going forward.
Information on the Federal Program: United States Department of State Assistance Listing Number: 19.415 Assistance Listing Name: Professional and Cultural Exchange Programs ? Citizen Exchanges Pass-through Awards: Pass-through Entity Pass through Award Number Award Period The Aspen Institute SI_SOL4_SubR-2021 April 1, 2021 through June 30, 2023 The Aspen Institute SI_SOL3_SubR-2020 April 1, 2021 through June 30, 2023 Criteria or Specific Requirement: In accordance with ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to 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. All procurement transactions must be conducted in a manner providing full and open competition consistent in accordance with ?200.319 and must be performed using the appropriate procurement method as outlined in ?200.320. In accordance with ?200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135.Condition: During our testing of compliance, we identified the following matters: ? The Organization?s subsidiary Soliya did not have a written procurement policy that complied with the federal requirements presented above. ? For three procurement samples of a total of nine items teested for AL# 19.415, management did not provide adequate supporting documentation for the procurement transaction. BDO was only provided a copy of the authorized contract between the consultant and Soliya. No other information to support compliance with federal procurement requirements was provided. Questioned Costs: Total known questioned costs are $6,656. Context: This is a condition based on testing of Soliya?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: Soliya did not adopt a written procurement policy that was compliant with the Uniform Administrative Requirements. In addition Soliya was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: We recommend management of Soliya adopt Search for Common Ground?s procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff of Soliya are trained on this policy to help ensure compliance going forward.
Information on the Federal Program(s): United States Department of the State Assistance Listing Number: 19.345 Assistance Listing Name: International Programs to Support Democracy, Human Rights and Labor Award Number:Direct Award Number Award Period SLMAQM21GR3097 July 15, 2021 through December 31, 2022 United States Department of the State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Number: Direct Award Number Award Period SLMAQM20CA2264 September 28, 2020 through September 30, 2024 Criteria or Specific Requirement: The Federal Funding Accountability and Transparency Act, as codified in 2 CFR Part 170, requires prime awardees awarded a federal grant to file a Federal Funding Accountability and Transparency Act (FFATA) report when the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: During our subrecipient testing for the major programs, we determined management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during BDO?s testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization did not comply with FFATA reporting requirements as there was not a control in place to ensure FFATA reporting was completed when required by 2 CFR Part 170. Effect: Failure to comply with the FFATA requirement may out the grant funding at risk due to noncompliance under the Uniform Guidance. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2021- 003 in the 2021 schedule of findings and questioned costs. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings in arrears are immediately filed.
2022-002 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Numbers: Direct Award Numbers Award Period SLMAQM20CA2264 September 28, 2020 through March 29, 2024 SLMAQM20GR2364 September 28, 2020 through September 30, 2024 Criteria: CFR Section ?200.510(b) states in part: ?The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section ?200.502 Basis for determining Federal awards expended.? The schedule must provide total Federal awards expended for each individual Federal program. In accordance with ?200.302 Financial Management, a non-federal entity?s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management?s preparation of the SEFA, BDO identified two awards whose assistance listing number was changed by the federal entity in award amendments issued prior to December 31, 2022. Management failed to update the assistance listing number for the awards within the SEFA to address the award modifications. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not fully operate as designed. The Organization did not adequately review award modifications for changes to existing awards. Effect: The SEFA initially provided to BDO resulted in incorrect major program selection as prescribed under the Unform Guidance. During the review of the award agreements, BDO identified the assistance listing numbers for the two awards had been modified. This issue resulted in a different major program selection once the SEFA was updated to reflect the correct assistance listing numbers. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management to continue to focus on training for both preparer and reviewers of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section ?200.510(b). This will ensure that the SEFA provides all relevant information as proscribed.
2022-002 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Numbers: Direct Award Numbers Award Period SLMAQM20CA2264 September 28, 2020 through March 29, 2024 SLMAQM20GR2364 September 28, 2020 through September 30, 2024 Criteria: CFR Section ?200.510(b) states in part: ?The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section ?200.502 Basis for determining Federal awards expended.? The schedule must provide total Federal awards expended for each individual Federal program. In accordance with ?200.302 Financial Management, a non-federal entity?s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management?s preparation of the SEFA, BDO identified two awards whose assistance listing number was changed by the federal entity in award amendments issued prior to December 31, 2022. Management failed to update the assistance listing number for the awards within the SEFA to address the award modifications. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not fully operate as designed. The Organization did not adequately review award modifications for changes to existing awards. Effect: The SEFA initially provided to BDO resulted in incorrect major program selection as prescribed under the Unform Guidance. During the review of the award agreements, BDO identified the assistance listing numbers for the two awards had been modified. This issue resulted in a different major program selection once the SEFA was updated to reflect the correct assistance listing numbers. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management to continue to focus on training for both preparer and reviewers of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section ?200.510(b). This will ensure that the SEFA provides all relevant information as proscribed.
2022-003 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Information on the Federal Program(s): United States Department of State Assistance Listing Number: 19.345 Assistance Listing Name: International Programs to Support Democracy, Human Rights and Labor Award Number: Direct Award Number Award Period SLMAQM20GR2250 September 8, 202 through June 30, 2023 United States Department of State Assistance Listing Number: 19.415 Assistance Listing Name: Professional and Cultural Exchange Programs ? Citizen Exchanges Pass-through Award: Pass-through Entity Pass through Award Number Award Period The Aspen Institute SI_SOL4_SubR-2021 April 1, 2021 through June 30, 2023 Criteria or Specific Requirement: In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Additionally, ?200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Organization has documented expenditure policies and procedures. However, as identified below, the review and approval process did not operate as designed. The Organization?s policies are designed to ensure expenses are reviewed and approved timely to ensure proper recording in the books and records. The following errors were identified during our testing of payroll and non-payroll expenditures: ? For AL# 19.345 we tested 40 non-payroll samples and identified one error. The expense was allocated between two projects based on preliminary estimates. The preliminary budgeted expense allocation was not corrected based on the actual allocation from the underlying documentation, representing $45 in questioned costs. ? For AL# 19.415 we tested 40 non-payroll samples and identified one error. The expense was related to depreciation which requires the Organization to maintain adequate property records and take a physical inventory at least once every two years to ensure that the assets exist and are usable, used, and needed. The documentation provided to support the charge to the award was not sufficient to meet the requirements above resulting in $3,046 in questioned costs. Questioned Costs: The items above represents questioned costs totaling $3,091. Context: This is a condition identified per review of the Organization?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: The Organization has documented expenditure policies and procedures regarding the timely processing and approval of expenditures. However, as identified above, the review and approval process did not operate as designed resulting in errors noted. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major programs. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: BDO recommends that the Organization adhere to its documented policies and procedures regarding authorization final invoices and recording of expenditures and not using preliminary budgeted expense allocations.
Information on the Federal Program(s): United States Department of the State Assistance Listing Number: 19.345 Assistance Listing Name: International Programs to Support Democracy, Human Rights and Labor Award Number:Direct Award Number Award Period SLMAQM21GR3097 July 15, 2021 through December 31, 2022 United States Department of the State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Number: Direct Award Number Award Period SLMAQM20CA2264 September 28, 2020 through September 30, 2024 Criteria or Specific Requirement: The Federal Funding Accountability and Transparency Act, as codified in 2 CFR Part 170, requires prime awardees awarded a federal grant to file a Federal Funding Accountability and Transparency Act (FFATA) report when the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: During our subrecipient testing for the major programs, we determined management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during BDO?s testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization did not comply with FFATA reporting requirements as there was not a control in place to ensure FFATA reporting was completed when required by 2 CFR Part 170. Effect: Failure to comply with the FFATA requirement may out the grant funding at risk due to noncompliance under the Uniform Guidance. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2021- 003 in the 2021 schedule of findings and questioned costs. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings in arrears are immediately filed.
2022-003 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Information on the Federal Program(s): United States Department of State Assistance Listing Number: 19.345 Assistance Listing Name: International Programs to Support Democracy, Human Rights and Labor Award Number: Direct Award Number Award Period SLMAQM20GR2250 September 8, 202 through June 30, 2023 United States Department of State Assistance Listing Number: 19.415 Assistance Listing Name: Professional and Cultural Exchange Programs ? Citizen Exchanges Pass-through Award: Pass-through Entity Pass through Award Number Award Period The Aspen Institute SI_SOL4_SubR-2021 April 1, 2021 through June 30, 2023 Criteria or Specific Requirement: In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Additionally, ?200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Organization has documented expenditure policies and procedures. However, as identified below, the review and approval process did not operate as designed. The Organization?s policies are designed to ensure expenses are reviewed and approved timely to ensure proper recording in the books and records. The following errors were identified during our testing of payroll and non-payroll expenditures: ? For AL# 19.345 we tested 40 non-payroll samples and identified one error. The expense was allocated between two projects based on preliminary estimates. The preliminary budgeted expense allocation was not corrected based on the actual allocation from the underlying documentation, representing $45 in questioned costs. ? For AL# 19.415 we tested 40 non-payroll samples and identified one error. The expense was related to depreciation which requires the Organization to maintain adequate property records and take a physical inventory at least once every two years to ensure that the assets exist and are usable, used, and needed. The documentation provided to support the charge to the award was not sufficient to meet the requirements above resulting in $3,046 in questioned costs. Questioned Costs: The items above represents questioned costs totaling $3,091. Context: This is a condition identified per review of the Organization?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: The Organization has documented expenditure policies and procedures regarding the timely processing and approval of expenditures. However, as identified above, the review and approval process did not operate as designed resulting in errors noted. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major programs. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: BDO recommends that the Organization adhere to its documented policies and procedures regarding authorization final invoices and recording of expenditures and not using preliminary budgeted expense allocations.
Information on the Federal Program: United States Department of State Assistance Listing Number: 19.415 Assistance Listing Name: Professional and Cultural Exchange Programs ? Citizen Exchanges Pass-through Awards: Pass-through Entity Pass through Award Number Award Period The Aspen Institute SI_SOL4_SubR-2021 April 1, 2021 through June 30, 2023 The Aspen Institute SI_SOL3_SubR-2020 April 1, 2021 through June 30, 2023 Criteria or Specific Requirement: In accordance with ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to 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. All procurement transactions must be conducted in a manner providing full and open competition consistent in accordance with ?200.319 and must be performed using the appropriate procurement method as outlined in ?200.320. In accordance with ?200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135.Condition: During our testing of compliance, we identified the following matters: ? The Organization?s subsidiary Soliya did not have a written procurement policy that complied with the federal requirements presented above. ? For three procurement samples of a total of nine items teested for AL# 19.415, management did not provide adequate supporting documentation for the procurement transaction. BDO was only provided a copy of the authorized contract between the consultant and Soliya. No other information to support compliance with federal procurement requirements was provided. Questioned Costs: Total known questioned costs are $6,656. Context: This is a condition based on testing of Soliya?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: Soliya did not adopt a written procurement policy that was compliant with the Uniform Administrative Requirements. In addition Soliya was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: We recommend management of Soliya adopt Search for Common Ground?s procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff of Soliya are trained on this policy to help ensure compliance going forward.
Information on the Federal Program: United States Department of State Assistance Listing Number: 19.415 Assistance Listing Name: Professional and Cultural Exchange Programs ? Citizen Exchanges Pass-through Awards: Pass-through Entity Pass through Award Number Award Period The Aspen Institute SI_SOL4_SubR-2021 April 1, 2021 through June 30, 2023 The Aspen Institute SI_SOL3_SubR-2020 April 1, 2021 through June 30, 2023 Criteria or Specific Requirement: In accordance with ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to 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. All procurement transactions must be conducted in a manner providing full and open competition consistent in accordance with ?200.319 and must be performed using the appropriate procurement method as outlined in ?200.320. In accordance with ?200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135.Condition: During our testing of compliance, we identified the following matters: ? The Organization?s subsidiary Soliya did not have a written procurement policy that complied with the federal requirements presented above. ? For three procurement samples of a total of nine items teested for AL# 19.415, management did not provide adequate supporting documentation for the procurement transaction. BDO was only provided a copy of the authorized contract between the consultant and Soliya. No other information to support compliance with federal procurement requirements was provided. Questioned Costs: Total known questioned costs are $6,656. Context: This is a condition based on testing of Soliya?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: Soliya did not adopt a written procurement policy that was compliant with the Uniform Administrative Requirements. In addition Soliya was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: We recommend management of Soliya adopt Search for Common Ground?s procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff of Soliya are trained on this policy to help ensure compliance going forward.
Information on the Federal Program(s): United States Department of the State Assistance Listing Number: 19.345 Assistance Listing Name: International Programs to Support Democracy, Human Rights and Labor Award Number:Direct Award Number Award Period SLMAQM21GR3097 July 15, 2021 through December 31, 2022 United States Department of the State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Number: Direct Award Number Award Period SLMAQM20CA2264 September 28, 2020 through September 30, 2024 Criteria or Specific Requirement: The Federal Funding Accountability and Transparency Act, as codified in 2 CFR Part 170, requires prime awardees awarded a federal grant to file a Federal Funding Accountability and Transparency Act (FFATA) report when the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: During our subrecipient testing for the major programs, we determined management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during BDO?s testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization did not comply with FFATA reporting requirements as there was not a control in place to ensure FFATA reporting was completed when required by 2 CFR Part 170. Effect: Failure to comply with the FFATA requirement may out the grant funding at risk due to noncompliance under the Uniform Guidance. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2021- 003 in the 2021 schedule of findings and questioned costs. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings in arrears are immediately filed.
2022-002 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Numbers: Direct Award Numbers Award Period SLMAQM20CA2264 September 28, 2020 through March 29, 2024 SLMAQM20GR2364 September 28, 2020 through September 30, 2024 Criteria: CFR Section ?200.510(b) states in part: ?The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section ?200.502 Basis for determining Federal awards expended.? The schedule must provide total Federal awards expended for each individual Federal program. In accordance with ?200.302 Financial Management, a non-federal entity?s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management?s preparation of the SEFA, BDO identified two awards whose assistance listing number was changed by the federal entity in award amendments issued prior to December 31, 2022. Management failed to update the assistance listing number for the awards within the SEFA to address the award modifications. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not fully operate as designed. The Organization did not adequately review award modifications for changes to existing awards. Effect: The SEFA initially provided to BDO resulted in incorrect major program selection as prescribed under the Unform Guidance. During the review of the award agreements, BDO identified the assistance listing numbers for the two awards had been modified. This issue resulted in a different major program selection once the SEFA was updated to reflect the correct assistance listing numbers. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management to continue to focus on training for both preparer and reviewers of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section ?200.510(b). This will ensure that the SEFA provides all relevant information as proscribed.
2022-002 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Numbers: Direct Award Numbers Award Period SLMAQM20CA2264 September 28, 2020 through March 29, 2024 SLMAQM20GR2364 September 28, 2020 through September 30, 2024 Criteria: CFR Section ?200.510(b) states in part: ?The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section ?200.502 Basis for determining Federal awards expended.? The schedule must provide total Federal awards expended for each individual Federal program. In accordance with ?200.302 Financial Management, a non-federal entity?s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management?s preparation of the SEFA, BDO identified two awards whose assistance listing number was changed by the federal entity in award amendments issued prior to December 31, 2022. Management failed to update the assistance listing number for the awards within the SEFA to address the award modifications. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not fully operate as designed. The Organization did not adequately review award modifications for changes to existing awards. Effect: The SEFA initially provided to BDO resulted in incorrect major program selection as prescribed under the Unform Guidance. During the review of the award agreements, BDO identified the assistance listing numbers for the two awards had been modified. This issue resulted in a different major program selection once the SEFA was updated to reflect the correct assistance listing numbers. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management to continue to focus on training for both preparer and reviewers of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section ?200.510(b). This will ensure that the SEFA provides all relevant information as proscribed.