Audit 309269

2023-003 – Internal Control over Compliance and Compliance with Reporting Information on the Major Federal Program: Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment and Appropriation Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2022 to September 30, 2023 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of the Federal Funding and Accountability Act (FFATA), which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, the Foundation is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition – During our testing of reporting, we selected seven subrecipient awards. For all samples tested, the Foundation did not comply with the mandatory FFATA report filing requirements. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 7 7 7 Not applicable – no report was submitted Not applicable – no report was submitted Dollar Amount of Tested 2023 Subawards Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 843,636 $ 843,636 $ 843,636 Not applicable – no report was submitted Not applicable – no report was submitted Cause - The Foundation did not have adequate policies and procedures in place to ensure compliance with the FFATA filing requirements. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance and awarding agency taking administrative action. Questioned Costs – None. Context - This is a condition identified based upon our review of the Foundation’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these finding is detailed in the condition section above. Repeat Finding – This is a repeat finding from prior year. This was reported as finding 2022-001 in the 2022 report. Recommendation – BDO noted management’s actions to address prior year finding, however, due to certain FFATA requirements to file, management is still unable to file the required FFATA reporting. BDO recommends that the Foundation continue to work with federal grantor/agencies to determine the required information and immediately file the required requirements. Views of Responsible Officials – The Foundation’s management agrees with the finding and recommendation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.

2023-002 - Internal Controls Over Compliance and Compliance with Reporting - Preparation of the Schedule of Expenditures of Federal Awards Information on the Major Federal Program - Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2022 to September 30, 2023 Criteria - The Uniform Guidance in 2 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 2 CFR Section 200.502 Basis for determining Federal awards expended.” The Schedule must provide total Federal awards expended for each individual Federal program. Condition – During the testing of the schedule of expenditures of federal awards (SEFA) for the National Park Service Second Century Endowment for the year-end September 30, 2023, we identified transactions totaling $1,848,493 which were improperly included in the SEFA. These expenditures were not incurred during the fiscal year and should not have been included in the SEFA. Cause - The internal controls established for the review and reconciliation of the SEFA to the underlying accounting records were not consistently followed to ensure accurate reporting of expenditures to the SEFA. Effect or Potential Effect - Failure to properly review and support expenditures reported in the SEFA can result in inaccurate reporting and non-compliance with laws and regulations. Questioned Costs - None. Context - We reviewed the SEFA and found the exception as noted in the condition. Repeat Finding - This is not a repeat finding. Recommendation - Internal controls should be designed to prevent, detect and correct errors and/or omissions in a timely manner. Without adequate controls, the Foundation cannot provide reasonable assurance that the SEFA is fairly presented. See management’s response for further details. Views of Responsible Officials - Management agrees with this finding and recommendation. The Foundation’s management agrees with the finding and recommendation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.

2023-003 – Internal Control over Compliance and Compliance with Reporting Information on the Major Federal Program: Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment and Appropriation Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2022 to September 30, 2023 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of the Federal Funding and Accountability Act (FFATA), which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, the Foundation is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition – During our testing of reporting, we selected seven subrecipient awards. For all samples tested, the Foundation did not comply with the mandatory FFATA report filing requirements. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 7 7 7 Not applicable – no report was submitted Not applicable – no report was submitted Dollar Amount of Tested 2023 Subawards Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 843,636 $ 843,636 $ 843,636 Not applicable – no report was submitted Not applicable – no report was submitted Cause - The Foundation did not have adequate policies and procedures in place to ensure compliance with the FFATA filing requirements. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance and awarding agency taking administrative action. Questioned Costs – None. Context - This is a condition identified based upon our review of the Foundation’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these finding is detailed in the condition section above. Repeat Finding – This is a repeat finding from prior year. This was reported as finding 2022-001 in the 2022 report. Recommendation – BDO noted management’s actions to address prior year finding, however, due to certain FFATA requirements to file, management is still unable to file the required FFATA reporting. BDO recommends that the Foundation continue to work with federal grantor/agencies to determine the required information and immediately file the required requirements. Views of Responsible Officials – The Foundation’s management agrees with the finding and recommendation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.

2023-003 – Internal Control over Compliance and Compliance with Reporting Information on the Major Federal Program: Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment and Appropriation Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2022 to September 30, 2023 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of the Federal Funding and Accountability Act (FFATA), which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, the Foundation is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition – During our testing of reporting, we selected seven subrecipient awards. For all samples tested, the Foundation did not comply with the mandatory FFATA report filing requirements. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 7 7 7 Not applicable – no report was submitted Not applicable – no report was submitted Dollar Amount of Tested 2023 Subawards Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 843,636 $ 843,636 $ 843,636 Not applicable – no report was submitted Not applicable – no report was submitted Cause - The Foundation did not have adequate policies and procedures in place to ensure compliance with the FFATA filing requirements. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance and awarding agency taking administrative action. Questioned Costs – None. Context - This is a condition identified based upon our review of the Foundation’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these finding is detailed in the condition section above. Repeat Finding – This is a repeat finding from prior year. This was reported as finding 2022-001 in the 2022 report. Recommendation – BDO noted management’s actions to address prior year finding, however, due to certain FFATA requirements to file, management is still unable to file the required FFATA reporting. BDO recommends that the Foundation continue to work with federal grantor/agencies to determine the required information and immediately file the required requirements. Views of Responsible Officials – The Foundation’s management agrees with the finding and recommendation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.

2023-002 - Internal Controls Over Compliance and Compliance with Reporting - Preparation of the Schedule of Expenditures of Federal Awards Information on the Major Federal Program - Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2022 to September 30, 2023 Criteria - The Uniform Guidance in 2 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 2 CFR Section 200.502 Basis for determining Federal awards expended.” The Schedule must provide total Federal awards expended for each individual Federal program. Condition – During the testing of the schedule of expenditures of federal awards (SEFA) for the National Park Service Second Century Endowment for the year-end September 30, 2023, we identified transactions totaling $1,848,493 which were improperly included in the SEFA. These expenditures were not incurred during the fiscal year and should not have been included in the SEFA. Cause - The internal controls established for the review and reconciliation of the SEFA to the underlying accounting records were not consistently followed to ensure accurate reporting of expenditures to the SEFA. Effect or Potential Effect - Failure to properly review and support expenditures reported in the SEFA can result in inaccurate reporting and non-compliance with laws and regulations. Questioned Costs - None. Context - We reviewed the SEFA and found the exception as noted in the condition. Repeat Finding - This is not a repeat finding. Recommendation - Internal controls should be designed to prevent, detect and correct errors and/or omissions in a timely manner. Without adequate controls, the Foundation cannot provide reasonable assurance that the SEFA is fairly presented. See management’s response for further details. Views of Responsible Officials - Management agrees with this finding and recommendation. The Foundation’s management agrees with the finding and recommendation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.

2023-003 – Internal Control over Compliance and Compliance with Reporting Information on the Major Federal Program: Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment and Appropriation Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2022 to September 30, 2023 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of the Federal Funding and Accountability Act (FFATA), which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, the Foundation is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition – During our testing of reporting, we selected seven subrecipient awards. For all samples tested, the Foundation did not comply with the mandatory FFATA report filing requirements. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 7 7 7 Not applicable – no report was submitted Not applicable – no report was submitted Dollar Amount of Tested 2023 Subawards Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 843,636 $ 843,636 $ 843,636 Not applicable – no report was submitted Not applicable – no report was submitted Cause - The Foundation did not have adequate policies and procedures in place to ensure compliance with the FFATA filing requirements. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance and awarding agency taking administrative action. Questioned Costs – None. Context - This is a condition identified based upon our review of the Foundation’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these finding is detailed in the condition section above. Repeat Finding – This is a repeat finding from prior year. This was reported as finding 2022-001 in the 2022 report. Recommendation – BDO noted management’s actions to address prior year finding, however, due to certain FFATA requirements to file, management is still unable to file the required FFATA reporting. BDO recommends that the Foundation continue to work with federal grantor/agencies to determine the required information and immediately file the required requirements. Views of Responsible Officials – The Foundation’s management agrees with the finding and recommendation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.