Finding # 2023-001 Timely Program Reporting Submission (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: §200.329 Monitoring and reporting program performance (c)(1)
states that “The non-Federal entity must submit performance reports at the interval required by the
Federal awarding agency”.
Condition: As part of our compliance audit over the Institute’s programmatic reporting requirements
under the major program, we noted multiple instances in which programmatic reports were not
submitted to the federal agency by the deadline stated in the grant agreement. In some cases,
reports were submitted after extended deadlines. Ultimately, all reports were completed and
accepted by the donor.
Cause: The final submission dates observed in this review were necessary because of a temporary
overlapping period on programs (LCWT and TKV). The need for this extra time was communicated
with the funder, however, such communication was not properly documented as amended
submission times. Lack of formalized communication rather than a delayed submission.
Effect or Potential Effect: Late program report submissions result in delays of program monitoring
and evaluation.
Questioned Costs: N/A
Context: As a federal award recipient, the Institute is responsible for oversight of the operations of
the Federal award supported activities. The Institute must monitor its activities under Federal awards
to assure compliance with applicable federal requirements and that performance expectations are
being achieved. Federal awards require varying programmatic reports to be submitted according to
the timeframe stated in the grant agreement.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute review its policies and procedures and
strengthen internal controls to ensure that all programmatic reports are submitted to the donor by the
deadlines stipulated in the terms of the agreement.
Finding # 2023-002 Procurement, Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the
non-federal entity must maintain records sufficient to detail the history of procurement. These
records will include, but are not necessarily limited to the following: rationale for the method of
procurement, selection of contract type, contractor selection or rejection, and the basis for the
contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that
procurement by noncompetitive proposals is procurement through solicitation of a proposal from only
one source and may be used only when certain requirements have been met. Additionally, §200.213
Reporting a determination that a non-Federal entity is not qualified for a Federal award states that
non-federal entities are subject to the non-procurement debarment and suspension regulations
implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict
awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise
excluded from or ineligible for participation in federal assistance programs or activities. The nonfederal
entity must verify that the person with whom you intend to do business is not excluded or
disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c)
adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the federal awards for which
evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable
for our inspection. It is our understanding that some contracts were procured under noncompetitive
(sole source) justification. However, in certain instances we were unable to review documentation
(prepared at the time the contracts were executed) detailing the history and rationale of the
procurements.
Cause: The Institute's processes in place during 2023 did not provide for the formalization and
retention of procurement records and vendor screenings consistent with the expectations outlined in
2 CFR 200 and related guidance provided by USAID.
Effect or Potential Effect: Purchases of goods and services could be made above the prevailing
market rates if the prescribed procurement procedures are not adhered to. Additionally, the Institute
may have inadvertently selected noncompetitive proposals method when the circumstances did not
meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby
failing to administer full and open competition as required by the regulations. Finally, the Institute
could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or
otherwise included on the US Federal sanction list.
Questioned Costs: N/A
Context: Our audit sample consisted of transactions incurred by both JGI USA and JGI Tanzania.
The finding relates to a transaction incurred by both entities. Both entities have defined procurement
policies.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute ensure its policy is distributed and
communicated in a formal manner to its employees, and that management properly enforce
compliance with its policy. All procurement actions should be clearly documented in writing and
maintained in the vendor or contractor files. Such documentation should include, but is not limited to;
(1) Bids (2) Bid Analysis with documentation of vendor selection and rationale (3) Minutes of
meetings of procurement committee (4) for sole source procurements, documentation of which of the
allowable sole source criteria the procurement was done under. Additionally, we recommend that the
procurement policies are enhanced to include compliance with §200.320 (f) Methods of procurement
to be followed and, §200.213 Reporting a determination that a non-Federal entity is not qualified for
a Federal award.
Finding # 2023-003 Subrecipient Monitoring (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: § 200.332, Requirements for pass-through entities, requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the
appropriate subrecipient monitoring. The statute also requires pass-through entities to include
certain federal award identifying information within the subaward agreement.
Condition: The Institute maintains subaward selection and monitoring policies. However, the
policies do not include pre-prescribed monitoring procedures based on an assessed level of risk
assigned in the subaward selection stage. Additionally, as part of our audit, we selected a sample of
subawards charged to the major federal programs. We noted that a subaward agreement did not
contain certain federal award identifying information, specifically the relevant Federal Assistance
Listing Number (ALN).
Cause: The Institute maintains subaward selection and monitoring policies that do not include preprescribed
monitoring procedures based on an assessed level of risk. Additionally, Federal
Assistance Listing Number were omitted from the subaward agreements based on an oversight
during the subaward writing process.
Effect or Potential Effect: The Institute may have inadvertently failed to perform monitoring
procedures appropriate for a subrecipient’s assessed level of risk. Not including Federal Assistance
Listing Numbers in the subaward agreement could lead to the subrecipient omitting the subaward
from its Schedule of Expenditures of Federal Awards.
Questioned Costs: N/A
Context: The Institute executes subaward agreements under US Federal grants. Therefore, the
Institute is subject to § 200.332 Requirements for pass-through entities. Our audit procedures
consisted of testwork completed on subawards charged to the federal awards. The report in which
samples were selected was generated directly from the Institute’s general ledger (accounting
system). We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute revise its subaward selection and monitoring
policies to include pre-prescribed monitoring procedures based on an assessed level of risk
assigned in the subaward selection stage. The assessed level of risk should be documented in a
pre-award risk assessment. Additionally, we recommend that the Institute ensure that all subaward
agreements include all elements required by §200.332.
Finding # 2023-004 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA
subaward report by the end of the month following the month in which the prime recipient awards
any subaward with a value greater than or equal to $30,000.
Condition: We noted one instance in which the Institute did not report a subaward in the Federal
Subaward Reporting System as required by 2 CFR Part 170.
Cause: The Institute was unaware of the FFATA report filing requirement.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially
result in withholding of future payments, award suspension or termination, and ineligibility for future
awards.
Questioned Costs: N/A
Context: There were three subawards under the major program. We selected one subaward for
which to test the FFATA reporting requirements. The sample is considered to be representative of
the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the Institute take steps to raise awareness of the FFATA
reporting requirements and associated deadlines to those staff responsible for compliance with
FFATA reporting requirements. The Institute should ensure reports are filed for all existing and future
first tier subawards in excess of $30,000. Requirements for FFATA reporting should be included in
the Institutes subaward selection and monitoring policies.
Finding # 2023-001 Timely Program Reporting Submission (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: §200.329 Monitoring and reporting program performance (c)(1)
states that “The non-Federal entity must submit performance reports at the interval required by the
Federal awarding agency”.
Condition: As part of our compliance audit over the Institute’s programmatic reporting requirements
under the major program, we noted multiple instances in which programmatic reports were not
submitted to the federal agency by the deadline stated in the grant agreement. In some cases,
reports were submitted after extended deadlines. Ultimately, all reports were completed and
accepted by the donor.
Cause: The final submission dates observed in this review were necessary because of a temporary
overlapping period on programs (LCWT and TKV). The need for this extra time was communicated
with the funder, however, such communication was not properly documented as amended
submission times. Lack of formalized communication rather than a delayed submission.
Effect or Potential Effect: Late program report submissions result in delays of program monitoring
and evaluation.
Questioned Costs: N/A
Context: As a federal award recipient, the Institute is responsible for oversight of the operations of
the Federal award supported activities. The Institute must monitor its activities under Federal awards
to assure compliance with applicable federal requirements and that performance expectations are
being achieved. Federal awards require varying programmatic reports to be submitted according to
the timeframe stated in the grant agreement.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute review its policies and procedures and
strengthen internal controls to ensure that all programmatic reports are submitted to the donor by the
deadlines stipulated in the terms of the agreement.
Finding # 2023-002 Procurement, Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the
non-federal entity must maintain records sufficient to detail the history of procurement. These
records will include, but are not necessarily limited to the following: rationale for the method of
procurement, selection of contract type, contractor selection or rejection, and the basis for the
contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that
procurement by noncompetitive proposals is procurement through solicitation of a proposal from only
one source and may be used only when certain requirements have been met. Additionally, §200.213
Reporting a determination that a non-Federal entity is not qualified for a Federal award states that
non-federal entities are subject to the non-procurement debarment and suspension regulations
implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict
awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise
excluded from or ineligible for participation in federal assistance programs or activities. The nonfederal
entity must verify that the person with whom you intend to do business is not excluded or
disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c)
adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the federal awards for which
evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable
for our inspection. It is our understanding that some contracts were procured under noncompetitive
(sole source) justification. However, in certain instances we were unable to review documentation
(prepared at the time the contracts were executed) detailing the history and rationale of the
procurements.
Cause: The Institute's processes in place during 2023 did not provide for the formalization and
retention of procurement records and vendor screenings consistent with the expectations outlined in
2 CFR 200 and related guidance provided by USAID.
Effect or Potential Effect: Purchases of goods and services could be made above the prevailing
market rates if the prescribed procurement procedures are not adhered to. Additionally, the Institute
may have inadvertently selected noncompetitive proposals method when the circumstances did not
meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby
failing to administer full and open competition as required by the regulations. Finally, the Institute
could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or
otherwise included on the US Federal sanction list.
Questioned Costs: N/A
Context: Our audit sample consisted of transactions incurred by both JGI USA and JGI Tanzania.
The finding relates to a transaction incurred by both entities. Both entities have defined procurement
policies.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute ensure its policy is distributed and
communicated in a formal manner to its employees, and that management properly enforce
compliance with its policy. All procurement actions should be clearly documented in writing and
maintained in the vendor or contractor files. Such documentation should include, but is not limited to;
(1) Bids (2) Bid Analysis with documentation of vendor selection and rationale (3) Minutes of
meetings of procurement committee (4) for sole source procurements, documentation of which of the
allowable sole source criteria the procurement was done under. Additionally, we recommend that the
procurement policies are enhanced to include compliance with §200.320 (f) Methods of procurement
to be followed and, §200.213 Reporting a determination that a non-Federal entity is not qualified for
a Federal award.
Finding # 2023-003 Subrecipient Monitoring (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: § 200.332, Requirements for pass-through entities, requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the
appropriate subrecipient monitoring. The statute also requires pass-through entities to include
certain federal award identifying information within the subaward agreement.
Condition: The Institute maintains subaward selection and monitoring policies. However, the
policies do not include pre-prescribed monitoring procedures based on an assessed level of risk
assigned in the subaward selection stage. Additionally, as part of our audit, we selected a sample of
subawards charged to the major federal programs. We noted that a subaward agreement did not
contain certain federal award identifying information, specifically the relevant Federal Assistance
Listing Number (ALN).
Cause: The Institute maintains subaward selection and monitoring policies that do not include preprescribed
monitoring procedures based on an assessed level of risk. Additionally, Federal
Assistance Listing Number were omitted from the subaward agreements based on an oversight
during the subaward writing process.
Effect or Potential Effect: The Institute may have inadvertently failed to perform monitoring
procedures appropriate for a subrecipient’s assessed level of risk. Not including Federal Assistance
Listing Numbers in the subaward agreement could lead to the subrecipient omitting the subaward
from its Schedule of Expenditures of Federal Awards.
Questioned Costs: N/A
Context: The Institute executes subaward agreements under US Federal grants. Therefore, the
Institute is subject to § 200.332 Requirements for pass-through entities. Our audit procedures
consisted of testwork completed on subawards charged to the federal awards. The report in which
samples were selected was generated directly from the Institute’s general ledger (accounting
system). We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute revise its subaward selection and monitoring
policies to include pre-prescribed monitoring procedures based on an assessed level of risk
assigned in the subaward selection stage. The assessed level of risk should be documented in a
pre-award risk assessment. Additionally, we recommend that the Institute ensure that all subaward
agreements include all elements required by §200.332.
Finding # 2023-004 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA
subaward report by the end of the month following the month in which the prime recipient awards
any subaward with a value greater than or equal to $30,000.
Condition: We noted one instance in which the Institute did not report a subaward in the Federal
Subaward Reporting System as required by 2 CFR Part 170.
Cause: The Institute was unaware of the FFATA report filing requirement.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially
result in withholding of future payments, award suspension or termination, and ineligibility for future
awards.
Questioned Costs: N/A
Context: There were three subawards under the major program. We selected one subaward for
which to test the FFATA reporting requirements. The sample is considered to be representative of
the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the Institute take steps to raise awareness of the FFATA
reporting requirements and associated deadlines to those staff responsible for compliance with
FFATA reporting requirements. The Institute should ensure reports are filed for all existing and future
first tier subawards in excess of $30,000. Requirements for FFATA reporting should be included in
the Institutes subaward selection and monitoring policies.
Finding # 2023-001 Timely Program Reporting Submission (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: §200.329 Monitoring and reporting program performance (c)(1)
states that “The non-Federal entity must submit performance reports at the interval required by the
Federal awarding agency”.
Condition: As part of our compliance audit over the Institute’s programmatic reporting requirements
under the major program, we noted multiple instances in which programmatic reports were not
submitted to the federal agency by the deadline stated in the grant agreement. In some cases,
reports were submitted after extended deadlines. Ultimately, all reports were completed and
accepted by the donor.
Cause: The final submission dates observed in this review were necessary because of a temporary
overlapping period on programs (LCWT and TKV). The need for this extra time was communicated
with the funder, however, such communication was not properly documented as amended
submission times. Lack of formalized communication rather than a delayed submission.
Effect or Potential Effect: Late program report submissions result in delays of program monitoring
and evaluation.
Questioned Costs: N/A
Context: As a federal award recipient, the Institute is responsible for oversight of the operations of
the Federal award supported activities. The Institute must monitor its activities under Federal awards
to assure compliance with applicable federal requirements and that performance expectations are
being achieved. Federal awards require varying programmatic reports to be submitted according to
the timeframe stated in the grant agreement.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute review its policies and procedures and
strengthen internal controls to ensure that all programmatic reports are submitted to the donor by the
deadlines stipulated in the terms of the agreement.
Finding # 2023-002 Procurement, Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the
non-federal entity must maintain records sufficient to detail the history of procurement. These
records will include, but are not necessarily limited to the following: rationale for the method of
procurement, selection of contract type, contractor selection or rejection, and the basis for the
contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that
procurement by noncompetitive proposals is procurement through solicitation of a proposal from only
one source and may be used only when certain requirements have been met. Additionally, §200.213
Reporting a determination that a non-Federal entity is not qualified for a Federal award states that
non-federal entities are subject to the non-procurement debarment and suspension regulations
implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict
awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise
excluded from or ineligible for participation in federal assistance programs or activities. The nonfederal
entity must verify that the person with whom you intend to do business is not excluded or
disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c)
adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the federal awards for which
evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable
for our inspection. It is our understanding that some contracts were procured under noncompetitive
(sole source) justification. However, in certain instances we were unable to review documentation
(prepared at the time the contracts were executed) detailing the history and rationale of the
procurements.
Cause: The Institute's processes in place during 2023 did not provide for the formalization and
retention of procurement records and vendor screenings consistent with the expectations outlined in
2 CFR 200 and related guidance provided by USAID.
Effect or Potential Effect: Purchases of goods and services could be made above the prevailing
market rates if the prescribed procurement procedures are not adhered to. Additionally, the Institute
may have inadvertently selected noncompetitive proposals method when the circumstances did not
meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby
failing to administer full and open competition as required by the regulations. Finally, the Institute
could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or
otherwise included on the US Federal sanction list.
Questioned Costs: N/A
Context: Our audit sample consisted of transactions incurred by both JGI USA and JGI Tanzania.
The finding relates to a transaction incurred by both entities. Both entities have defined procurement
policies.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute ensure its policy is distributed and
communicated in a formal manner to its employees, and that management properly enforce
compliance with its policy. All procurement actions should be clearly documented in writing and
maintained in the vendor or contractor files. Such documentation should include, but is not limited to;
(1) Bids (2) Bid Analysis with documentation of vendor selection and rationale (3) Minutes of
meetings of procurement committee (4) for sole source procurements, documentation of which of the
allowable sole source criteria the procurement was done under. Additionally, we recommend that the
procurement policies are enhanced to include compliance with §200.320 (f) Methods of procurement
to be followed and, §200.213 Reporting a determination that a non-Federal entity is not qualified for
a Federal award.
Finding # 2023-003 Subrecipient Monitoring (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: § 200.332, Requirements for pass-through entities, requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the
appropriate subrecipient monitoring. The statute also requires pass-through entities to include
certain federal award identifying information within the subaward agreement.
Condition: The Institute maintains subaward selection and monitoring policies. However, the
policies do not include pre-prescribed monitoring procedures based on an assessed level of risk
assigned in the subaward selection stage. Additionally, as part of our audit, we selected a sample of
subawards charged to the major federal programs. We noted that a subaward agreement did not
contain certain federal award identifying information, specifically the relevant Federal Assistance
Listing Number (ALN).
Cause: The Institute maintains subaward selection and monitoring policies that do not include preprescribed
monitoring procedures based on an assessed level of risk. Additionally, Federal
Assistance Listing Number were omitted from the subaward agreements based on an oversight
during the subaward writing process.
Effect or Potential Effect: The Institute may have inadvertently failed to perform monitoring
procedures appropriate for a subrecipient’s assessed level of risk. Not including Federal Assistance
Listing Numbers in the subaward agreement could lead to the subrecipient omitting the subaward
from its Schedule of Expenditures of Federal Awards.
Questioned Costs: N/A
Context: The Institute executes subaward agreements under US Federal grants. Therefore, the
Institute is subject to § 200.332 Requirements for pass-through entities. Our audit procedures
consisted of testwork completed on subawards charged to the federal awards. The report in which
samples were selected was generated directly from the Institute’s general ledger (accounting
system). We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute revise its subaward selection and monitoring
policies to include pre-prescribed monitoring procedures based on an assessed level of risk
assigned in the subaward selection stage. The assessed level of risk should be documented in a
pre-award risk assessment. Additionally, we recommend that the Institute ensure that all subaward
agreements include all elements required by §200.332.
Finding # 2023-004 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA
subaward report by the end of the month following the month in which the prime recipient awards
any subaward with a value greater than or equal to $30,000.
Condition: We noted one instance in which the Institute did not report a subaward in the Federal
Subaward Reporting System as required by 2 CFR Part 170.
Cause: The Institute was unaware of the FFATA report filing requirement.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially
result in withholding of future payments, award suspension or termination, and ineligibility for future
awards.
Questioned Costs: N/A
Context: There were three subawards under the major program. We selected one subaward for
which to test the FFATA reporting requirements. The sample is considered to be representative of
the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the Institute take steps to raise awareness of the FFATA
reporting requirements and associated deadlines to those staff responsible for compliance with
FFATA reporting requirements. The Institute should ensure reports are filed for all existing and future
first tier subawards in excess of $30,000. Requirements for FFATA reporting should be included in
the Institutes subaward selection and monitoring policies.
Finding # 2023-001 Timely Program Reporting Submission (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: §200.329 Monitoring and reporting program performance (c)(1)
states that “The non-Federal entity must submit performance reports at the interval required by the
Federal awarding agency”.
Condition: As part of our compliance audit over the Institute’s programmatic reporting requirements
under the major program, we noted multiple instances in which programmatic reports were not
submitted to the federal agency by the deadline stated in the grant agreement. In some cases,
reports were submitted after extended deadlines. Ultimately, all reports were completed and
accepted by the donor.
Cause: The final submission dates observed in this review were necessary because of a temporary
overlapping period on programs (LCWT and TKV). The need for this extra time was communicated
with the funder, however, such communication was not properly documented as amended
submission times. Lack of formalized communication rather than a delayed submission.
Effect or Potential Effect: Late program report submissions result in delays of program monitoring
and evaluation.
Questioned Costs: N/A
Context: As a federal award recipient, the Institute is responsible for oversight of the operations of
the Federal award supported activities. The Institute must monitor its activities under Federal awards
to assure compliance with applicable federal requirements and that performance expectations are
being achieved. Federal awards require varying programmatic reports to be submitted according to
the timeframe stated in the grant agreement.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute review its policies and procedures and
strengthen internal controls to ensure that all programmatic reports are submitted to the donor by the
deadlines stipulated in the terms of the agreement.
Finding # 2023-002 Procurement, Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the
non-federal entity must maintain records sufficient to detail the history of procurement. These
records will include, but are not necessarily limited to the following: rationale for the method of
procurement, selection of contract type, contractor selection or rejection, and the basis for the
contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that
procurement by noncompetitive proposals is procurement through solicitation of a proposal from only
one source and may be used only when certain requirements have been met. Additionally, §200.213
Reporting a determination that a non-Federal entity is not qualified for a Federal award states that
non-federal entities are subject to the non-procurement debarment and suspension regulations
implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict
awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise
excluded from or ineligible for participation in federal assistance programs or activities. The nonfederal
entity must verify that the person with whom you intend to do business is not excluded or
disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c)
adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the federal awards for which
evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable
for our inspection. It is our understanding that some contracts were procured under noncompetitive
(sole source) justification. However, in certain instances we were unable to review documentation
(prepared at the time the contracts were executed) detailing the history and rationale of the
procurements.
Cause: The Institute's processes in place during 2023 did not provide for the formalization and
retention of procurement records and vendor screenings consistent with the expectations outlined in
2 CFR 200 and related guidance provided by USAID.
Effect or Potential Effect: Purchases of goods and services could be made above the prevailing
market rates if the prescribed procurement procedures are not adhered to. Additionally, the Institute
may have inadvertently selected noncompetitive proposals method when the circumstances did not
meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby
failing to administer full and open competition as required by the regulations. Finally, the Institute
could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or
otherwise included on the US Federal sanction list.
Questioned Costs: N/A
Context: Our audit sample consisted of transactions incurred by both JGI USA and JGI Tanzania.
The finding relates to a transaction incurred by both entities. Both entities have defined procurement
policies.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute ensure its policy is distributed and
communicated in a formal manner to its employees, and that management properly enforce
compliance with its policy. All procurement actions should be clearly documented in writing and
maintained in the vendor or contractor files. Such documentation should include, but is not limited to;
(1) Bids (2) Bid Analysis with documentation of vendor selection and rationale (3) Minutes of
meetings of procurement committee (4) for sole source procurements, documentation of which of the
allowable sole source criteria the procurement was done under. Additionally, we recommend that the
procurement policies are enhanced to include compliance with §200.320 (f) Methods of procurement
to be followed and, §200.213 Reporting a determination that a non-Federal entity is not qualified for
a Federal award.
Finding # 2023-003 Subrecipient Monitoring (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: § 200.332, Requirements for pass-through entities, requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the
appropriate subrecipient monitoring. The statute also requires pass-through entities to include
certain federal award identifying information within the subaward agreement.
Condition: The Institute maintains subaward selection and monitoring policies. However, the
policies do not include pre-prescribed monitoring procedures based on an assessed level of risk
assigned in the subaward selection stage. Additionally, as part of our audit, we selected a sample of
subawards charged to the major federal programs. We noted that a subaward agreement did not
contain certain federal award identifying information, specifically the relevant Federal Assistance
Listing Number (ALN).
Cause: The Institute maintains subaward selection and monitoring policies that do not include preprescribed
monitoring procedures based on an assessed level of risk. Additionally, Federal
Assistance Listing Number were omitted from the subaward agreements based on an oversight
during the subaward writing process.
Effect or Potential Effect: The Institute may have inadvertently failed to perform monitoring
procedures appropriate for a subrecipient’s assessed level of risk. Not including Federal Assistance
Listing Numbers in the subaward agreement could lead to the subrecipient omitting the subaward
from its Schedule of Expenditures of Federal Awards.
Questioned Costs: N/A
Context: The Institute executes subaward agreements under US Federal grants. Therefore, the
Institute is subject to § 200.332 Requirements for pass-through entities. Our audit procedures
consisted of testwork completed on subawards charged to the federal awards. The report in which
samples were selected was generated directly from the Institute’s general ledger (accounting
system). We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute revise its subaward selection and monitoring
policies to include pre-prescribed monitoring procedures based on an assessed level of risk
assigned in the subaward selection stage. The assessed level of risk should be documented in a
pre-award risk assessment. Additionally, we recommend that the Institute ensure that all subaward
agreements include all elements required by §200.332.
Finding # 2023-004 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA
subaward report by the end of the month following the month in which the prime recipient awards
any subaward with a value greater than or equal to $30,000.
Condition: We noted one instance in which the Institute did not report a subaward in the Federal
Subaward Reporting System as required by 2 CFR Part 170.
Cause: The Institute was unaware of the FFATA report filing requirement.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially
result in withholding of future payments, award suspension or termination, and ineligibility for future
awards.
Questioned Costs: N/A
Context: There were three subawards under the major program. We selected one subaward for
which to test the FFATA reporting requirements. The sample is considered to be representative of
the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend the Institute take steps to raise awareness of the FFATA
reporting requirements and associated deadlines to those staff responsible for compliance with
FFATA reporting requirements. The Institute should ensure reports are filed for all existing and future
first tier subawards in excess of $30,000. Requirements for FFATA reporting should be included in
the Institutes subaward selection and monitoring policies.