Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
2 CFR §180.300 mandates that when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition and Context
The Organization did not perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 2 of 2 vendors tested were not verified against the Excluded Parties List System.
Cause and Effect
The Organization does not have internal processes to properly identify excluded parties ineligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties.
Questioned Costs
N/A
Identification of Repeat Findings
2022-012
Recommendation
We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
The federal compliance supplement allows a de minimis indirect cost rate of 10% which may be applied by organizations which do not have a negotiated indirect cost rate. However, the contract for the major federal program specifies that the Organization may only use "5% of the amount of federal funding for this cooperative agreement for administrative costs, including indirect costs."
Condition and Context
During the test of the allowable costs, indirect costs were compared to the amount allowed under the contracts. The Organization did not apply either the indirect cost rate allowed under the contract, nor did it apply the indirect cost rate to the appropriate cost basis when calculating indirect costs to charge to the federal program.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
2022-011
Recommendation
We recommend the Organization update its policies to calculate indirect costs based on the contractually allowed basis and using rates as specified in its federal contracts.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
According to 2 CFR §200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ."
Condition and Context
During tests of financial statement balances, it was determined that multiple internal controls over financial reporting were not effective which would impact federal awards. See Findings 2023-001 through 2023-008 for additional information.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
N/A
Recommendation
We recommend the Organization update its policies to implement sufficient internal controls over financial reporting to be able to properly identify costs related to the program.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
2 CFR §180.300 mandates that when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition and Context
The Organization did not perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 2 of 2 vendors tested were not verified against the Excluded Parties List System.
Cause and Effect
The Organization does not have internal processes to properly identify excluded parties ineligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties.
Questioned Costs
N/A
Identification of Repeat Findings
2022-012
Recommendation
We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
The federal compliance supplement allows a de minimis indirect cost rate of 10% which may be applied by organizations which do not have a negotiated indirect cost rate. However, the contract for the major federal program specifies that the Organization may only use "5% of the amount of federal funding for this cooperative agreement for administrative costs, including indirect costs."
Condition and Context
During the test of the allowable costs, indirect costs were compared to the amount allowed under the contracts. The Organization did not apply either the indirect cost rate allowed under the contract, nor did it apply the indirect cost rate to the appropriate cost basis when calculating indirect costs to charge to the federal program.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
2022-011
Recommendation
We recommend the Organization update its policies to calculate indirect costs based on the contractually allowed basis and using rates as specified in its federal contracts.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
According to 2 CFR §200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ."
Condition and Context
During tests of financial statement balances, it was determined that multiple internal controls over financial reporting were not effective which would impact federal awards. See Findings 2023-001 through 2023-008 for additional information.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
N/A
Recommendation
We recommend the Organization update its policies to implement sufficient internal controls over financial reporting to be able to properly identify costs related to the program.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
2 CFR §180.300 mandates that when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition and Context
The Organization did not perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 2 of 2 vendors tested were not verified against the Excluded Parties List System.
Cause and Effect
The Organization does not have internal processes to properly identify excluded parties ineligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties.
Questioned Costs
N/A
Identification of Repeat Findings
2022-012
Recommendation
We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
The federal compliance supplement allows a de minimis indirect cost rate of 10% which may be applied by organizations which do not have a negotiated indirect cost rate. However, the contract for the major federal program specifies that the Organization may only use "5% of the amount of federal funding for this cooperative agreement for administrative costs, including indirect costs."
Condition and Context
During the test of the allowable costs, indirect costs were compared to the amount allowed under the contracts. The Organization did not apply either the indirect cost rate allowed under the contract, nor did it apply the indirect cost rate to the appropriate cost basis when calculating indirect costs to charge to the federal program.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
2022-011
Recommendation
We recommend the Organization update its policies to calculate indirect costs based on the contractually allowed basis and using rates as specified in its federal contracts.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
According to 2 CFR §200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ."
Condition and Context
During tests of financial statement balances, it was determined that multiple internal controls over financial reporting were not effective which would impact federal awards. See Findings 2023-001 through 2023-008 for additional information.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
N/A
Recommendation
We recommend the Organization update its policies to implement sufficient internal controls over financial reporting to be able to properly identify costs related to the program.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
2 CFR §180.300 mandates that when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition and Context
The Organization did not perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 2 of 2 vendors tested were not verified against the Excluded Parties List System.
Cause and Effect
The Organization does not have internal processes to properly identify excluded parties ineligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties.
Questioned Costs
N/A
Identification of Repeat Findings
2022-012
Recommendation
We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
The federal compliance supplement allows a de minimis indirect cost rate of 10% which may be applied by organizations which do not have a negotiated indirect cost rate. However, the contract for the major federal program specifies that the Organization may only use "5% of the amount of federal funding for this cooperative agreement for administrative costs, including indirect costs."
Condition and Context
During the test of the allowable costs, indirect costs were compared to the amount allowed under the contracts. The Organization did not apply either the indirect cost rate allowed under the contract, nor did it apply the indirect cost rate to the appropriate cost basis when calculating indirect costs to charge to the federal program.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
2022-011
Recommendation
We recommend the Organization update its policies to calculate indirect costs based on the contractually allowed basis and using rates as specified in its federal contracts.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
According to 2 CFR §200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ."
Condition and Context
During tests of financial statement balances, it was determined that multiple internal controls over financial reporting were not effective which would impact federal awards. See Findings 2023-001 through 2023-008 for additional information.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
N/A
Recommendation
We recommend the Organization update its policies to implement sufficient internal controls over financial reporting to be able to properly identify costs related to the program.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
2 CFR §180.300 mandates that when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition and Context
The Organization did not perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 2 of 2 vendors tested were not verified against the Excluded Parties List System.
Cause and Effect
The Organization does not have internal processes to properly identify excluded parties ineligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties.
Questioned Costs
N/A
Identification of Repeat Findings
2022-012
Recommendation
We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
The federal compliance supplement allows a de minimis indirect cost rate of 10% which may be applied by organizations which do not have a negotiated indirect cost rate. However, the contract for the major federal program specifies that the Organization may only use "5% of the amount of federal funding for this cooperative agreement for administrative costs, including indirect costs."
Condition and Context
During the test of the allowable costs, indirect costs were compared to the amount allowed under the contracts. The Organization did not apply either the indirect cost rate allowed under the contract, nor did it apply the indirect cost rate to the appropriate cost basis when calculating indirect costs to charge to the federal program.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
2022-011
Recommendation
We recommend the Organization update its policies to calculate indirect costs based on the contractually allowed basis and using rates as specified in its federal contracts.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
According to 2 CFR §200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ."
Condition and Context
During tests of financial statement balances, it was determined that multiple internal controls over financial reporting were not effective which would impact federal awards. See Findings 2023-001 through 2023-008 for additional information.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
N/A
Recommendation
We recommend the Organization update its policies to implement sufficient internal controls over financial reporting to be able to properly identify costs related to the program.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
2 CFR §180.300 mandates that when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition and Context
The Organization did not perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 2 of 2 vendors tested were not verified against the Excluded Parties List System.
Cause and Effect
The Organization does not have internal processes to properly identify excluded parties ineligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties.
Questioned Costs
N/A
Identification of Repeat Findings
2022-012
Recommendation
We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
The federal compliance supplement allows a de minimis indirect cost rate of 10% which may be applied by organizations which do not have a negotiated indirect cost rate. However, the contract for the major federal program specifies that the Organization may only use "5% of the amount of federal funding for this cooperative agreement for administrative costs, including indirect costs."
Condition and Context
During the test of the allowable costs, indirect costs were compared to the amount allowed under the contracts. The Organization did not apply either the indirect cost rate allowed under the contract, nor did it apply the indirect cost rate to the appropriate cost basis when calculating indirect costs to charge to the federal program.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
2022-011
Recommendation
We recommend the Organization update its policies to calculate indirect costs based on the contractually allowed basis and using rates as specified in its federal contracts.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.
Program Affected
66.818 Brownfields Assessment and Cleanup Cooperative Agreements
U.S. Environmental Protection Agency
Contract year: 2023
FAIN: 00A00664 / 00A00676 / 00A00909
Criteria
According to 2 CFR §200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ."
Condition and Context
During tests of financial statement balances, it was determined that multiple internal controls over financial reporting were not effective which would impact federal awards. See Findings 2023-001 through 2023-008 for additional information.
Cause and Effect
The Organization does not have internal processes to properly identify costs related to the program. As a result, indirect costs may exceed allowable thresholds.
Questioned Costs
N/A
Identification of Repeat Findings
N/A
Recommendation
We recommend the Organization update its policies to implement sufficient internal controls over financial reporting to be able to properly identify costs related to the program.
Views of Responsible Officials and Planned Corrective Actions
Management agrees with the finding. See attached Planned Corrective Actions.