Audit 322549

FY End

2023-12-31

Total Expended

$1.04M

Findings

2

Programs

2

Organization: Distilled Spirits Council of the United States, Inc. (DC)

Year: 2023 Accepted: 2024-09-30

Auditor: Aprio

Organization Exclusion Status:

Checking exclusion status...

ID	Ref	Severity	Repeat	Requirement
499733	2023-001	Significant Deficiency	Yes	I
1076175	2023-001	Significant Deficiency	Yes	I

ALN	Program	Spent	Major	Findings
10.601	Market Access Program	$1.01M	Yes	1
10.603	Emerging Markets Program	$33,115	-	0

Contacts

Name	Title	Type
L61ACDNCL7H9	Adrian Baxter	Auditee
2026828815	William Donahue	Auditor
No contacts on file

Notes to SEFA

Title: Basis of presentation Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal award activity of Distilled Spirits Council of the United States, Inc. under programs of the federal government for the year ended December 31, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of Distilled Spirits Council of the United States, Inc., it is not intended to and does not present the financial position, changes in net assets, functional expenses, or cash flows of Distilled Spirits Council of the United States, Inc. De Minimis Rate Used: N Rate Explanation: Distilled Spirits Council of the United States, Inc. has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal award activity of Distilled Spirits Council of the United States, Inc. under programs of the federal government for the year ended December 31, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of Distilled Spirits Council of the United States, Inc., it is not intended to and does not present the financial position, changes in net assets, functional expenses, or cash flows of Distilled Spirits Council of the United States, Inc.

Title: Summary of significant accounting policies Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal award activity of Distilled Spirits Council of the United States, Inc. under programs of the federal government for the year ended December 31, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of Distilled Spirits Council of the United States, Inc., it is not intended to and does not present the financial position, changes in net assets, functional expenses, or cash flows of Distilled Spirits Council of the United States, Inc. De Minimis Rate Used: N Rate Explanation: Distilled Spirits Council of the United States, Inc. has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting in accordance with accounting principles generally accepted in the United States of America. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement.

Title: Indirect cost rate Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal award activity of Distilled Spirits Council of the United States, Inc. under programs of the federal government for the year ended December 31, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of Distilled Spirits Council of the United States, Inc., it is not intended to and does not present the financial position, changes in net assets, functional expenses, or cash flows of Distilled Spirits Council of the United States, Inc. De Minimis Rate Used: N Rate Explanation: Distilled Spirits Council of the United States, Inc. has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. Distilled Spirits Council of the United States, Inc. has elected not to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance.

Finding Details

Finding 2023-001

Compliance Requirement: Procurement, Suspension, and Debarment Criteria: According to 2 CFR 200.318(a) non-federal entities must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of 2 CFR 200.318 through 200.327, for the acquisition of property or services required under a Federal award. Condition: During our testing of vendor procurement compliance, we noted the entity had a procurement policy in line with the federal award’s specific procurement guidelines but not in line with standards of 2 CFR 200.318 through 200.327. In particular, the policy did not address methods of procurement based on micro-purchase, small purchase, and simplified acquisition purchase thresholds, circumstances in which noncompetitive procurement could be used, and procedures for verifying that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause: The auditee was not aware of the requirements outlined in 2 CFR 200.318 through 200.327, and believed the contracting guidelines outlined for their specific award were sufficient. Effect: The auditee was not in compliance with procurement policies outlined in of 2 CFR 200.318 through 200.327. There was a lack of full and open competition and auditee did not ensure the vendors with which it planned to enter into a covered transaction were not debarred, suspended, or otherwise excluded. Repeat Finding: This is a repeat finding. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the Organization adopt an updated procurement policy in line with 2 CFR 200 requirements and ensure all staff involved in the acquisition of property or services charged to federal grants are aware of relevant procurement requirements.

Finding 2023-001

Compliance Requirement: Procurement, Suspension, and Debarment Criteria: According to 2 CFR 200.318(a) non-federal entities must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of 2 CFR 200.318 through 200.327, for the acquisition of property or services required under a Federal award. Condition: During our testing of vendor procurement compliance, we noted the entity had a procurement policy in line with the federal award’s specific procurement guidelines but not in line with standards of 2 CFR 200.318 through 200.327. In particular, the policy did not address methods of procurement based on micro-purchase, small purchase, and simplified acquisition purchase thresholds, circumstances in which noncompetitive procurement could be used, and procedures for verifying that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause: The auditee was not aware of the requirements outlined in 2 CFR 200.318 through 200.327, and believed the contracting guidelines outlined for their specific award were sufficient. Effect: The auditee was not in compliance with procurement policies outlined in of 2 CFR 200.318 through 200.327. There was a lack of full and open competition and auditee did not ensure the vendors with which it planned to enter into a covered transaction were not debarred, suspended, or otherwise excluded. Repeat Finding: This is a repeat finding. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the Organization adopt an updated procurement policy in line with 2 CFR 200 requirements and ensure all staff involved in the acquisition of property or services charged to federal grants are aware of relevant procurement requirements.