001 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Requirement
Identification of the Federal Program:
United States Agency for International Development (USAID)
Assistance Listing Number: 98.001
Assistance Listing Name: USAID Foreign Assistance for Programs Overseas
Pass-through Award Information:
Pass-through
Entity Pass-through Award Number
Award Period
IPE Global Limited IPE-DOM-2022 January 25, 2022 through August 31, 2023
Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135.
Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified one procurement sample out of a total of ten procurement samples tested wherein management was unable to provide evidence that the suspension and debarment check was performed prior to entering into contract with the vendor. Management had most recently performed a suspension and debarment check on this vendor in 2021 for a previously covered transaction. Management has also performed a new suspension and debarment check on this vendor when this condition was identified noting no suspension and debarment issues.
Cause: ChildFund policies and procedures did not require suspension and debarment checks be performed prior to entering a covered transaction if a check had been done within the previous three years.
Effect: Failure to timely verify that a vendor is not suspended or debarred prior to each covered transaction with that vendor could result in unintentionally entering into a contract with an vendor that is suspended or barred from performing work for the Federal government.
Questioned Costs: There are no known or likely questioned costs.
Context: This is a condition based on testing of ChildFund’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend that management perform the suspension and debarment checks before each covered transaction is executed.
Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.
Internal Control over Compliance and Compliance with the Reporting Compliance Requirement
Identification of the Federal Program:
United States Agency for International Development (USAID)
Assistance Listing Number: 98.001
Assistance Listing Name: USAID Foreign Assistance for Programs Overseas
Award Number: 720BHA24GR00016
Award Period: December 15, 2023 through December 31, 2026
Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The prime awardee is required to file a Transparency Act sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant granter than or equal to $30,000.
Condition: During BDO’s testing of the FFATA reporting, we tested the only subrecipient in the major program. ChildFund entered into the subaward agreement with the entity in January 2024, however ChildFund did not report activity in the FSRS system until October 2024.
Cause: There was turnover at ChildFund in the personnel who is responsible for the Transparency Act reports and it was not initially identified that someone had not assumed that responsibility until our audit procedures identified the missing report.
Effect: Failure to properly track all Transparency Act reporting requirements impacts the Federal agency from obtaining performance information required to assess award performance on a macro level.
Questioned Costs: There are no questioned costs as the items outlined above are all matters relate to late submission of required reports.
Context: This is a condition identified during BDO’s testing of Transparency Act reports. We tested the only required FFATA report submission for the year ended June 30, 2024.
Repeat Finding: This finding is not a repeat finding.
Recommendation: To facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, BDO recommends management implement a process by which approvals, submission considerations and supporting documentation for programmatic reports and Transparency Act reports is maintained in a centralized location.
Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.
Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles
Identification of the Federal Program:
United States Agency for International Development (USAID)
Assistance Listing Number: 98.001
Assistance Listing Name: USAID Foreign Assistance for Programs Overseas
Pass-through Award Information:
Pass-through
Entity Pass-through Award Number
Award Period
IPE Global Limited IPE-DOM-2022 January 25, 2022 through August 31, 2023
Criteria or Specific Requirement: In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions;
and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
(1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
(2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
(3) Records that identify adequately the source and application of funds for federally-funded activities.
(4) Effective control over, and accountability for, all funds, property, and other assets.
Additionally, §200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: ChildFund has documented expenditure policies and procedures. ChildFund’s policies are designed to ensure grant expenses are reviewed and approved timely to ensure proper accounting. However, as identified below, the review and approval process did not operate as designed. However, in seven out of our 40 samples tested, BDO identified instances in which the expenditures were reported within the incorrect financial reporting period. These errors all occurred at the same office location. These expenditures did occur in the award period.
Cause: ChildFund has documented expenditure policies and procedures. However, as identified above, the review and approval process for the samples identified above did not operate as designed.
Effect: The lack of adherence to established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of award agreements which could ultimately lead to disallowed costs for the major program.
Questioned Costs: As all of the costs noted were within the award period of performance, there are no questioned costs to report.
Context: This is a condition identified per review of ChildFund’s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of this finding is detailed in the condition section above. Samples were selected using a non-statistical method.
Repeat Finding: This is not a repeat finding from the previous year.
Recommendation: BDO recommends ChildFund adhere to its documented policies and procedures regarding approval and recording of expenditures.
Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.
001 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Requirement
Identification of the Federal Program:
United States Agency for International Development (USAID)
Assistance Listing Number: 98.001
Assistance Listing Name: USAID Foreign Assistance for Programs Overseas
Pass-through Award Information:
Pass-through
Entity Pass-through Award Number
Award Period
IPE Global Limited IPE-DOM-2022 January 25, 2022 through August 31, 2023
Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135.
Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified one procurement sample out of a total of ten procurement samples tested wherein management was unable to provide evidence that the suspension and debarment check was performed prior to entering into contract with the vendor. Management had most recently performed a suspension and debarment check on this vendor in 2021 for a previously covered transaction. Management has also performed a new suspension and debarment check on this vendor when this condition was identified noting no suspension and debarment issues.
Cause: ChildFund policies and procedures did not require suspension and debarment checks be performed prior to entering a covered transaction if a check had been done within the previous three years.
Effect: Failure to timely verify that a vendor is not suspended or debarred prior to each covered transaction with that vendor could result in unintentionally entering into a contract with an vendor that is suspended or barred from performing work for the Federal government.
Questioned Costs: There are no known or likely questioned costs.
Context: This is a condition based on testing of ChildFund’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend that management perform the suspension and debarment checks before each covered transaction is executed.
Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.
Internal Control over Compliance and Compliance with the Reporting Compliance Requirement
Identification of the Federal Program:
United States Agency for International Development (USAID)
Assistance Listing Number: 98.001
Assistance Listing Name: USAID Foreign Assistance for Programs Overseas
Award Number: 720BHA24GR00016
Award Period: December 15, 2023 through December 31, 2026
Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The prime awardee is required to file a Transparency Act sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant granter than or equal to $30,000.
Condition: During BDO’s testing of the FFATA reporting, we tested the only subrecipient in the major program. ChildFund entered into the subaward agreement with the entity in January 2024, however ChildFund did not report activity in the FSRS system until October 2024.
Cause: There was turnover at ChildFund in the personnel who is responsible for the Transparency Act reports and it was not initially identified that someone had not assumed that responsibility until our audit procedures identified the missing report.
Effect: Failure to properly track all Transparency Act reporting requirements impacts the Federal agency from obtaining performance information required to assess award performance on a macro level.
Questioned Costs: There are no questioned costs as the items outlined above are all matters relate to late submission of required reports.
Context: This is a condition identified during BDO’s testing of Transparency Act reports. We tested the only required FFATA report submission for the year ended June 30, 2024.
Repeat Finding: This finding is not a repeat finding.
Recommendation: To facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, BDO recommends management implement a process by which approvals, submission considerations and supporting documentation for programmatic reports and Transparency Act reports is maintained in a centralized location.
Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.
Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles
Identification of the Federal Program:
United States Agency for International Development (USAID)
Assistance Listing Number: 98.001
Assistance Listing Name: USAID Foreign Assistance for Programs Overseas
Pass-through Award Information:
Pass-through
Entity Pass-through Award Number
Award Period
IPE Global Limited IPE-DOM-2022 January 25, 2022 through August 31, 2023
Criteria or Specific Requirement: In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions;
and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
(1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
(2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
(3) Records that identify adequately the source and application of funds for federally-funded activities.
(4) Effective control over, and accountability for, all funds, property, and other assets.
Additionally, §200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: ChildFund has documented expenditure policies and procedures. ChildFund’s policies are designed to ensure grant expenses are reviewed and approved timely to ensure proper accounting. However, as identified below, the review and approval process did not operate as designed. However, in seven out of our 40 samples tested, BDO identified instances in which the expenditures were reported within the incorrect financial reporting period. These errors all occurred at the same office location. These expenditures did occur in the award period.
Cause: ChildFund has documented expenditure policies and procedures. However, as identified above, the review and approval process for the samples identified above did not operate as designed.
Effect: The lack of adherence to established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of award agreements which could ultimately lead to disallowed costs for the major program.
Questioned Costs: As all of the costs noted were within the award period of performance, there are no questioned costs to report.
Context: This is a condition identified per review of ChildFund’s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of this finding is detailed in the condition section above. Samples were selected using a non-statistical method.
Repeat Finding: This is not a repeat finding from the previous year.
Recommendation: BDO recommends ChildFund adhere to its documented policies and procedures regarding approval and recording of expenditures.
Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.