FAC Explorer

Audit 334317

FY End
2024-06-30
Total Expended
$6.10M
Findings
2
Programs
16
Organization: National Trust for Historic Preservation in the United States (DC)
Year: 2024 Accepted: 2024-12-20
Auditor: Bdo USA PC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
516370 2024-002 Significant Deficiency - AB
1092812 2024-002 Significant Deficiency - AB

Programs

ALN Program Spent Major Findings
99.U99 Congressional Cemetery Endowment $2.44M Yes 0
45.164 Promotion of the Humanities Public Programs $1.20M - 0
20.942 Thriving Communities Program Capacity Builders Cooperative Agreements $927,467 Yes 0
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $365,522 Yes 1
45.130 Promotion of the Humanities Challenge Grants $298,338 - 0
15.957 Emergency Supplemental Historic Preservation Fund $168,350 - 0
15.904 Historic Preservation Fund Grants-in-Aid $154,333 - 0
15.946 Cultural Resources Management $56,467 - 0
45.301 Museums for America $38,902 - 0
15.929 Save America's Treasures $37,508 - 0
10.351 Rural Business Development Grant $20,347 - 0
15.930 Chesapeake Bay Gateways Network $20,032 - 0
45.312 National Leadership Grants $16,000 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $15,000 - 0
45.025 Promotion of the Arts Partnership Agreements $12,752 - 0
15.939 Heritage Partnership $4,775 - 0

Contacts

Name Title Type
D8XXKDNVK9Q5 Denise M. Wise Auditee
2025886192 Jason A. Aldridge Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget (OMB) Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Both Rate Explanation: The National Trust has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. One of the Trust’s subsidiaries, National Main Street Center, Inc., has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of the National Trust for Historic Preservation in the United States (the National Trust) and its Subsidiaries and Affiliates (collectively, the Trust) under programs of the federal government for the year ended June 30, 2024. 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 the Trust, it is not intended to and does not present the financial position, changes in net assets or cash flows of the Trust.
Title: Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget (OMB) Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Both Rate Explanation: The National Trust has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. One of the Trust’s subsidiaries, National Main Street Center, Inc., has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget (OMB) Circular A-122, Cost Principles for Non-Profit Organizations, or 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: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget (OMB) Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Both Rate Explanation: The National Trust has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. One of the Trust’s subsidiaries, National Main Street Center, Inc., has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The National Trust has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. One of the Trust’s subsidiaries, National Main Street Center, Inc., has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: Federally Sponsored Endowment Funds Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, either the cost principles in Office of Management and Budget (OMB) Circular A-122, Cost Principles for Non-Profit Organizations, or the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Both Rate Explanation: The National Trust has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. One of the Trust’s subsidiaries, National Main Street Center, Inc., has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The Trust has one federally sponsored endowment fund, the Congressional Cemetery Endowment, funded by the Architect of the Capitol, which is included in the Schedule. The balance of this endowment fund is summarized below: "See the Notes to the SEFA for chart/table."

Finding Details

Finding 2024-002
2024-002 Internal Control over Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Payroll Activities Identification of the Federal Program: Federal Agency: United States Housing & Urban Development Program Name: Community Development Block Grant - Disaster Recovery Whole Community Resilience Planning Program Assistance Listing Number: 14.228 Award Number: B-17-DM-72-0001 Passthrough Entity: Government of Puerto Rico Department of Housing Pass-Through Entity Identifying Number: FFNMUBT6WCM1 Sub-award Period: 1/30/2023-9/30/2024 Criteria - The Code of Federal Regulations 2 CFR 200.303, Internal Control, requires the non-federal entity to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing Federal awards in compliance with Federal statutes, regulations, and other terms and conditions. Per 2 CFR Section 200.430 Compensation – Personal Services: “Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.” 2 CFR Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition – During the audit, we noted that the Trust has a system of internal control in whichemployees who charge time to the Federal programs, are required to complete a timeslip and have their Timeslips reports reviewed and approved by the employees’ supervisors on a monthly basis. During our testing, we noted that five out of seven employees selected for testing charged time to the Federal program between July 1, 2023 and April 30, 2024, but the timeslips reports were not reviewed and approved by their supervisors until June 2024. There was a lack of timely approval of hours charged to the federal program by the supervisors. However, we validated that the employees who charged time to the federal awards as part of our sample selection were included in the budgets for the federal programs. Cause – The Trust did not follow its documented policies and procedures in place to ensure compliance with the requirements regarding activities allowed or unallowed and allowable costs/cost principles – payroll activities. Effect or Potential Effect - Without timely approvals that the personnel costs charged are accurate, the Trust is not able to demonstrate that key elements in a system of internal control over the recording of time exists. Questioned Costs - None. Context - This is a condition identified based upon our review of the Trust’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these findings is detailed in the condition section above. Repeat finding - This is not a repeat finding. Recommendation - We recommend that the Trust strengthen its current policies and procedures to ensure that payroll costs charged to federal awards are supported by a system of internal controls that allows for timely employee preparation, certification, and supervisory approval of time charged to the federal awards. Views of Responsible Officials – Time charged to this program had to be captured both as part of the billing process to the Federal funder, United States Housing and Urban Development (HUD) and through Timeslips system as required by internal policy. Time entries were downloaded from the Timeslips system and formatted for approvals using a time certification form template as required and approved by HUD. Billing to HUD occurs monthly. However, there were significant delays by HUD in reviewing and approving monthly invoices along with frequent changes to the requested documentation needed to substantiate costs. Although internal Timeslips reports were available for review and approval on a monthly basis, the program manager’s approvals were only documented on the time certification form as required by HUD. As a result, evidence of timely approvals on a monthly basis were not available as internal policy states. Procedures will be enforced to ensure that program managers are documenting approvals for hours charged to all federal awards according to both federal and internal policies as required on a monthly basis.
Finding 2024-002
2024-002 Internal Control over Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Payroll Activities Identification of the Federal Program: Federal Agency: United States Housing & Urban Development Program Name: Community Development Block Grant - Disaster Recovery Whole Community Resilience Planning Program Assistance Listing Number: 14.228 Award Number: B-17-DM-72-0001 Passthrough Entity: Government of Puerto Rico Department of Housing Pass-Through Entity Identifying Number: FFNMUBT6WCM1 Sub-award Period: 1/30/2023-9/30/2024 Criteria - The Code of Federal Regulations 2 CFR 200.303, Internal Control, requires the non-federal entity to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing Federal awards in compliance with Federal statutes, regulations, and other terms and conditions. Per 2 CFR Section 200.430 Compensation – Personal Services: “Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.” 2 CFR Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition – During the audit, we noted that the Trust has a system of internal control in whichemployees who charge time to the Federal programs, are required to complete a timeslip and have their Timeslips reports reviewed and approved by the employees’ supervisors on a monthly basis. During our testing, we noted that five out of seven employees selected for testing charged time to the Federal program between July 1, 2023 and April 30, 2024, but the timeslips reports were not reviewed and approved by their supervisors until June 2024. There was a lack of timely approval of hours charged to the federal program by the supervisors. However, we validated that the employees who charged time to the federal awards as part of our sample selection were included in the budgets for the federal programs. Cause – The Trust did not follow its documented policies and procedures in place to ensure compliance with the requirements regarding activities allowed or unallowed and allowable costs/cost principles – payroll activities. Effect or Potential Effect - Without timely approvals that the personnel costs charged are accurate, the Trust is not able to demonstrate that key elements in a system of internal control over the recording of time exists. Questioned Costs - None. Context - This is a condition identified based upon our review of the Trust’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these findings is detailed in the condition section above. Repeat finding - This is not a repeat finding. Recommendation - We recommend that the Trust strengthen its current policies and procedures to ensure that payroll costs charged to federal awards are supported by a system of internal controls that allows for timely employee preparation, certification, and supervisory approval of time charged to the federal awards. Views of Responsible Officials – Time charged to this program had to be captured both as part of the billing process to the Federal funder, United States Housing and Urban Development (HUD) and through Timeslips system as required by internal policy. Time entries were downloaded from the Timeslips system and formatted for approvals using a time certification form template as required and approved by HUD. Billing to HUD occurs monthly. However, there were significant delays by HUD in reviewing and approving monthly invoices along with frequent changes to the requested documentation needed to substantiate costs. Although internal Timeslips reports were available for review and approval on a monthly basis, the program manager’s approvals were only documented on the time certification form as required by HUD. As a result, evidence of timely approvals on a monthly basis were not available as internal policy states. Procedures will be enforced to ensure that program managers are documenting approvals for hours charged to all federal awards according to both federal and internal policies as required on a monthly basis.