FAC Explorer

Audit 343141

FY End
2022-12-31
Total Expended
$763,284
Findings
12
Programs
4
Organization: Micronesia Conservation Trust (FM)
Year: 2022 Accepted: 2025-02-19
Auditor: Ernst & Young LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
523960 2022-001 Significant Deficiency - I
523961 2022-001 Significant Deficiency - I
523962 2022-001 Significant Deficiency - I
523963 2022-002 Material Weakness - L
523964 2022-002 Material Weakness - L
523965 2022-002 Material Weakness - L
1100402 2022-001 Significant Deficiency - I
1100403 2022-001 Significant Deficiency - I
1100404 2022-001 Significant Deficiency - I
1100405 2022-002 Material Weakness - L
1100406 2022-002 Material Weakness - L
1100407 2022-002 Material Weakness - L

Programs

ALN Program Spent Major Findings
11.482 Coral Reef Conservation Program $304,668 Yes 2
98.001 Usaid Foreign Assistance for Programs Overseas $26,882 - 0
15.875 Economic, Social, and Political Development of the Territories $5,563 - 0
10.664 Cooperative Forestry Assistance $3,505 - 0

Contacts

Name Title Type
EPGHDY3KFMK5 Lisa Andon Auditee
6913205670 James Whitt Auditor
No contacts on file

Notes to SEFA

Title: 1. Scope of Audit Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting, consistent with the manner in which the MCT maintains its accounting records. All expenses and capital outlays are reported as expenditures. 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. MCT recognizes contributions from the federal government when qualifying expenditures are incurred. MCT does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: MCT does not elect to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The Micronesia Conservation Trust (the Trust) is a nonprofit organization incorporated under the laws of the Federated States of Micronesia (FSM) on November 7, 2002. The Trust is operated under a Board of Trustees, which must be composed of nine members. Only the transactions of the Trust are included within the scope of the Single Audit.
Title: 2. Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting, consistent with the manner in which the MCT maintains its accounting records. All expenses and capital outlays are reported as expenditures. 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. MCT recognizes contributions from the federal government when qualifying expenditures are incurred. MCT does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: MCT does not elect to use the 10% 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 Trust under programs of the U.S. federal government for the year ended December 31, 2022. 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: 3. Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting, consistent with the manner in which the MCT maintains its accounting records. All expenses and capital outlays are reported as expenditures. 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. MCT recognizes contributions from the federal government when qualifying expenditures are incurred. MCT does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: MCT does not elect to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting, consistent with the manner in which the Trust maintains its accounting records. All expenses and capital outlays are reported as expenditures. 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. The Trust recognizes contributions from the U.S. federal government when qualifying expenditures are incurred.
Title: 4. Indirect Cost Rate Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting, consistent with the manner in which the MCT maintains its accounting records. All expenses and capital outlays are reported as expenditures. 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. MCT recognizes contributions from the federal government when qualifying expenditures are incurred. MCT does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: MCT does not elect to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The Trust does not elect to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance.

Finding Details

Finding 2022-001
Finding No. 2022-001 Federal Agency: U.S. Department of Commerce ALN and Title: 11.482 Coral Reef Conservation Program Compliance Requirement: Suspension and Debarment Questioned Cost: $0 Criteria In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition The Trust could not provide written evidence showing that, prior to entering into a contract with a vendor, that the Trust concluded the vendor has not been debarred, suspended, or otherwise excluded from participating in the contract. Cause: The Trust does not have a written document proving prior to entering into a contract, that the vendor was deemed not to be debarred or suspended. Effect or potential effect: The Trust is in noncompliance with the applicable requirement. Recommendation: The Trust should revisit and implement procedures to ensure that vendors that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2022-001
Finding No. 2022-001 Federal Agency: U.S. Department of Commerce ALN and Title: 11.482 Coral Reef Conservation Program Compliance Requirement: Suspension and Debarment Questioned Cost: $0 Criteria In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition The Trust could not provide written evidence showing that, prior to entering into a contract with a vendor, that the Trust concluded the vendor has not been debarred, suspended, or otherwise excluded from participating in the contract. Cause: The Trust does not have a written document proving prior to entering into a contract, that the vendor was deemed not to be debarred or suspended. Effect or potential effect: The Trust is in noncompliance with the applicable requirement. Recommendation: The Trust should revisit and implement procedures to ensure that vendors that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2022-001
Finding No. 2022-001 Federal Agency: U.S. Department of Commerce ALN and Title: 11.482 Coral Reef Conservation Program Compliance Requirement: Suspension and Debarment Questioned Cost: $0 Criteria In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition The Trust could not provide written evidence showing that, prior to entering into a contract with a vendor, that the Trust concluded the vendor has not been debarred, suspended, or otherwise excluded from participating in the contract. Cause: The Trust does not have a written document proving prior to entering into a contract, that the vendor was deemed not to be debarred or suspended. Effect or potential effect: The Trust is in noncompliance with the applicable requirement. Recommendation: The Trust should revisit and implement procedures to ensure that vendors that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2022-002
Finding No.: 2022-002 Federal Agency: U.S. Department of Commerce AL Program: 11.482 Federal Award Nos.: NA22NOS4820155, NA20NOS4820198, NA20NOS4820046 Area: Reporting Questioned Costs: $0 Criteria In accordance with 2 CFR 170.000, recipients of a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) subaward report if the recipient grants any subaward equal to or greater than $30,000 in federal funds. Under reporting requirements, the recipient must report each subaward of this award term to the FFATA Subaward Reporting System (FSRS) at http://www.fsrs.gov. The key data elements to be reported include subawardee name, subawardee Data Universal Numbering System (DUNS) number, amount of subaward, subaward obligation/action date, date of report submission, subaward number, subaward project description, subawardee names and compensation of highly compensated officers. The subaward report should be submitted no later than the end of the month following the month in which the subaward was issued. Condition The Trust is required to file ten (10) reports to the federal grantor for fiscal year 2022. These comprise of four (4) financial reports, four (4) progress narrative reports, and two (2) special reports related to FFATA Subaward Reporting System (FSRS). However, the Trust did not file two (2) of these reports. The Trust has two (2) subaward agreements that exceed the $30,000 federal funds criteria set by FFATA. Cause: The Trust does not have procedures and internal controls in place to determine the special reporting requirements under the FFATA. Recommendation: The Trust should establish internal controls requiring periodic review of the applicable reporting requirements involving subawards. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding 2022-002
Finding No.: 2022-002 Federal Agency: U.S. Department of Commerce AL Program: 11.482 Federal Award Nos.: NA22NOS4820155, NA20NOS4820198, NA20NOS4820046 Area: Reporting Questioned Costs: $0 Criteria In accordance with 2 CFR 170.000, recipients of a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) subaward report if the recipient grants any subaward equal to or greater than $30,000 in federal funds. Under reporting requirements, the recipient must report each subaward of this award term to the FFATA Subaward Reporting System (FSRS) at http://www.fsrs.gov. The key data elements to be reported include subawardee name, subawardee Data Universal Numbering System (DUNS) number, amount of subaward, subaward obligation/action date, date of report submission, subaward number, subaward project description, subawardee names and compensation of highly compensated officers. The subaward report should be submitted no later than the end of the month following the month in which the subaward was issued. Condition The Trust is required to file ten (10) reports to the federal grantor for fiscal year 2022. These comprise of four (4) financial reports, four (4) progress narrative reports, and two (2) special reports related to FFATA Subaward Reporting System (FSRS). However, the Trust did not file two (2) of these reports. The Trust has two (2) subaward agreements that exceed the $30,000 federal funds criteria set by FFATA. Cause: The Trust does not have procedures and internal controls in place to determine the special reporting requirements under the FFATA. Recommendation: The Trust should establish internal controls requiring periodic review of the applicable reporting requirements involving subawards. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding 2022-002
Finding No.: 2022-002 Federal Agency: U.S. Department of Commerce AL Program: 11.482 Federal Award Nos.: NA22NOS4820155, NA20NOS4820198, NA20NOS4820046 Area: Reporting Questioned Costs: $0 Criteria In accordance with 2 CFR 170.000, recipients of a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) subaward report if the recipient grants any subaward equal to or greater than $30,000 in federal funds. Under reporting requirements, the recipient must report each subaward of this award term to the FFATA Subaward Reporting System (FSRS) at http://www.fsrs.gov. The key data elements to be reported include subawardee name, subawardee Data Universal Numbering System (DUNS) number, amount of subaward, subaward obligation/action date, date of report submission, subaward number, subaward project description, subawardee names and compensation of highly compensated officers. The subaward report should be submitted no later than the end of the month following the month in which the subaward was issued. Condition The Trust is required to file ten (10) reports to the federal grantor for fiscal year 2022. These comprise of four (4) financial reports, four (4) progress narrative reports, and two (2) special reports related to FFATA Subaward Reporting System (FSRS). However, the Trust did not file two (2) of these reports. The Trust has two (2) subaward agreements that exceed the $30,000 federal funds criteria set by FFATA. Cause: The Trust does not have procedures and internal controls in place to determine the special reporting requirements under the FFATA. Recommendation: The Trust should establish internal controls requiring periodic review of the applicable reporting requirements involving subawards. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding 2022-001
Finding No. 2022-001 Federal Agency: U.S. Department of Commerce ALN and Title: 11.482 Coral Reef Conservation Program Compliance Requirement: Suspension and Debarment Questioned Cost: $0 Criteria In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition The Trust could not provide written evidence showing that, prior to entering into a contract with a vendor, that the Trust concluded the vendor has not been debarred, suspended, or otherwise excluded from participating in the contract. Cause: The Trust does not have a written document proving prior to entering into a contract, that the vendor was deemed not to be debarred or suspended. Effect or potential effect: The Trust is in noncompliance with the applicable requirement. Recommendation: The Trust should revisit and implement procedures to ensure that vendors that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2022-001
Finding No. 2022-001 Federal Agency: U.S. Department of Commerce ALN and Title: 11.482 Coral Reef Conservation Program Compliance Requirement: Suspension and Debarment Questioned Cost: $0 Criteria In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition The Trust could not provide written evidence showing that, prior to entering into a contract with a vendor, that the Trust concluded the vendor has not been debarred, suspended, or otherwise excluded from participating in the contract. Cause: The Trust does not have a written document proving prior to entering into a contract, that the vendor was deemed not to be debarred or suspended. Effect or potential effect: The Trust is in noncompliance with the applicable requirement. Recommendation: The Trust should revisit and implement procedures to ensure that vendors that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2022-001
Finding No. 2022-001 Federal Agency: U.S. Department of Commerce ALN and Title: 11.482 Coral Reef Conservation Program Compliance Requirement: Suspension and Debarment Questioned Cost: $0 Criteria In accordance with 2 CFR 200.214, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing 2 CFR 180. Such regulation restricts 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. Under 2 CFR 180.300, when entering into a covered transaction with another person at the next lower tier, verification must be made that the person with whom an intent to do business with is not excluded or disqualified. Such verification can be made by (a) checking SAM Exclusions, (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition The Trust could not provide written evidence showing that, prior to entering into a contract with a vendor, that the Trust concluded the vendor has not been debarred, suspended, or otherwise excluded from participating in the contract. Cause: The Trust does not have a written document proving prior to entering into a contract, that the vendor was deemed not to be debarred or suspended. Effect or potential effect: The Trust is in noncompliance with the applicable requirement. Recommendation: The Trust should revisit and implement procedures to ensure that vendors that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities are restricted from Federal awards, subawards and contracts. Procedures performed should be adequately maintained in the procurement files. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2022-002
Finding No.: 2022-002 Federal Agency: U.S. Department of Commerce AL Program: 11.482 Federal Award Nos.: NA22NOS4820155, NA20NOS4820198, NA20NOS4820046 Area: Reporting Questioned Costs: $0 Criteria In accordance with 2 CFR 170.000, recipients of a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) subaward report if the recipient grants any subaward equal to or greater than $30,000 in federal funds. Under reporting requirements, the recipient must report each subaward of this award term to the FFATA Subaward Reporting System (FSRS) at http://www.fsrs.gov. The key data elements to be reported include subawardee name, subawardee Data Universal Numbering System (DUNS) number, amount of subaward, subaward obligation/action date, date of report submission, subaward number, subaward project description, subawardee names and compensation of highly compensated officers. The subaward report should be submitted no later than the end of the month following the month in which the subaward was issued. Condition The Trust is required to file ten (10) reports to the federal grantor for fiscal year 2022. These comprise of four (4) financial reports, four (4) progress narrative reports, and two (2) special reports related to FFATA Subaward Reporting System (FSRS). However, the Trust did not file two (2) of these reports. The Trust has two (2) subaward agreements that exceed the $30,000 federal funds criteria set by FFATA. Cause: The Trust does not have procedures and internal controls in place to determine the special reporting requirements under the FFATA. Recommendation: The Trust should establish internal controls requiring periodic review of the applicable reporting requirements involving subawards. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding 2022-002
Finding No.: 2022-002 Federal Agency: U.S. Department of Commerce AL Program: 11.482 Federal Award Nos.: NA22NOS4820155, NA20NOS4820198, NA20NOS4820046 Area: Reporting Questioned Costs: $0 Criteria In accordance with 2 CFR 170.000, recipients of a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) subaward report if the recipient grants any subaward equal to or greater than $30,000 in federal funds. Under reporting requirements, the recipient must report each subaward of this award term to the FFATA Subaward Reporting System (FSRS) at http://www.fsrs.gov. The key data elements to be reported include subawardee name, subawardee Data Universal Numbering System (DUNS) number, amount of subaward, subaward obligation/action date, date of report submission, subaward number, subaward project description, subawardee names and compensation of highly compensated officers. The subaward report should be submitted no later than the end of the month following the month in which the subaward was issued. Condition The Trust is required to file ten (10) reports to the federal grantor for fiscal year 2022. These comprise of four (4) financial reports, four (4) progress narrative reports, and two (2) special reports related to FFATA Subaward Reporting System (FSRS). However, the Trust did not file two (2) of these reports. The Trust has two (2) subaward agreements that exceed the $30,000 federal funds criteria set by FFATA. Cause: The Trust does not have procedures and internal controls in place to determine the special reporting requirements under the FFATA. Recommendation: The Trust should establish internal controls requiring periodic review of the applicable reporting requirements involving subawards. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding 2022-002
Finding No.: 2022-002 Federal Agency: U.S. Department of Commerce AL Program: 11.482 Federal Award Nos.: NA22NOS4820155, NA20NOS4820198, NA20NOS4820046 Area: Reporting Questioned Costs: $0 Criteria In accordance with 2 CFR 170.000, recipients of a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) subaward report if the recipient grants any subaward equal to or greater than $30,000 in federal funds. Under reporting requirements, the recipient must report each subaward of this award term to the FFATA Subaward Reporting System (FSRS) at http://www.fsrs.gov. The key data elements to be reported include subawardee name, subawardee Data Universal Numbering System (DUNS) number, amount of subaward, subaward obligation/action date, date of report submission, subaward number, subaward project description, subawardee names and compensation of highly compensated officers. The subaward report should be submitted no later than the end of the month following the month in which the subaward was issued. Condition The Trust is required to file ten (10) reports to the federal grantor for fiscal year 2022. These comprise of four (4) financial reports, four (4) progress narrative reports, and two (2) special reports related to FFATA Subaward Reporting System (FSRS). However, the Trust did not file two (2) of these reports. The Trust has two (2) subaward agreements that exceed the $30,000 federal funds criteria set by FFATA. Cause: The Trust does not have procedures and internal controls in place to determine the special reporting requirements under the FFATA. Recommendation: The Trust should establish internal controls requiring periodic review of the applicable reporting requirements involving subawards. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.