Audit 345168

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), 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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.

2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.