Audit 350382

2022-002 Document Policies and Procedures Over Federal Awards Federal Program Information Federal Agency: U.S. Department of the Interior Award Name: Natural Resource Stewardship; Cooperative Research and Training Programs – Resources of the National Park System Assistance Listing Number(s): 15.944, 15.945 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Procurement, Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: • Determination of allowable costs • Employee travel • Cash management • Procurement • Conflicts of interest Condition and Context The Organization does not have written policies and procedures in place related to federal awards, as required under the Uniform Guidance. Cause The Organization has not developed written formal documentation of internal controls to encompass all applicable areas per the Uniform Guidance. Effect or Potential Effect Due to the weaknesses in internal controls noted above, the Organization did not comply with the requirements of the Uniform Guidance over documented policies and procedures. No questioned costs are reported as this requirement is procedural in nature. Recommendation The Organization should address the weakness noted above and create policies and procedures related to federal awards in order to comply with the Uniform Guidance. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2022-002 Document Policies and Procedures Over Federal Awards Federal Program Information Federal Agency: U.S. Department of the Interior Award Name: Natural Resource Stewardship; Cooperative Research and Training Programs – Resources of the National Park System Assistance Listing Number(s): 15.944, 15.945 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Procurement, Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: • Determination of allowable costs • Employee travel • Cash management • Procurement • Conflicts of interest Condition and Context The Organization does not have written policies and procedures in place related to federal awards, as required under the Uniform Guidance. Cause The Organization has not developed written formal documentation of internal controls to encompass all applicable areas per the Uniform Guidance. Effect or Potential Effect Due to the weaknesses in internal controls noted above, the Organization did not comply with the requirements of the Uniform Guidance over documented policies and procedures. No questioned costs are reported as this requirement is procedural in nature. Recommendation The Organization should address the weakness noted above and create policies and procedures related to federal awards in order to comply with the Uniform Guidance. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2022-003 Implement Controls and Documentation Over Procurement Federal Program Information Federal Agency: U.S. Department of the Interior Award Name: Natural Resource Stewardship Assistance Listing Number(s): 15.944 Award Year: 2022 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that grant recipients follow procurement procedures for the acquisition of property or services under a federal award. Grantees are required to comply with certain procurement standards as defined in 2 CFR 200.318. These standards include the requirement that the grantee must use its own documented procurement procedures provided that they conform to applicable federal law. In addition, the grantee must maintain records sufficient to detail the history of procurement. Condition and Context During our audit, we tested a sample of one procurement transaction for a vendor with expenditures between $10,000 and $249,999 during 2022. Of the transaction tested, there was no supporting documentation to validate justification of why the vendor was selected, as approvals were not formally documented. In addition, no evidence was provided to prove a suspension and debarment check was performed. Cause The Organization did not have adequate policies or controls in place to maintain formal evidence of vendor approval. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, there is a risk that contracts may be awarded to vendors in a manner that is not consistent with Federal procurement requirements. Questioned Costs Due to the condition noted above, Federal procurement requirements were not followed and resulted in the following questioned costs. AL Number(s) Name of Federal Program Questioned Costs 15.944 Natural Resource Stewardship $50,672 Recommendation The Organization should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal requirements and supporting documentation is maintained to support such conclusion. The Organization should ensure that prior to entering into transactions, a review is performed over vendor selection and all required documentation is retained. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2022-004 Improve Controls Over Cash Management and Application of Indirect Cost Rate Federal Program Information Federal Agency: U.S Department of the Interior Award Name: Natural Resource Stewardship; Cooperative Research and Training Programs – Resources of the National Park System Assistance Listing Number(s): 15.944, 15.945 Award Year: 2022 Compliance Requirement: Cash Management, Allowable Costs/Cost Principles Type of Finding Internal Control Over Compliance – Significant Deficiency Criteria or Specific Requirement Management of the Organization is responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Management of the Organization is also responsible for applying the indirect cost rate appropriately. Condition and Context There is no documented review of requests for reimbursement by an individual that is not involved with preparing the requests. One individual is both preparing and reviewing requests for reimbursement with no additional documented oversight. As a result, there is also no review over the application of the indirect cost rate prior to requests for reimbursement. Cause The Organization did not have adequate controls in place to ensure approval over reimbursement requests prior to submission to the federal agency, including application of the indirect cost rate. Effect or Potential Effect Due to the weakness in internal controls noted above, there is a risk that amounts requested to be reimbursed under federal awards could not be allowable or in accordance with applicable cost principles, including application of the indirect cost rate. No questioned costs are reported as this is an internal control over compliance finding. Recommendation The Organization should address the weaknesses in internal controls noted above by requiring two individuals to be involved in requesting reimbursements, and that the review and oversight of reimbursement requests and application of the indirect cost rate be documented. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2022-004 Improve Controls Over Cash Management and Application of Indirect Cost Rate Federal Program Information Federal Agency: U.S Department of the Interior Award Name: Natural Resource Stewardship; Cooperative Research and Training Programs – Resources of the National Park System Assistance Listing Number(s): 15.944, 15.945 Award Year: 2022 Compliance Requirement: Cash Management, Allowable Costs/Cost Principles Type of Finding Internal Control Over Compliance – Significant Deficiency Criteria or Specific Requirement Management of the Organization is responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Management of the Organization is also responsible for applying the indirect cost rate appropriately. Condition and Context There is no documented review of requests for reimbursement by an individual that is not involved with preparing the requests. One individual is both preparing and reviewing requests for reimbursement with no additional documented oversight. As a result, there is also no review over the application of the indirect cost rate prior to requests for reimbursement. Cause The Organization did not have adequate controls in place to ensure approval over reimbursement requests prior to submission to the federal agency, including application of the indirect cost rate. Effect or Potential Effect Due to the weakness in internal controls noted above, there is a risk that amounts requested to be reimbursed under federal awards could not be allowable or in accordance with applicable cost principles, including application of the indirect cost rate. No questioned costs are reported as this is an internal control over compliance finding. Recommendation The Organization should address the weaknesses in internal controls noted above by requiring two individuals to be involved in requesting reimbursements, and that the review and oversight of reimbursement requests and application of the indirect cost rate be documented. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2022-002 Document Policies and Procedures Over Federal Awards Federal Program Information Federal Agency: U.S. Department of the Interior Award Name: Natural Resource Stewardship; Cooperative Research and Training Programs – Resources of the National Park System Assistance Listing Number(s): 15.944, 15.945 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Procurement, Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: • Determination of allowable costs • Employee travel • Cash management • Procurement • Conflicts of interest Condition and Context The Organization does not have written policies and procedures in place related to federal awards, as required under the Uniform Guidance. Cause The Organization has not developed written formal documentation of internal controls to encompass all applicable areas per the Uniform Guidance. Effect or Potential Effect Due to the weaknesses in internal controls noted above, the Organization did not comply with the requirements of the Uniform Guidance over documented policies and procedures. No questioned costs are reported as this requirement is procedural in nature. Recommendation The Organization should address the weakness noted above and create policies and procedures related to federal awards in order to comply with the Uniform Guidance. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2022-002 Document Policies and Procedures Over Federal Awards Federal Program Information Federal Agency: U.S. Department of the Interior Award Name: Natural Resource Stewardship; Cooperative Research and Training Programs – Resources of the National Park System Assistance Listing Number(s): 15.944, 15.945 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Procurement, Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: • Determination of allowable costs • Employee travel • Cash management • Procurement • Conflicts of interest Condition and Context The Organization does not have written policies and procedures in place related to federal awards, as required under the Uniform Guidance. Cause The Organization has not developed written formal documentation of internal controls to encompass all applicable areas per the Uniform Guidance. Effect or Potential Effect Due to the weaknesses in internal controls noted above, the Organization did not comply with the requirements of the Uniform Guidance over documented policies and procedures. No questioned costs are reported as this requirement is procedural in nature. Recommendation The Organization should address the weakness noted above and create policies and procedures related to federal awards in order to comply with the Uniform Guidance. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2022-003 Implement Controls and Documentation Over Procurement Federal Program Information Federal Agency: U.S. Department of the Interior Award Name: Natural Resource Stewardship Assistance Listing Number(s): 15.944 Award Year: 2022 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that grant recipients follow procurement procedures for the acquisition of property or services under a federal award. Grantees are required to comply with certain procurement standards as defined in 2 CFR 200.318. These standards include the requirement that the grantee must use its own documented procurement procedures provided that they conform to applicable federal law. In addition, the grantee must maintain records sufficient to detail the history of procurement. Condition and Context During our audit, we tested a sample of one procurement transaction for a vendor with expenditures between $10,000 and $249,999 during 2022. Of the transaction tested, there was no supporting documentation to validate justification of why the vendor was selected, as approvals were not formally documented. In addition, no evidence was provided to prove a suspension and debarment check was performed. Cause The Organization did not have adequate policies or controls in place to maintain formal evidence of vendor approval. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, there is a risk that contracts may be awarded to vendors in a manner that is not consistent with Federal procurement requirements. Questioned Costs Due to the condition noted above, Federal procurement requirements were not followed and resulted in the following questioned costs. AL Number(s) Name of Federal Program Questioned Costs 15.944 Natural Resource Stewardship $50,672 Recommendation The Organization should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal requirements and supporting documentation is maintained to support such conclusion. The Organization should ensure that prior to entering into transactions, a review is performed over vendor selection and all required documentation is retained. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2022-004 Improve Controls Over Cash Management and Application of Indirect Cost Rate Federal Program Information Federal Agency: U.S Department of the Interior Award Name: Natural Resource Stewardship; Cooperative Research and Training Programs – Resources of the National Park System Assistance Listing Number(s): 15.944, 15.945 Award Year: 2022 Compliance Requirement: Cash Management, Allowable Costs/Cost Principles Type of Finding Internal Control Over Compliance – Significant Deficiency Criteria or Specific Requirement Management of the Organization is responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Management of the Organization is also responsible for applying the indirect cost rate appropriately. Condition and Context There is no documented review of requests for reimbursement by an individual that is not involved with preparing the requests. One individual is both preparing and reviewing requests for reimbursement with no additional documented oversight. As a result, there is also no review over the application of the indirect cost rate prior to requests for reimbursement. Cause The Organization did not have adequate controls in place to ensure approval over reimbursement requests prior to submission to the federal agency, including application of the indirect cost rate. Effect or Potential Effect Due to the weakness in internal controls noted above, there is a risk that amounts requested to be reimbursed under federal awards could not be allowable or in accordance with applicable cost principles, including application of the indirect cost rate. No questioned costs are reported as this is an internal control over compliance finding. Recommendation The Organization should address the weaknesses in internal controls noted above by requiring two individuals to be involved in requesting reimbursements, and that the review and oversight of reimbursement requests and application of the indirect cost rate be documented. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2022-004 Improve Controls Over Cash Management and Application of Indirect Cost Rate Federal Program Information Federal Agency: U.S Department of the Interior Award Name: Natural Resource Stewardship; Cooperative Research and Training Programs – Resources of the National Park System Assistance Listing Number(s): 15.944, 15.945 Award Year: 2022 Compliance Requirement: Cash Management, Allowable Costs/Cost Principles Type of Finding Internal Control Over Compliance – Significant Deficiency Criteria or Specific Requirement Management of the Organization is responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Management of the Organization is also responsible for applying the indirect cost rate appropriately. Condition and Context There is no documented review of requests for reimbursement by an individual that is not involved with preparing the requests. One individual is both preparing and reviewing requests for reimbursement with no additional documented oversight. As a result, there is also no review over the application of the indirect cost rate prior to requests for reimbursement. Cause The Organization did not have adequate controls in place to ensure approval over reimbursement requests prior to submission to the federal agency, including application of the indirect cost rate. Effect or Potential Effect Due to the weakness in internal controls noted above, there is a risk that amounts requested to be reimbursed under federal awards could not be allowable or in accordance with applicable cost principles, including application of the indirect cost rate. No questioned costs are reported as this is an internal control over compliance finding. Recommendation The Organization should address the weaknesses in internal controls noted above by requiring two individuals to be involved in requesting reimbursements, and that the review and oversight of reimbursement requests and application of the indirect cost rate be documented. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.