Federal Agency: U.S. Department of Agriculture Forest Service
Federal Program Name: Cooperative Forestry Assistance - Pass-Through Agency: N/A
Assistance Listing Number: 10.664
Federal Award Identification Year: 2021
Award Period: 09/01/21-08/31/26
Type of Finding: Other Matters - Significant Deficiency in Internal Control
Criteria: 2 CFR 200.403(a) - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
Condition: For one payroll sample that was selected, the amount of time charged to the grant was greater than the
amount of time work was performed for the grant. As such, the program was overcharged.
Context: A nonstatistical sample of 25 out of > 250 payroll entries were selected for testing for the Cooperative Forestry Assistance program. The condition noted above was identified during our procedures over the CFSC’s allowable costs provisions.
Effect: CFSC did not identify the error to be able to make the appropriate corrections before receiving reimbursement for incorrect payroll related expenditures.
Cause: CFSC did not consistently ensure that the hours worked by each employee related to the federal program were accurate applying the cost to the grant.
Repeat Finding: The finding is a repeat finding.
Recommendation: We recommend that management strengthen its current policies and procedures to ensure that all payroll amounts applied to the grant were for actual hours worked based on employee timesheets.
Management’s Views: See separate corrective action plan.
Federal Agency: U.S. Department of Agriculture Forest Service
Federal Program Name: Cooperative Forestry Assistance - Pass-Through Agency: N/A
Assistance Listing Number: 10.664
Federal Award Identification Year: 2021
Award Period: 09/01/21-08/31/26
Type of Finding: Other Matters - Significant Deficiency in Internal Control
Criteria: 2 CFR 200.403(a) - When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in
the transaction.
Condition: For two subrecipient samples that were selected, verification of subrecipient's suspension or debarment
status was not verified until after the subaward agreement was effective.
Context: A nonstatistical sample of 6 out of 20 subrecipients were selected for testing for the Cooperative Forestry Assistance program. The condition noted above was identified during our procedures over CFSC’s subrecipients.
Effect: CFSC did not verify suspension or debarment status timely which could result in naming a subrecipient
as an award recipient who is potentially suspended or debarred.
Cause: CFSC did not consistently ensure that Suspension or Debarment status was verified timely before naming the subrecipients tested as award recipients.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend that management strengthen its current policies and procedures to ensure that
Suspension and Debarment Status is verified for each subrecipient applicant during its pre-award subrecipient screening process.
Management’s Views: See separate corrective action plan.
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Pass-Through Agency: National Fish and Wildlife Grant Agreement
Award Period: 9/1/20-08/31/23
Type of Finding: Other Matters - Significant Deficiency in Internal Control
Criteria: 2 CFR 200.403(a) - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
Condition: For two payroll samples that were selected, the amount of time charged to the grant was greater than the amount of time work was performed for the grant. As such, the program was overcharged.
Context: A nonstatistical sample of 8 out of 48 payroll entries were selected for testing for the Office for Coastal Management program. The condition noted above was identified during our procedures over the CFSC’s allowable costs provisions.
Effect: CFSC did not identify the error to be able to make the appropriate corrections before receiving reimbursement for incorrect payroll related expenditures.
Cause: CFSC did not consistently ensure that the hours worked by each employee related to the federal program were accurate applying the cost to the grant.
Repeat Finding: The finding is a repeat finding.
Recommendation: We recommend that management strengthen its current policies and procedures to ensure that all payroll amounts applied to the grant were for actual hours worked based on employee timesheets.
Management’s Views: See separate corrective action plan.
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Pass-Through Agency: National Fish and Wildlife Grant Agreement
Award Period: 9/1/20-08/31/23
Type of Finding: Other Matters - Significant Deficiency in Internal Control
Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB approved, governmentwide data elements available from the OMB designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or passthrough entity to best inform improvements in program outcomes and productivity.
Condition: For one of the two reports selected for testing, CFSC did not submit the reports to the National Fish and
Wildlife Foundation by the required date.
Context: A nonstatistical sample of 2 out of 4 required reports were selected for testing for the Office for Coastal
Management program. The condition noted above was identified during our procedures over the CFSC’s reporting requirements.
Effect: CFSC did not submit required reports in a timely manner, increasing the risk of noncompliance.
Cause: CFSC’s procedures did not consistently ensure that the required reports were submitted on a timely
basis.
Repeat Finding: The finding is a repeat finding.
Recommendation: We recommend that management modify and strengthen its current policies and procedures to ensure that all required reports are submitted on a timely basis to the appropriate Federal Agency or Pass-Through Entity.
Management’s Views: See separate corrective action plan.
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Award Period: 9/1/20-08/31/23
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified
Opinion)
Criteria: 2 CFR 200.403(a) - When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: For two subrecipient samples that were selected, verification of subrecipient's suspension or debarment
status was not verified.
Context: A nonstatistical sample of 2 of 4 subrecipients were selected for testing for the Office for Coastal Management program. Condition noted above was identified during our procedures over subrecipients.
Effect: CFSC did not verify suspension or debarment status, which could result in naming a subrecipient as an award recipient, which is potentially suspended or debarred.
Cause: CFSC did not consistently ensure that Suspension or Debarment status was verified before naming the
subrecipients tested as award recipients.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend that management strengthen its current policies and procedures to ensure that
Suspension and Debarment Status is verified for each subrecipient applicant during its pre-award subrecipient screening process.
Management’s Views: See separate corrective action plan.
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Pass-Through Agency: National Fish and Wildlife Grant Agreement
Award Period: 9/1/20-08/31/23
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified
Opinion)
Criteria: 2 CFR 200.332(d) - establishes that the auditee must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.
Condition: Management did not perform risk assessment for all subrecipients selected for testing. Management
was unable to provide supporting documentation to show that they inquired with the subrecipients about any audits they had undergone or evidence that management received and reviewed audit reports to ensure timely follow ups were made if any findings pertaining to the Federal Award was noted.
Context: A nonstatistical sample of 2 out of 4 subrecipients were selected for testing for the Office for Coastal
Management program. The condition noted above was identified during our procedures over CFSC’s subrecipients.
Effect: CFSC did not perform the following, which increases the risk of noncompliance:
Required risk assessments for the subrecipients,
Review subrecipient audit reports to ensure compliance with Federal Awards or make any necessary follow-ups pertaining to any findings noted, if any.
Cause: CFSC’s procedures did not consistently ensure that the required risk assessments were performed.
Repeat Finding: The finding is a repeat finding.
Recommendation: We recommend that management modifies and strengthens its current policies and procedures to ensure that all required risk assessments are performed in accordance with the criteria outlined above.
Management’s Views: See separate corrective action plan.
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Pass-Through Agency: National Fish and Wildlife Grant Agreement
Award Period: 9/1/20-08/31/23
Type of Finding: Other Matters – Material Weakness in Internal Control
Criteria: 2 CFR 200.414(c) - Federal award recipients must negotiate an indirect cost rate with the cognizant agency for indirect costs, which is typically the federal agency that provides the most funding to the recipient.2 CFR 200.403(d) - The negotiated rate must be applied consistently across all federal awards to ensure uniformity in cost allocation. 2 CFR 200.302(b)(3) - Recipients must maintain adequate documentation to support the indirect costs charged to federal awards, ensuring compliance with the cost principles outlined in the regulation.
Condition: For two reimbursement requests from the grantor, an indirect cost rate was used, for which CSFC did
not have a provisional or final rate agreement from the USDA.
Context: Of the 2 reimbursements invoiced, 2 were selected for testing for the Office for Coastal Management
program. The condition noted above was identified during our procedures over CFSC’s subrecipients.
Effect: CFSC did not identify the error to be able to make the appropriate corrections before receiving reimbursement for incorrect indirect cost rate invoiced.
Cause: CFSC’s procedures did not ensure that the negotiated provisional rate was invoiced properly.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to perform review over the indirect cost rate utilized when submitting invoices to the grantor.
Management’s Views: See separate corrective action plan.
Federal Agency: U.S. Department of Agriculture Forest Service
Federal Program Name: Cooperative Forestry Assistance - Pass-Through Agency: N/A
Assistance Listing Number: 10.664
Federal Award Identification Year: 2021
Award Period: 09/01/21-08/31/26
Type of Finding: Other Matters - Significant Deficiency in Internal Control
Criteria: 2 CFR 200.403(a) - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
Condition: For one payroll sample that was selected, the amount of time charged to the grant was greater than the
amount of time work was performed for the grant. As such, the program was overcharged.
Context: A nonstatistical sample of 25 out of > 250 payroll entries were selected for testing for the Cooperative Forestry Assistance program. The condition noted above was identified during our procedures over the CFSC’s allowable costs provisions.
Effect: CFSC did not identify the error to be able to make the appropriate corrections before receiving reimbursement for incorrect payroll related expenditures.
Cause: CFSC did not consistently ensure that the hours worked by each employee related to the federal program were accurate applying the cost to the grant.
Repeat Finding: The finding is a repeat finding.
Recommendation: We recommend that management strengthen its current policies and procedures to ensure that all payroll amounts applied to the grant were for actual hours worked based on employee timesheets.
Management’s Views: See separate corrective action plan.
Federal Agency: U.S. Department of Agriculture Forest Service
Federal Program Name: Cooperative Forestry Assistance - Pass-Through Agency: N/A
Assistance Listing Number: 10.664
Federal Award Identification Year: 2021
Award Period: 09/01/21-08/31/26
Type of Finding: Other Matters - Significant Deficiency in Internal Control
Criteria: 2 CFR 200.403(a) - When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in
the transaction.
Condition: For two subrecipient samples that were selected, verification of subrecipient's suspension or debarment
status was not verified until after the subaward agreement was effective.
Context: A nonstatistical sample of 6 out of 20 subrecipients were selected for testing for the Cooperative Forestry Assistance program. The condition noted above was identified during our procedures over CFSC’s subrecipients.
Effect: CFSC did not verify suspension or debarment status timely which could result in naming a subrecipient
as an award recipient who is potentially suspended or debarred.
Cause: CFSC did not consistently ensure that Suspension or Debarment status was verified timely before naming the subrecipients tested as award recipients.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend that management strengthen its current policies and procedures to ensure that
Suspension and Debarment Status is verified for each subrecipient applicant during its pre-award subrecipient screening process.
Management’s Views: See separate corrective action plan.
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Pass-Through Agency: National Fish and Wildlife Grant Agreement
Award Period: 9/1/20-08/31/23
Type of Finding: Other Matters - Significant Deficiency in Internal Control
Criteria: 2 CFR 200.403(a) - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
Condition: For two payroll samples that were selected, the amount of time charged to the grant was greater than the amount of time work was performed for the grant. As such, the program was overcharged.
Context: A nonstatistical sample of 8 out of 48 payroll entries were selected for testing for the Office for Coastal Management program. The condition noted above was identified during our procedures over the CFSC’s allowable costs provisions.
Effect: CFSC did not identify the error to be able to make the appropriate corrections before receiving reimbursement for incorrect payroll related expenditures.
Cause: CFSC did not consistently ensure that the hours worked by each employee related to the federal program were accurate applying the cost to the grant.
Repeat Finding: The finding is a repeat finding.
Recommendation: We recommend that management strengthen its current policies and procedures to ensure that all payroll amounts applied to the grant were for actual hours worked based on employee timesheets.
Management’s Views: See separate corrective action plan.
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Pass-Through Agency: National Fish and Wildlife Grant Agreement
Award Period: 9/1/20-08/31/23
Type of Finding: Other Matters - Significant Deficiency in Internal Control
Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB approved, governmentwide data elements available from the OMB designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or passthrough entity to best inform improvements in program outcomes and productivity.
Condition: For one of the two reports selected for testing, CFSC did not submit the reports to the National Fish and
Wildlife Foundation by the required date.
Context: A nonstatistical sample of 2 out of 4 required reports were selected for testing for the Office for Coastal
Management program. The condition noted above was identified during our procedures over the CFSC’s reporting requirements.
Effect: CFSC did not submit required reports in a timely manner, increasing the risk of noncompliance.
Cause: CFSC’s procedures did not consistently ensure that the required reports were submitted on a timely
basis.
Repeat Finding: The finding is a repeat finding.
Recommendation: We recommend that management modify and strengthen its current policies and procedures to ensure that all required reports are submitted on a timely basis to the appropriate Federal Agency or Pass-Through Entity.
Management’s Views: See separate corrective action plan.
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Award Period: 9/1/20-08/31/23
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified
Opinion)
Criteria: 2 CFR 200.403(a) - When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition: For two subrecipient samples that were selected, verification of subrecipient's suspension or debarment
status was not verified.
Context: A nonstatistical sample of 2 of 4 subrecipients were selected for testing for the Office for Coastal Management program. Condition noted above was identified during our procedures over subrecipients.
Effect: CFSC did not verify suspension or debarment status, which could result in naming a subrecipient as an award recipient, which is potentially suspended or debarred.
Cause: CFSC did not consistently ensure that Suspension or Debarment status was verified before naming the
subrecipients tested as award recipients.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend that management strengthen its current policies and procedures to ensure that
Suspension and Debarment Status is verified for each subrecipient applicant during its pre-award subrecipient screening process.
Management’s Views: See separate corrective action plan.
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Pass-Through Agency: National Fish and Wildlife Grant Agreement
Award Period: 9/1/20-08/31/23
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified
Opinion)
Criteria: 2 CFR 200.332(d) - establishes that the auditee must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.
Condition: Management did not perform risk assessment for all subrecipients selected for testing. Management
was unable to provide supporting documentation to show that they inquired with the subrecipients about any audits they had undergone or evidence that management received and reviewed audit reports to ensure timely follow ups were made if any findings pertaining to the Federal Award was noted.
Context: A nonstatistical sample of 2 out of 4 subrecipients were selected for testing for the Office for Coastal
Management program. The condition noted above was identified during our procedures over CFSC’s subrecipients.
Effect: CFSC did not perform the following, which increases the risk of noncompliance:
Required risk assessments for the subrecipients,
Review subrecipient audit reports to ensure compliance with Federal Awards or make any necessary follow-ups pertaining to any findings noted, if any.
Cause: CFSC’s procedures did not consistently ensure that the required risk assessments were performed.
Repeat Finding: The finding is a repeat finding.
Recommendation: We recommend that management modifies and strengthens its current policies and procedures to ensure that all required risk assessments are performed in accordance with the criteria outlined above.
Management’s Views: See separate corrective action plan.
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Pass-Through Agency: National Fish and Wildlife Grant Agreement
Award Period: 9/1/20-08/31/23
Type of Finding: Other Matters – Material Weakness in Internal Control
Criteria: 2 CFR 200.414(c) - Federal award recipients must negotiate an indirect cost rate with the cognizant agency for indirect costs, which is typically the federal agency that provides the most funding to the recipient.2 CFR 200.403(d) - The negotiated rate must be applied consistently across all federal awards to ensure uniformity in cost allocation. 2 CFR 200.302(b)(3) - Recipients must maintain adequate documentation to support the indirect costs charged to federal awards, ensuring compliance with the cost principles outlined in the regulation.
Condition: For two reimbursement requests from the grantor, an indirect cost rate was used, for which CSFC did
not have a provisional or final rate agreement from the USDA.
Context: Of the 2 reimbursements invoiced, 2 were selected for testing for the Office for Coastal Management
program. The condition noted above was identified during our procedures over CFSC’s subrecipients.
Effect: CFSC did not identify the error to be able to make the appropriate corrections before receiving reimbursement for incorrect indirect cost rate invoiced.
Cause: CFSC’s procedures did not ensure that the negotiated provisional rate was invoiced properly.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to perform review over the indirect cost rate utilized when submitting invoices to the grantor.
Management’s Views: See separate corrective action plan.