Federal Agency: U.S. Department of Energy
Federal Program: EERE Information Dissemination, Outreach, Training and Technical Analysis/ Assistance
Assistance Listing Numbers: 81.117
Federal Award Identification Number and Year: DE-EE0010933 – 2023
Award Period: January 1, 2024 – December 31, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Compliance - Other Matter
Criteria or specific requirement: As required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA), this award is subject to the subaward reporting requirements of 2 CFR Part 170. This reporting requirement is applicable and must be reported for each action that obligates $25,000 or more in Federal funds. Reporting must be completed after each obligating action no later than the end of the month following the month in which the obligation was made.
Condition: During our testing, the Organization reported that this reporting had not been completed as required when subawards were obligated to subrecipients in 2024.
Questioned Costs: None
Context: During our testing, it was noted the Organization did not submit required FFATA reports required in the federal notice of awards for these funds.
Cause: The Organization was not aware of the requirement of the FFATA reporting requirements and did not have a process in place to ensure that required reporting had been completed within the time allowed.
Effect: Required reporting of subawardees' information was not completed as required.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Organization puts a process in place to ensure the required reporting is completed in the timeline allowed by the granting agency and to complete any missed or late reporting requirements.
Views of responsible officials and planned corrective actions: Management is in agreement with the finding.
Federal Agency: U.S. Department of Energy
Federal Program: EERE Information Dissemination, Outreach, Training and Technical Analysis/ Assistance
Assistance Listing Numbers: 81.117
Federal Award Identification Number and Year: DE-EE0010933 – 2023
Award Period: January 1, 2024 – December 31, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Compliance - Other Matter
Criteria or specific requirement: Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215.
Condition: SAM.gov verification was performed several months after contract was executed instead of prior to contract execution, or inclusion of contract clause.
Questioned Costs: None
Context: We tested five subrecipients and noted the SAM.gov verification was done after executing the contract, noting the subrecipients were neither suspended nor debarred.
Cause: Management was not aware of the requirement to perform the SAM.gov verification or include a clause in the contract to validate the subrecipient is neither suspended nor debarred.
Effect: In cases where this verification is not completed there is a risk of payment to a vendor who is suspended or debarred by the federal government.
Repeat Finding: This was not a repeat finding.
Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment, along with a documented review of this documentation prior to executing the agreement. These procedures should be included in a written policy that complies with the federal regulations around contracting or making subawards under covered transactions. Alternatively, in lieu of the SAM.gov verification, the Organization could include appropriate language in the contract that provides representations the subrecipient is neither suspended nor debarred.
Views of responsible officials and planned corrective actions: Management is in agreement with the finding.
Federal Agency: U.S. Department of Energy
Federal Program: EERE Information Dissemination, Outreach, Training and Technical Analysis/ Assistance
Assistance Listing Numbers: 81.117
Federal Award Identification Number and Year: DE-EE0010933 – 2023
Award Period: January 1, 2024 – December 31, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
• Compliance - Other Matter
Criteria or specific requirement: As required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA), this award is subject to the subaward reporting requirements of 2 CFR Part 170. This reporting requirement is applicable and must be reported for each action that obligates $25,000 or more in Federal funds. Reporting must be completed after each obligating action no later than the end of the month following the month in which the obligation was made.
Condition: During our testing, the Organization reported that this reporting had not been completed as required when subawards were obligated to subrecipients in 2024.
Questioned Costs: None
Context: During our testing, it was noted the Organization did not submit required FFATA reports required in the federal notice of awards for these funds.
Cause: The Organization was not aware of the requirement of the FFATA reporting requirements and did not have a process in place to ensure that required reporting had been completed within the time allowed.
Effect: Required reporting of subawardees' information was not completed as required.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Organization puts a process in place to ensure the required reporting is completed in the timeline allowed by the granting agency and to complete any missed or late reporting requirements.
Views of responsible officials and planned corrective actions: Management is in agreement with the finding.
Federal Agency: U.S. Department of Energy
Federal Program: EERE Information Dissemination, Outreach, Training and Technical Analysis/ Assistance
Assistance Listing Numbers: 81.117
Federal Award Identification Number and Year: DE-EE0010933 – 2023
Award Period: January 1, 2024 – December 31, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Compliance - Other Matter
Criteria or specific requirement: Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215.
Condition: SAM.gov verification was performed several months after contract was executed instead of prior to contract execution, or inclusion of contract clause.
Questioned Costs: None
Context: We tested five subrecipients and noted the SAM.gov verification was done after executing the contract, noting the subrecipients were neither suspended nor debarred.
Cause: Management was not aware of the requirement to perform the SAM.gov verification or include a clause in the contract to validate the subrecipient is neither suspended nor debarred.
Effect: In cases where this verification is not completed there is a risk of payment to a vendor who is suspended or debarred by the federal government.
Repeat Finding: This was not a repeat finding.
Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment, along with a documented review of this documentation prior to executing the agreement. These procedures should be included in a written policy that complies with the federal regulations around contracting or making subawards under covered transactions. Alternatively, in lieu of the SAM.gov verification, the Organization could include appropriate language in the contract that provides representations the subrecipient is neither suspended nor debarred.
Views of responsible officials and planned corrective actions: Management is in agreement with the finding.