Program Information:
U.S. Department of the Interior
Single Agreement – Assistance Listing #15.036
Award Number: A18AV00341
Award Period: 10/01/2023 – 9/30/2024
Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200.
Non-federal 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 non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220.
Per 2 CFR § 200.303 Internal controls, the non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: 1 of 3 procurement samples selected for testing had no documentation of bidding, alternative price quotes, or sole source documentation. Additionally, for 1 of 1 Individually Important Items and 2 of 2 suspension and debarment samples selected for testing, NWIFC could not provide support showing a SAM.gov check was performed prior to conducting business with the vendors.
[ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness
Cause: It appears the policies and procedures for procurement and suspension and debarment were not followed.
Effect: Without solicitation from an adequate number of qualified sources, NWIFC is at risk of over-spending on projects and, thus, leaving fewer resources available to fulfill the mission of NWIFC. Additionally, NWIFC could be subject to other sanctions from funding agencies if they determine that programs did not assure vendors were properly checked for suspension and debarment.
Questioned Costs: $25,750 for procurement. This amount represents procurement transactions selected for testing that lacked required documentation of competitive bidding, price comparisons, or sole source justifications. As a result, these costs do not meet the allowability and procurement standards under 2 CFR 200.318–200.320 and are therefore questioned.
Not applicable for suspension and debarment. While internal controls were not followed, no specific transactions were identified that violated the cost allowability requirements.
Repeat Finding: Yes, finding #2023-003.
Recommendation: We recommend that the NWIFC adhere to program policies and procedures as documented and supporting documentation is kept available for review.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Commerce
NOAA Hatchery Genetic Mgmt – Assistance Listing #11.437
Award Number: NA18NMF4370324
Award Period: 7/01/2018 – 6/30/2024
Criteria: Reporting requirements are contained in the following:
Monitoring and reporting program performance, 2 CFR Section 200.329.
• Per the award documents, the grantee shall prepare and provide progress reports to Pacific States Marine Fisheries Commission (PSMFC). These run January to June and July to December and are due 15 days after each period.
Per 2 CFR § 200.303 Internal controls, the non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: NWIFC could not provide support showing review and approval of the progress reports prior to submitting them to PSMFC.
[ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness
Cause: It appears the policies and procedures for reporting were not followed.
Effect: Failing to comply with the grant award requirements, the program may be subject to higher risk status and a decreased amount of funding.
Questioned Costs: Not applicable – The condition relates to the lack of review and approval of the required reports before submitting to the funding agency, which does not directly impact the allowability or support for costs charged to the program. No costs are being questioned as a result.
Repeat Finding: No.
Recommendation: We recommend that the NWIFC adhere to program policies and procedures as documented and supporting documentation is kept available for review.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
Single Agreement – Assistance Listing #15.036
Award Number: A18AV00341
Award Period: 10/01/2023 – 9/30/2024
Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200.
Non-federal 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 non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220.
Per 2 CFR § 200.303 Internal controls, the non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: 1 of 3 procurement samples selected for testing had no documentation of bidding, alternative price quotes, or sole source documentation. Additionally, for 1 of 1 Individually Important Items and 2 of 2 suspension and debarment samples selected for testing, NWIFC could not provide support showing a SAM.gov check was performed prior to conducting business with the vendors.
[ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness
Cause: It appears the policies and procedures for procurement and suspension and debarment were not followed.
Effect: Without solicitation from an adequate number of qualified sources, NWIFC is at risk of over-spending on projects and, thus, leaving fewer resources available to fulfill the mission of NWIFC. Additionally, NWIFC could be subject to other sanctions from funding agencies if they determine that programs did not assure vendors were properly checked for suspension and debarment.
Questioned Costs: $25,750 for procurement. This amount represents procurement transactions selected for testing that lacked required documentation of competitive bidding, price comparisons, or sole source justifications. As a result, these costs do not meet the allowability and procurement standards under 2 CFR 200.318–200.320 and are therefore questioned.
Not applicable for suspension and debarment. While internal controls were not followed, no specific transactions were identified that violated the cost allowability requirements.
Repeat Finding: Yes, finding #2023-003.
Recommendation: We recommend that the NWIFC adhere to program policies and procedures as documented and supporting documentation is kept available for review.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Commerce
NOAA Hatchery Genetic Mgmt – Assistance Listing #11.437
Award Number: NA18NMF4370324
Award Period: 7/01/2018 – 6/30/2024
Criteria: Reporting requirements are contained in the following:
Monitoring and reporting program performance, 2 CFR Section 200.329.
• Per the award documents, the grantee shall prepare and provide progress reports to Pacific States Marine Fisheries Commission (PSMFC). These run January to June and July to December and are due 15 days after each period.
Per 2 CFR § 200.303 Internal controls, the non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: NWIFC could not provide support showing review and approval of the progress reports prior to submitting them to PSMFC.
[ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness
Cause: It appears the policies and procedures for reporting were not followed.
Effect: Failing to comply with the grant award requirements, the program may be subject to higher risk status and a decreased amount of funding.
Questioned Costs: Not applicable – The condition relates to the lack of review and approval of the required reports before submitting to the funding agency, which does not directly impact the allowability or support for costs charged to the program. No costs are being questioned as a result.
Repeat Finding: No.
Recommendation: We recommend that the NWIFC adhere to program policies and procedures as documented and supporting documentation is kept available for review.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.