Audit 369350

Program Affected 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2023 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria 2 CFR §180.300 mandates that 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 is not suspended or debarred or otherwise excluded from participating in the transaction. Condition and Context The Organization did not perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 6 of 6 vendors tested were not verified against the Excluded Parties List System. Cause and Effect The Organization does not have internal processes to properly identify excluded parties ineligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties. Questioned Costs N/A Identification of Repeat Findings 2023-009 Recommendation We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.

Program Affected 11.307 Economic Adjustment Assistance U.S. Department of Commerce Contract year: 2024 FAIN: 01-79-14834; URI112335 Criteria 2 CFR §200 defines the period of performance as the time interval between the start and end date of a federal award. The Organization is only allowed to bill costs from within the period of performance to the federal award. Condition and Context The Organization reports applied for and received reimbursement for costs incurred from outside the period of performance as defined by the federal award. The Organization believes that it obtained authorization from the awarding agency to incur such costs, but written documentation of the relevant extensions or waivers was not provided. Cause and Effect The Organization reports they obtained verbal confirmation from the awarding agency that certain costs from both prior to and subsequent to the period of performance would be allowable costs under the agreement. However, the Organization did retain written confirmation of these extensions to the period of performance. As a result, the Organization charged funds to the federal award from periods not within the period of performance as defined by the contract and subsequent written amendments provided by the awarding agency. The Organization requested further documentation of the extensions from the awarding agency, but the awarding agency was unable to provide timely response due to staffing shortages and turnover. Questioned Costs $311,702 Identification of Repeat Findings N/A Recommendation We recommend the Organization update its policies and procedures to require obtaining documentation of extensions to the period of performance from the awarding agency before expending funds. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.