Audit 394315

Item 2025-002 – Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting Not Performed Type of Finding: Material weakness in Internal Control over Compliance; Other Matter Compliance Finding Federal Award Agency: Department of Commerce Pass-through Entity: N/A Federal Program: Habitat Conservation Assistance Listing Number: 11.463 Federal Award Identification Number: NA19NMF4630270; NA23NMF4630019; NA23NMF4630020; NA24NMFX463C0004-T1-01 Federal Award Year: Year ended June 30, 2025 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended, hereafter referred as the “Transparency Act” that are codified in 2 CFR Parts 25 and 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to System for Award Management (SAM.gov). Condition: American Rivers failed to submit report for the new subrecipient awards under the Federal Funding Accountability and Transparency Act. This failure is a result of improper implementation and understanding of new requirements to submit such reporting under a new platform. The reports have been subsequently prepared, reviewed and submitted after the deadline. Cause: American Rivers was not aware of the change in filing systems and thus determined that they were no longer required to file. Effect: Incomplete data was available to the public on USASpending.gov, reducing federal spending transparency as intended by the Transparency Act. This noncompliance could also lead to a loss of federal funds. Questioned costs: None Context: FFATA reporting was not completed for any subawards made during the year. Repeat finding: No Recommendation: Reporting should be completed as soon as possible. When there are changes in the future, management should verify the changes by contacting the grantor organization to ensure compliance. Views of responsible officials: American Rivers agrees with the finding.

Item 2025-003 – Untimely Submission of Federal Financial Report (SF-425) Type of Finding: Significant deficiency in Internal Control over Compliance; Other Matter Compliance Finding Federal Award Agency: Department of Commerce Pass-through Entity: N/A Federal Program: Habitat Conservation Assistance Listing Number: 11.463 Federal Award Identification Number: NA19NMF4630270; NA23NMF4630019; NA23NMF4630020; NA24NMFX463C0004-T1-01 Federal Award Year: Year ended June 30, 2025 Criteria: The award terms and conditions and Uniform Guidance require timely submission of financial reports. The SF 425 must be submitted per the reporting frequency and due dates specified in the Notice of Award or pass through subaward). Condition: During the year ended June 30, 2025, American Rivers submitted SF 425 reports after the required due dates: • Semi-annual SF 425 for award NA23NMF4630019 for period ended September 30, 2024, was submitted on June 2, 2025 (due October 31, 2024). • Semi-annual SF 425 for award NA24NMFX463C0004-T1-01 period ended March 31, 2025, was submitted on October 30, 2025(due April 30, 2025). Cause: Formalized procedures to track report due dates and ensure timely review and approval were not consistently followed. Effect: Untimely SF 425 filings constitute noncompliance with award reporting requirements and increase the risk of federal oversight concerns, potential payment delays or administrative actions by the agency/pass through, and misalignment in cash management (e.g., delayed draw reconciliations). Repeated late filings could adversely affect American Rivers’ risk profile with the awarding agency. Questioned Costs: None Context: We tested four SF 425 reports during the period from July 1, 2024–June 30, 2025. Two reports were filed late. Testing was performed as part of the Reporting compliance requirement for the Habitat Conservation major program. Repeat finding: No Recommendation: Reporting should be completed as soon as possible and the proper review and approval processes should be completed on a timely basis. Views of responsible officials: American Rivers agrees with the finding.