Finding 2025-001: Federal Funding Accountability and Transparency Act Reporting Federal Agency: U.S. Agency for International Development (USAID) Federal Program: Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Pass-through Entity (if applicable): Not applicable Award Identification Number and Year: All Criteria or Specific Requirement: 2 CFR part 170, Appendix A; 2 CFR 200.303 For Federal awards containing the applicable Transparency Act award term, a recipient generally must report each first-tier subaward that equals or exceeds $30,000 in Federal funds, including a modification that increases Federal funding to that level. The report is made through the Federal Funding Accountability and Transparency Act Subaward Reporting System and is due no later than the end of the month following the month in which the subaward was issued. Recipients are also required to establish and maintain effective internal control over Federal awards and comply with the terms and conditions of those awards. Condition: Internews Network was unable to provide documentation supporting its identification and reporting of first-tier subawards subject to FFATA during the year ended December 31, 2025. As a result, we were unable to determine whether all reportable subawards and modifications were identified, submitted completely and accurately, and reported within the required timeframe. Cause: Management indicated that significant reductions in grants and compliance personnel occurred after the termination of Federal awards and funding. Responsibilities for FFATA reporting and custody of related records were not formally reassigned, and management did not maintain a centralized, durable repository or documented closeout process sufficient to preserve evidence of compliance after staff departures. Effect or Potential Effect: The absence of supporting records prevented verification of compliance with the applicable FFATA award term. Untimely, incomplete, or omitted reporting, if it occurred, could result in inaccurate information in Federal spending transparency systems, noncompliance with award terms, and increased risk of Federal or pass-through entity follow-up. Because sufficient documentation was not available, the extent of any unreported or late subawards and any related monetary effect could not be determined. Questioned Costs: Undetermined Context: The Organization received Federal funding and issued or modified first-tier subawards during the audit period. The applicable Federal award terms required Internews Network to evaluate whether those subawards met FFATA reporting requirements and, when applicable, submit the required information through the designated Federal reporting system within the prescribed timeframe. Identification as a Repeat Finding, if Applicable: Not a repeat finding Recommendation: We recommend that Internews Network designate an accountable FFATA process owner and backup, establish a complete inventory of Federal awards and first-tier subawards, and implement a documented monthly review for new subawards and modifications. For each potentially reportable item, management should retain the threshold analysis, required data elements, FSRS submission confirmation, submission date, and evidence of review in a centralized repository with access that is not dependent on a single employee. When a Federal program is terminated or staffing is reduced, management should perform a formal records-transfer and awardcloseout checklist, including reassignment of outstanding reporting responsibilities and validation that compliance records remain accessible for the required retention period.
Finding 2025-002: Procurement, Suspension and Debarment Federal Agency: U.S. Agency for International Development (USAID) Federal Program: Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Pass-through Entity (if applicable): Not applicable Award Identification Number and Year: All Criteria or Specific Requirement: 2 CFR 200.318 through 200.327; 2 CFR 200.303 Recipients and subrecipients must maintain and use documented procurement procedures consistent with applicable laws and the Federal procurement standards. Procurement transactions must be conducted using an appropriate method, with records sufficient to support the procurement history and required determinations. The standards also address competition, conflicts of interest, contractor oversight, cost or price analysis when applicable, required contract provisions, and suspension and debarment requirements. Condition: For several procurement transactions sampled, Internews Network was unable to provide some or all documentation necessary to support compliance. Missing items included procurement method determination, solicitation or quotations, bid/proposal evaluation, sole-source justification, price reasonableness or cost/price analysis. Accordingly, we were unable to determine whether the transactions were procured in accordance with Internews Network’s policies, 2 CFR 200.318 through 200.327, and applicable award terms. Cause: Management indicated that significant staffing reductions followed the termination of Federal awards and funding. Procurement and grants administration duties were dispersed or discontinued without a complete transition of electronic and paper records. Management did not have an enforced, centralized procurement file standard or a closeout control designed to confirm that each procurement file was complete before responsible staff separated. Effect or Potential Effect: The missing documentation prevented verification that procurement transactions were conducted with the required competition, approvals, price considerations, exclusion checks, and contract terms. This increases the risk of unsupported vendor selection, unreasonable costs, transactions with excluded parties, omitted Federal clauses, and costs that may be challenged by a Federal agency or pass-through entity. Questioned Costs: Undetermined Context: Internews Network used Federal award funds to acquire goods and services under during the audit period. Compliance with Federal procurement requirements is ordinarily demonstrated through a contemporaneous procurement file documenting the applicable method, competition or authorized noncompetitive justification, vendor selection, price or cost considerations, approvals, exclusion checks, contract terms, and oversight. Identification as a Repeat Finding, if Applicable: Not a repeat finding Recommendation: Implement a standardized procurement checklist scaled to method and threshold. Retain the funding source, threshold and method determination, competition or approved noncompetitive justification, vendor responses, evaluation, price support, conflicts documentation, exclusion verification, approvals, contract provisions, invoices, and oversight evidence. Require independent completeness reviews before award and final payment, centralize records, and use a staffing-reduction or award-termination protocol to transfer ownership, preserve access, and certify file completeness.
Finding 2025-003: Subrecipient Monitoring and Management Federal Agency: U.S. Agency for International Development (USAID) Federal Program: Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Pass-through Entity (if applicable): Not applicable Award Identification Number and Year: All Criteria or Specific Requirement: 2 CFR 200.331 through 200.333; 2 CFR 200.329; 2 CFR 200.303 A pass-through entity must document subrecipient-versus-contractor determinations, verify that potential subrecipients are not excluded or disqualified, include required Federal information and conditions in subawards, evaluate risk of noncompliance, and monitor activities as necessary. Monitoring includes reviewing financial and performance reports, following up on deficiencies, and issuing management decisions for applicable audit findings. Procedures and specific conditions should respond to assessed risk. Condition: Internews Network could not provide complete documentation for several subrecipients tested. Missing items included classification, risk assessment, exclusion verification, complete agreement and award data, financial and programmatic reports and review evidence. We therefore could not determine whether risk was assessed, requirements communicated, performance and compliance monitored and issues resolved. Cause: Significant reductions in program, grants, and finance personnel followed termination of Federal awards and funding. Files and responsibilities were not fully transitioned; evidence was maintained across individual mailboxes, local drives, and other locations; and no staff-exit procedure required transfer and validation of subrecipient records. Effect or Potential Effect: The absence of monitoring documentation prevented verification that subrecipients used funds for authorized purposes, achieved required performance, complied with award terms, and corrected deficiencies. Noncompliance, unsupported costs, performance issues, or audit findings may not be detected and resolved timely. Questioned Costs: Undetermined Context: Internews Network served as a pass-through entity and provided Federal funds to subrecipients responsible for carrying out portions of the Federal program. It was therefore responsible for documenting pre-award determinations, communicating Federal requirements, assessing subrecipient risk, performing responsive monitoring, following up on deficiencies, and completing closeout. Identification as a Repeat Finding, if Applicable: Not a repeat finding Recommendation: Establish a risk-based lifecycle process with primary and backup owners. Central files should include classification, exclusion verification, risk assessment, required terms and identifiers, monitoring plan, reports, review evidence, invoice testing, audit determinations, finding follow-up, management decisions, corrective actions, and closeout. Use a register to track deadlines, risks, procedures, findings, and open items. Award termination or staffing reduction should trigger formal portfolio transfer, reconciliation of open matters, preservation of records, and certification that duties and system access were reassigned.