Audit 412567

Federal Agency: U.S. Department of the Interior - BOR Federal Program Name: Providing Water to At-Risk Natural Desert Terminal Lakes Assistance Listing Number: 15.508 Federal Award Identification Year: 2025 Pass-Through Agency: National Fish and Wildlife Foundation Award Period: 7/1/19-10/31/25 Compliance Requirement Affected: Suspension and Debarment Type of Finding and other matters: Significant Deficiency in Internal Control over Compliance and other matters Criteria: 2 CFR 200.403(a) - 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, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Of the six procured vendors that were selected, verification of subrecipient's suspension or debarment status was not performed for one vendor. Context: A nonstatistical sample of 6 out of 19 procured vendors were selected for testing for the above program. The condition noted above was identified during our procedures over WBC's procured vendors. Effect: WBC did not verify suspension or debarment status timely, which could result in procuring a vendor which is potentially suspended or debarred. Cause: WBC did not consistently ensure that Suspension or Debarment status was verified timely before naming procuring the vendor. Repeat Finding: The finding is a repeat finding. Recommendation: We recommend that WBC strengthen its current policies and procedures to ensure that Suspension and Debarment Status is verified for each vendor subject to verification of suspension and debarment verification according to WBC's Procurement policy. Management’s Views: See Separate Corrective Action Plan.

Federal Agency: U.S. Department of the Interior - BOR Federal Program Name: Providing Water to At-Risk Natural Desert Terminal Lakes Assistance Listing Number: 15.508 Federal Award Identification Year: 2025 Pass-Through Agency: National Fish and Wildlife Foundation Award Period: 7/1/19-10/31/25 Compliance Requirement Affected: Allowable Activities & Costs Type of Finding: Significant Deficiency in Internal Control over Compliance and other matters Criteria: The organization’s policies require board approval for disbursements exceeding $25,000 to ensure costs charged to the federal program are properly authorized and allowable in accordance with the award terms and conditions and 2 CFR 200.403. Condition: The auditor tested a sample of 40 disbursements and identified one disbursement of $30,000 that exceeded the approval threshold but did not have the required board approval. Questioned costs: Known- dollar amount determined: $30,000 Context: The population of disbursements subject to the board‑approval requirement consisted of 21 transactions totaling $822,697. Effect: The lack of required approval increases the risk that unallowable or unauthorized costs could be charged to the federal program without appropriate oversight. Cause: Management did not consistently ensure that disbursements exceeding the approval threshold were submitted for and received board approval prior to payment. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that management strengthen procedures to ensure that all disbursements exceeding the board‑approval threshold receive documented approval prior to payment, and that compliance with this requirement is monitored consistently. Management’s Views: See Separate Corrective Action Plan.