Audit 414322

Corporation for National and Community Service Federal Financial Assistance Listing #94.012, 22BIICA001 10/1/2022 – 9/30/2025, 23BIACA001 10/1/2023 – 9/30/2026, 23BIFNY001 10/1/2023 – 9/30/2026 Americorps September 11th National Day of Service and Remembrance Grants Procurement, Suspension and Debarment Material Weakness in Internal Controls over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.327 which also requires documentation to be retained to detail the history of procurements. Condition: The Organization’s procurement policy is missing required provisions in accordance with 2 CFR 200.318. For each of the 3 vendors selected for testing there was no documentation retained to support the rationale for the method of procurement. Additionally, the Organization did not retain supporting documentation to substantiate whether consideration was taken whether the vendor was suspended or debarred from doing business with the federal government prior to entering the covered transaction for each of the 3 vendors selected for testing. Cause: There was a lapse in oversight of the internal control process ensuring documentation was retained supporting the Organization’s procurement, suspension and debarment process. Additionally, the Organization did not cross reference procurement policy with 2 CFR 200.318 through 200.327 ensuring minimum required provisions were included within. Effect: Without retaining documentation to support procurement, suspension and debarment rationale, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported based on assessment of comparative pricing readily available. Context/Sampling: A nonstatistical sample of 3 vendors out of 9 vendors were selected for testing. Repeat Finding from Prior Year: Yes, prior year finding 2024-003 Recommendation: We recommend management to review internal control procedures ensuring support is retained to substantiate procurement, suspension and debarment was considered prior to entering the transaction. We recommend management review 2 CFR 200.318 through 200.327 and revise the Organization’s procurement policy to include all minimum required provisions. Views of Responsible Officials: Management is in agreement.

Corporation for National and Community Service Federal Financial Assistance Listing #94.012, 22BIICA001 10/1/2022 – 9/30/2025, 23BIACA001 10/1/2023 – 9/30/2026, 23BIFNY001 10/1/2023 – 9/30/2026 Americorps September 11th National Day of Service and Remembrance Grants Reporting Material Weakness in Internal Controls over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: Reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA) was not completed for 3 of the subrecipients in which pass through funds exceeded $30,000 and 1 of the subrecipients in which pass through funds exceeded $30,000 was not filed timely. Cause: There was a misunderstanding with management over reporting requirements surrounding amounts passed through to subrecipients. Effect: Not having a clear understanding of FFATA reporting requirements lead to required information not being reported. Questioned Costs: None reported. Context/Sampling: There was a total of 9 federal financial reports, of which 3 were selected for testing. There were a total of 10 FFATA reports, of which 4 were selected for testing. Repeat Finding from Prior Year: Yes, prior year finding 2024-004. Recommendation: We recommend that management review procedures and control processes to ensure they comply with the federal requirements noted above. Views of Responsible Officials: Management is in agreement.

Corporation for National and Community Service Federal Financial Assistance Listing #94.012, 22BIICA001 10/1/2022 – 9/30/2025, 23BIACA001 10/1/2023 – 9/30/2026, 23BIFNY001 10/1/2023 – 9/30/2026 Americorps September 11th National Day of Service and Remembrance Grants Subrecipient Monitoring Material Weakness in Internal Controls over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.332 identifies the requirements for all pass-through entities surrounding subrecipient monitoring and management. Condition: We noted the following during testing; a) Subawards did not contain minimum required elements in accordance with 2 CFR 200.332(b) b) The Organization did not consider all suggested elements when evaluating subgrantee’s fraud risk and risk of noncompliance with subaward in accordance with 2 CFR 200.332(c) c) Documentation could not be provided to substantiate whether suspension and debarment was considered prior to awarding the subgrant d) The Organization required the subgrantee to complete performance reports, however, did not require completion of a financial report in accordance with 2 CFR 200.332(e)(1) e) The Organization did not consider whether subgrantee was required to be audited and therefore did not review whether subgrantee had deficiencies reported over the federal program in accordance with 2 CFR 200.332(e)(2) through 2 CFR 200.332(e)(4) Cause: Management was not familiar with all subrecipient monitoring requirements as published under 2 CFR 200.332. The Organization adopted a subrecipient monitoring policy during quarter 4 of 2025. Effect: Without full understanding of subrecipient monitoring requirements under 2 CFR 200.332, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported. Context/Sampling: Seven out of thirty six subrecipients were reviewed for testing. Repeat Finding from Prior Year: Yes, prior year finding 2024-005. Recommendation: We recommend management to review subrecipient monitoring requirements as published under 2 CFR 200.332 and adopt a subrecipient monitoring policy. Views of Responsible Officials: Management is in agreement.