Audit 414328

Finding 2025-001 – Timeliness of Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting Award information Cluster: N/A Grantor: U.S. Department of Energy Award name: Preventing Outages and Enhancing the Resilience of the Electric Grid Formula Grants to States and Indian Tribes Award number: DE-GD0000041 Award year: 2025 Assistance listing number: 81.254 Assistance listing title: Grid Resilience Grant Program 40101 (d) Pass-through entity: N/A Criteria The Federal Funding Accountability and Transparency Act (FFATA), as implemented through 2 CFR Part 170 and Appendix A to Part 170, requires recipients of Federal awards to report applicable first-tier subawards. Unless an exemption applies, recipients must report each first-tier subaward that equals or exceeds $30,000 in Federal funds, including subsequent modifications that cause a subaward to meet or exceed the reporting threshold. Subaward information is required to be reported no later than the end of the month following the month in which the subaward was issued. Effective March 8, 2025, FFATA subaward reporting functionality transitioned from FSRS.gov to SAM.gov. Condition Through our testing of the Federal Funding Accountability and Transparency Act (FFATA) reporting compliance requirement, we selected 5 first-tier subawards for testing. We noted that the required subaward information for all selections had not been submitted by Sante Cooper for these selections along with other applicable subawards.. Following identification of the exception through our audit procedures, Santee Cooper submitted the required subaward information through the applicable Federal reporting system in Q3 2026. As such, the required reporting was completed subsequent to the applicable reporting deadlines and after the exceptions were identified during the audit. Cause Santee Cooper did not have an established process in place to identify and report applicable first-tier subawards under FFATA within the required reporting timeframe. As a result, the required subaward information was not timely reported through SAM.gov, and the subawards selected for testing were reported after the applicable reporting deadlines. Effect The lack of reporting of applicable first-tier subawards results in noncompliance with FFATA reporting requirements and delays the completeness and transparency of Federal spending information available to the public through USASpending.gov. Questioned costs None noted. Recommendation We recommend Santee Cooper establish and implement a formal FFATA reporting process to ensure applicable first-tier subawards are reported through SAM.gov within the required timeframe, including monitoring applicable reporting due dates and retaining documentation evidencing the completion and timeliness of the reporting. Repeat Finding from the Prior Year No Management’s views and corrective action plan Management’s view and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.

Finding 2025-002 – Suspension and Debarment Award information Cluster: N/A Grantor: U.S. Department of Energy Award name: Grid Infrastructure Deployment and Resilience Award number: DE-GD0000041 Award year: 2025 Assistance listing number: 81.254 Assistance listing title: Grid Resilience Grant Program 40101 (d) Pass-through entity: N/A Criteria Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. This verification may be accomplished by (1) checking the System for Award Management (SAM.gov) for exclusions, (2) collecting a certification from that person, or (3) adding a clause or condition to the covered transaction with that person (2 CFR section 180.300). Santee Cooper has established a Supplier Performance Policy that provides procedures for evaluating supplier performance and placing suppliers in Inactive, Non-Responsive, or Debarred status. The policy provides that suppliers may be debarred for certain convictions, failure to correct violations of contract provisions, or failure to perform as required under a contract. Condition In testing compliance with suspension and debarment requirements, we selected 2 transactions greater than $25,000 and noted that, for both transactions, Santee Cooper was unable to provide evidence that the vendors’ suspension and debarment status had been verified against the SAM.gov exclusions database or provide evidence of another permissible method of verifying that the vendors were not suspended, debarred, or otherwise excluded from participation in federal programs prior to entering into the covered transactions. Cause Santee Cooper’s policy establishes procedures for evaluating supplier performance and internally placing suppliers in Inactive, Non-Responsive, or Debarred status. However, the policy did not establish procedures requiring verification that suppliers are not suspended, debarred, or otherwise excluded from participation in federal programs through SAM.gov or another permissible verification method prior to entering into applicable covered transactions, as this requirement was not understood by management. Effect The lack of validation of the vendors against the required SAM.gov database (or allowed alternative) increases the risk that procurements could be made with suspended or debarred vendors. Questioned costs None noted. Recommendation We recommend Santee Cooper enhance its procedures to ensure suspension and debarment status is verified for applicable covered transactions prior to entering into the transaction and, as appropriate, periodically thereafter. Santee should also maintain sufficient documentation to demonstrate that an allowable verification method was performed, including evidence of the results of such verification. Repeat Finding from the Prior Year No Management’s views and corrective action plan Management’s view and corrective action plan are included at the end of this report after the summary schedule of prior audit findings and status.