Grant Reporting (SF-425 Submissions) Federal Agency Name: Department of Agriculture / Forest Service Assistance Listing Number: 10.720 (Infrastructure Investment and Jobs Act Community Wildfire Defense Grant) Finding Summary: Federal expenditures reported on Line 10e of the quarterly Federal Financi...
Grant Reporting (SF-425 Submissions) Federal Agency Name: Department of Agriculture / Forest Service Assistance Listing Number: 10.720 (Infrastructure Investment and Jobs Act Community Wildfire Defense Grant) Finding Summary: Federal expenditures reported on Line 10e of the quarterly Federal Financial Reports (SF-425) did not reconcile directly to the Cooperative’s general ledger records for the applicable reporting period, resulting in an understatement of reportable expenditures for that period. Views of Responsible Officials & Management Response: Management disagrees with the finding as a Material Noncompliance and Material Weakness. Management acknowledges a timing discrepancy existed between quarterly filings and standard accrual rules, but maintains this matter does not constitute material noncompliance or a material weakness for the following reasons: 1. Reliance on Explicit Federal Directives: While management acknowledges Uniform Guidance under 2 CFR 200 requires financial reporting to align directly with accounting records, the Cooperative prepared and submitted the SF-425 reports in strict good-faith compliance with explicit, written instructions provided by the Forest Service’s Grant Department. See Exhibit B. Seeking out, receiving, and adhering to written directives from the federal oversight agency demonstrates a strong culture of compliance and an active effort to align with funder expectations, rather than a disregard for federal reporting statutes. 2. No Financial Risk or Loss of Funds: All underlying grant expenditures were valid, allowable, and verified. No questioned costs were identified. Because the reporting timing discrepancy was a direct result of following the awarding agency’s specific written guidance, management maintains this does not constitute a systemic control failure. The understatement in expenditures is directly related to a timing issue, resulting in zero financial risk to the federal government. Corrective Action Planned: Management has implemented formal control enhancements covering both grant reporting schedules and contract administration: o Revised Report Timing & Reconciliation Controls: To resolve the conflict between agency-specific guidance and independent audit standards, management has updated the operational timing and preparation method for Form SF-425. All future quarterly reports will be generated directly from general ledger accrual records strictly as of the quarter-end date. The SF425 and SF270 forms will be submitted separately in an effort to mitigate the timing issue. This updated timeline satisfies requirements for accrual reporting while providing an auditable submission trail for the granting agency. Responsible Person(s): Stacie Dellamano, Chief Financial Officer Anticipated Completion Date: December 31, 2026 Exhibit B From: Fusselman, Sarah - FS, ID Sarah.Fusselman@usda.gov Sent: Friday, July 17, 2026 10:09 AM To: Katie Dalton Subject: Re: [External Email]SF 425 Question for Grant 24-DG-11010013-052 Attachments: Grant Reminders for State, Private & Tribal Forestry R1 R4.pdf; POST AWARD Training2025.pptx Hi Katie, Please review the attached documents that outline how to properly complete the SF-425. I’m also including a helpful training video provided by the U.S. Fish and Wildlife Service: Please keep in mind that in the past, as the GMS for this award, I was able to piece together Flathead Electric’s reporting approach and document why certain entries were allowable on earlier SF-425 submissions. Going forward, because some quarters are busier than others, additional Forest Service administrative staff help manage the reporting inbox. They review SF-425s closely, and since fewer than three cooperators out of more than 500 awards submit the SF-425 and SF-270 simultaneously, these submissions will continue to be questioned. When the SF-425 shows an expenditure as “received” during the same period in which the SF-270 was just submitted, FS staff will request corrections from Flathead Electric each time. Additionally, with the upcoming FS reorganization, I may not remain the point of contact for this award. Future reviewers will need Flathead Electric to clearly explain its accounting methodology every reporting cycle. Please have Flathead Electric’s auditor reach out to my supervisor, Kamie Vaux, at kami.vaux@usda.gov so that the Forest Service can better understand what clarification the auditor is seeking. Thank you, and please let me know if you need anything additional. Sarah Fusselman Grants Management Specialist Forest Service State, Private & Tribal Forestry, Region 1 & 4 c: 208-479-3095 sarah.fusselman@usda.gov Exhibit B Continued From: Vaux, Kamie - FS, UT <kamie.vaux@usda.gov> Sent: Tuesday, July 28, 2026 9:18 AM To: Katie Dalton; Kathryn Eigenberg Cc: Stacey Nelson; Stacie Dellamano Subject: RE: [External Email]RE: Form 425 Reporting Good morning, Thank you for the detailed explanation. Yes—your understanding is correct, and the information you outlined aligns with Forest Service expectations. As we discussed, the timing differences between the quarterly SF-270 and SF-425 submissions naturally affect line 10e, and the values you’ve reported previously are exactly what we would expect to see. Adjusting the submission timing as you described may help reduce the variance, but we recognize that invoice timing will not always allow for that approach. And you’re also right that lines 10a, 10b, and 10c are generally not required for this program, and when they are included, they are not reviewed by the Forest Service. Please let me know if any additional clarification would be helpful—I’m happy to assist further. Thank you, Kamie Kamie Vaux Supervisory Grants Specialist Forest Service State, Private & Tribal Forestry Region 1 and Region 4 c: 385-278-3255 kamie.vaux@usda.gov 324 25th Street Ogden, UT 84401