Finding Reference 2025-002 Personnel Responsible for Corrective Action: Drafting of policy, procedures, and forms will be completed by Westen Gehring (Grants Specialist) and Laura Froese (Accounting Manager), with input and final approval provided by Tracie Thomas (Chief Operating Officer) Anticipat...
Finding Reference 2025-002 Personnel Responsible for Corrective Action: Drafting of policy, procedures, and forms will be completed by Westen Gehring (Grants Specialist) and Laura Froese (Accounting Manager), with input and final approval provided by Tracie Thomas (Chief Operating Officer) Anticipated Completion Date: The Effort Verification Policy and related procedures will be finalized by July 1, 2026, for implementation in Fiscal Year 2027. Retroactive effort certification for the period July 1, 2025 through March 31, 2026 will be completed by June 30, 2026. Monthly implementation tests of the new policies and procedures will begin with the April 2026 reporting period. Views of Responsible Officials and Planned Corrective Action: Concur. Corrective Actions Planned: The Land Institute will implement a formal effort reporting system effective July 1, 2026 (Fiscal Year 2027), including finalized policies, procedures, and standardized effort certification forms designed to ensure compliance with 2 CFR 200.430 As part of the transition to this system, retroactive effort certifications will be completed for Fiscal Year 2026 for the period of July 1, 2025 through March 31, 2026 to support payroll costs previously charged to federal awards. The months of April through June 2026 will be utilized as an implementation and testing period to establish and refine the monthly effort certification process. During this time, The Land Institute will complete effort certifications on a monthly basis, reflecting an after-the-fact determination of actual work performed across all institutional activities, and integrate the certification process into month-end close procedures. This phased implementation approach will allow management to validate processes, ensure accuracy and completeness of certifications, and make any necessary adjustments prior to full implementation in Fiscal Year 2027. Training will be provided to all applicable staff to ensure understanding of effort reporting requirements and compliance expectations. Finance and Grants personnel will monitor compliance and timeliness of certifications, and ongoing monitoring controls will be implemented to ensure continued compliance.