The National Conference of State Historic Preservation Officers respectfully submit the following corrective action plan for the year ended December 31, 2024
Name and address of independent public accounting firm:
CBIZ
1899 L Street, NW, Suite 850
Washington, DC 20036
Audit Period: January 01, 2024 ...
The National Conference of State Historic Preservation Officers respectfully submit the following corrective action plan for the year ended December 31, 2024
Name and address of independent public accounting firm:
CBIZ
1899 L Street, NW, Suite 850
Washington, DC 20036
Audit Period: January 01, 2024 to December 31, 2024
The findings from the Schedule of Finding for the year ending December 31,2024, are discussed below. The findings are numbered consistently with the number assigned in the schedule.
Finding No. 2024-001
Revenue Recognition – Significant Deficiency in Internal Control over Financial Reporting:
The finding was that NCSHPO provided a trial balance and SEFA that omitted indirect cost rates on accrued direct expenditures through December 31, 2024.
Contacts for Corrective Action:
Sharon Smith, Business Manager – email: smith@ncshpo.org – phone: 202-624-5465
Erik Hein, Executive Director – email: hein@ncshpo.org – phone: 202-624-5465
The NCSHPO only recognized the direct costs as revenue for the period ending 12/31/24 not considering that the indirect cost rate should be accrued as revenue also thus causing the SEFA to not balance with the Trial Balance at the end of the year. NCSHPO agreed with CBIZ that the indirect costs should be recognized.
The NCSHPO will begin a new internal control procedure to recognize the indirect costs as revenue to include on the SEFA schedule monthly beginning July 1, 2025. The SEFA and the Trial Balance will be reconciled for each job report. When Accounts Receivable (1120-000-0000), Revenue (4700-104-XXXX) and Administration fee/Indirect costs (4420-000-0000) are reconciled, then the SEFA, the Trial balance and the journal entry transaction(s) to recognize revenue will be given to the Executive Director to review and approve to be entered into the General Ledger.
Implementation date: 07-01-2025
Finding No. 2024-002
Procurement – Significant Deficiency in Internal Control Over Compliance
RE: Federal Award Identification Numbers P17AC00528 and P22AM01146
The finding was that NCSHPO failed to perform the required search of vendors per Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Section 200.213. NCSHPO agreed with CBIZ that we did not do a search for suspension and debarment in SAM for any of the vendors and that it was not included in our Procurement Policy.
Contacts for Corrective Action:
Sharon Smith, Business Manager – email: smith@ncshpo.org – phone: 202-624-5465
Erik Hein, Executive Director – email: hein@ncshpo.org – phone: 202-624-5465
The NCSHPO updated the Procurement Policy to include a section for Suspension and Debarment. NCSHPO then used SAM to obtain the proper documentation to include in each respective vendor’s file.
The NCSHPO will implement the new procedure to do a search in SAM.gov for every vendor it selects to do business with under the Cooperative Agreement and continue to do the search annually. Below is the new policy that is included in NCSHPO’s Procurement Section:
Suspension and Debarment:
NCSHPO verifies that the vendor or subrecipient with whom NCSHPO intends to do business is not excluded or disqualified in accordance with 2 C.F.R. Part 200, Appendix II (1) and 2 C.F.R. §§ 180.220 and 180.300. Before final selection, the Business Manager or the Special Projects Manager will perform a search on the General Services Administration Excluded Parties List System (EPLS) (http://www.sam.gov). Results of the screenings should be printed and placed in the procurement file. Suspension and debarment checks will be updated annually and will remain documented in the procurement file in line with NCSHPO’s document retention policy. The ED ensures this is completed during inspection and approval of procurement.
Implementation date: 04/30/2025