Finding Text
Federal Agency: United States Department of Commerce
Federal Program Name: Office for Coastal Management
Assistance Listing Number: 11.473
Federal Award Identification Year: 2020
Pass-Through Agency: National Fish and Wildlife Grant Agreement
Award Period: 9/1/20-08/02/24
Compliance Requirement Affected: Subrecipient Monitoring
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified
Opinion)
Criteria: 2 CFR 200.332(d) - establishes that the auditee must monitor the activities of the subrecipient as
necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal
statutes, regulations, and the terms and conditions of the subaward; and that subaward performance
goals are achieved.
Condition: CFSC did not perform risk assessment for all subrecipients selected for testing. CFSC was unable to
provide supporting documentation to show that they inquired with the subrecipients about any audits
they had undergone or evidence that CFSC received and reviewed audit reports to ensure timely follow
ups were made if any findings pertaining to the Federal Award was noted.
Context: A nonstatistical sample of 2 out of 4 subrecipients were selected for testing for the Office for Coastal
Management program. The condition noted above was identified during our procedures over CFSC’s
subrecipients.
Effect: CFSC did not perform the following, which increases the risk of noncompliance:
-Required risk assessments for the subrecipients,
-Review subrecipient audit reports to ensure compliance with Federal Awards or make any necessary follow-ups pertaining to any findings noted, if any.
Cause: CFSC’s procedures did not consistently ensure that the required risk assessments were performed.
Repeat Finding: The finding is a repeat finding.
Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required risk assessments are performed in accordance with the criteria outlined above.
Management’s Views: See separate corrective action plan.