Finding 1153432 (2024-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-09-18

AI Summary

  • Core Issue: The Schedule of Expenditures of Federal Awards (SEFA) had significant inaccuracies, including omitted amounts passed to subrecipients and misreported expenditures.
  • Impacted Requirements: Compliance with 2 CFR §200.510(b) was not met, risking noncompliance with Federal reporting requirements.
  • Recommended Follow-Up: Implement formal procedures for SEFA preparation, including reconciliations, grant agreement reviews, and supervisory checks, along with training for staff on SEFA requirements.

Finding Text

Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Commerce. Federal Programs: Ocean Exploration, Coastal Zone Management Administration Awards, Marine Sanctuary Program, Unallied Management Projects, Habitat Conservation, Building Resilience through Community Stewardship of Coral Reefs, Marine Debris Program. Assistance Listing Numbers: 11.011, 11.419, 11.429, 11.454, 11.463, 11.473, 11.999. Compliance Requirement: Reporting. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance. Criteria: Per 2 CFR §200.510(b), the auditee must prepare a SEFA that includes total Federal expenditures, the name of the Federal agency, the Assistance Listing Number, and other identifying information. The SEFA must be accurate, complete, and prepared in accordance with the Uniform Guidance to facilitate the Single Audit. Condition: During our audit of the SEFA for the year ended December 31, 2024, we noted that the initial SEFA provided by management contained material inaccuracies. Specifically, we noted that amounts passed through to subrecipients were not properly reported and certain programs had expenditures that were inaccurately reported. Cause: The inaccuracies in the SEFA were primarily due to a lack of formalized procedures and oversight in the SEFA preparation process. Effect or Potential Effect: An incomplete or inaccurate SEFA may result in inadequate audit coverage, potential noncompliance with Federal reporting requirements, and increased risk of questioned costs or funding disallowances. Questioned Costs: None. Context: The initial SEFA provided for audit included approximately $310,000 passed through to subrecipients. During the performance of our audit procedures, we identified approximately $5.2 million in amounts passed through to subrecipients that were omitted. Additionally, other expenses were omitted from the SEFA as well. The SEFA was subsequently revised and corrected by management. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management implement formal procedures for compiling the SEFA, including a reconciliation of expenditures to the general ledger, review of all grant agreements for required disclosures, and a documented supervisory review prior to finalization. Staff involved in Federal grant reporting should also receive training on SEFA requirements under Uniform Guidance.

Corrective Action Plan

Views of Responsible Officials: Management concurs with the auditor’s findings related to Federal award compliance and questioned costs. Several internal transitions contributed to the control gaps and compliance lapses identified during the audit period, including:  The implementation of a new chart of accounts and a new instance of the Sage Intacct accounting system, which impacted reporting structures and account mapping for Federal programs.  A transition in finance leadership, which affected oversight of Federal grant compliance and reporting.  The lack of timely replacement for a key vacant finance position, which limited staff capacity during critical reporting periods. These factors collectively contributed to the challenges experienced in adhering to certain requirements under the Uniform Guidance, including the accurate preparation of the Schedule of Expenditures of Federal Awards (SEFA) and the documentation of allowable costs. To address the findings and prevent recurrence, management has taken or is taking the following steps:  Staff training on SEFA preparation and Uniform Guidance requirements will be conducted to ensure a full understanding of Federal compliance obligations. Will ask GRF what recommendations they have for trainings by August 2025.  Verify chart of accounts mapping for Federal grants has been finalized and validated within the new Intacct system to support more accurate tracking of expenditures. – Complete by September 2025.  The utilization of the C-STAAR system will support a more structured and consistent internal grant management process.  Finance will also evaluate the grants management module within the accounting system to determine feasibility for integration and ease of syncing with SEFA reporting requirements.  A calendar of Federal reporting deadlines will be developed to strengthen compliance monitoring and accountability. – By October 2025. Management is committed to improving its internal controls and ensuring compliance with all applicable Federal requirements moving forward.

Categories

Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1153423 2024-002
    Material Weakness Repeat
  • 1153424 2024-002
    Material Weakness Repeat
  • 1153425 2024-002
    Material Weakness Repeat
  • 1153426 2024-002
    Material Weakness Repeat
  • 1153427 2024-002
    Material Weakness Repeat
  • 1153428 2024-002
    Material Weakness Repeat
  • 1153429 2024-002
    Material Weakness Repeat
  • 1153430 2024-002
    Material Weakness Repeat
  • 1153431 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.429 Marine Sanctuary Program $11.03M
11.999 Marine Debris Program $9.38M
11.463 Habitat Conservation $7.08M
11.454 Unallied Management Projects $1.15M
11.473 Office for Coastal Management $1.01M
11.469 Congressionally Identified Awards and Projects $499,164
11.011 Ocean Exploration $460,081
66.436 Surveys, Studies, Investigations, Demonstrations, and Training Grants and Cooperative Agreements - Section 104(b)(3) of the Clean Water Act $213,056
11.419 Coastal Zone Management Administration Awards $143,375
11.417 Sea Grant Support $73,791
15.645 Marine Turtle Conservation Fund $51,464
11.008 Noaa Mission-Related Education Awards $25,002
19.017 Environmental and Scientific Partnerships and Programs $76