Finding 1155471 (2024-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-26

AI Summary

  • Core Issue: The Foundation's procurement policy lacks essential elements required by federal standards.
  • Impacted Requirements: Compliance with procurement standards in 2 CFR sections 200.318 through 200.326 is not met.
  • Recommended Follow-Up: Revise the procurement policy to align with federal requirements and address compliance risks.

Finding Text

Federal Agency: U.S. Department of State Federal Program Name: Professional and Cultural Exchange Programs - Citizen Exchanges Assistance Listing Number: 19.415 Award Period: July 26, 2022- September 30, 2025; September 14, 2022- September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Foundation must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy of the Foundation does not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None Context: We reviewed the procurement policy of the Foundation and noted that the policy does not include the essential compliance elements as outlined in 2 CFR sections 200.318 through 200.326. Cause: Management was unaware of the restrictive requirements of the new procurement standards. Effect: With the absence of a compliant policy, the Foundation is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Foundation review its procurement policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management is not in agreement with the finding. See separate corrective action plan.

Corrective Action Plan

Professional and Cultural Exchange Programs - Citizen Exchanges - Assistance Listing No. 19.415 Recommendation: We recommend that the Foundation review its procurement and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Explanation of disagreement with audit finding: American Institute For Foreign Study Foundation, Inc. does not agree with the finding. During a visit by representatives of BEGA the existing procurement policy was shared with those representatives. They approved of it and did not recommend any changes. However, a compliant policy that complies with CFR sections 200.318 through 200.326 will be developed. Name of the contact person responsible for corrective action: James Mahoney, CFO Planned completion date for corrective action plan: August 31, 2025

Categories

Procurement, Suspension & Debarment Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1155468 2024-001
    Material Weakness Repeat
  • 1155469 2024-001
    Material Weakness Repeat
  • 1155470 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
19.415 Professional and Cultural Exchange Programs - Citizen Exchanges $555,260