Finding Text
FEDERAL FINDING INTERNAL CONTROL - SIGNIFICANT DEFICIENCY Criteria: According to Title 2 CFR Part 200.303(a), the recipient must establish, document and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the federal award. Additionally, the Market Access Program, specifically section 1485.31(a), states that all participants are required to annually submit a fraud prevention program for approval. Condition: Segregation of duties of Council disbursements were not being followed as outlined in the fraud prevention program previously approved by the Foreign Agricultural Service (FAS). Effect: Council was not in compliance with fraud prevention program for a portion of 2024. A lack of further disbursement approval could result in fraudulent activity. Cause: Council underwent Executive Director and accounting personnel changes mid-year that resulted in an internal control weakness. Recommendation: Council either follows existing fraud prevention program to incorporate a level of disbursement and documentation approval from a party other than the contracted finance management company to improve segregation of duties, or revises fraud prevention program to appropriately depict internal control framework and receives approval from FAS. Repeat finding: No.