Finding Text
2024-003—REPORTING Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instance of Noncompliance related to Federal Awards Funding Agency U.S. Department of Agriculture (“USDA”) Programs Beginning Farmer and Rancher Development Program; Award: BFRDP-2023-49400-40894 (AL 10.311); Period: 09/15/2023-09/14/2026 Partnerships for Climate-Smart Commodities; Award: USDA/NR243A750004G005 (AL 10.937); Period: 11/02/2023 -11/01/2028 Questioned Costs None identified Statement of Condition During our testing of the Reporting Compliance requirement for the major federal programs, we noted the SF-425 reports were generated based on Harvest billing/tracking system and not properly reconciled to the general ledger (QuickBooks). In addition, some other minor clerical errors were also present. Criteria In accordance with 2 CFR 200.327 (Financial Reporting) and award terms requiring SF-425 is required to be submitted for the Beginning Farmer and Rancher Development Program and Partnerships for Climate-Smart Commodities program. Recipients use the SF-425 as a standardized format to report expenditures under Federal awards, as well as, when applicable, cash status. The report should be reconciled to the general ledger on same basis as marked on the SF-425. Also, the reports need to be reviewed for accuracy and completeness. Cause Reports were submitted based on the tracking/billing system (Harvest) and not reconciled to QuickBooks. Effect Reports could have errors and jeopardize future federal funding. Recommendation Quivira should implement procedures and controls to ensure that the federal reports are reconciled, reviewed for accuracy and completeness before submission. Views of Responsible Officials and Planned Corrective Action Management agrees that, despite regular reviews of SF-425 reports for accuracy and completeness, current steps were not adequate to ensure federal reports are reconciled and reviewed for accuracy and completeness before submission. This finding is directly connected to 2024-001, and the same action steps will address this finding. To correct for this significant deficiency, Quivira Coalition will:Action Step Detail Date Responsible Party Develop a new, compliant method to allocate personnel costs for federal billing and reporting. Stop using the timekeeping system (Harvest) for allocation. The new method must properly reflect actual paid salaries, paid fringe, and actual time spent. 12/31/2025 Accounting Firm Update reporting process to reconcile all costs reported on the SF-425 to the general ledger (instead of the timekeeping system) using the new federal grants billing process. Keep detailed records of the reconciliation. 12/31/2025 Accounting Firm Implement a monthly reconciliation process between the time and expense system (Harvest) and the QuickBooks general ledger to reconcile all non-personnel expenses. 1/30/2026 Operations Director Document the grant management process, including new reporting processes, required reconciliations, monitoring policies, and allowable cost management to ensure consistency across the organization. 2/28/2026 Operations Director Update policies and procedures to require that expenses reported on the SEFA form come directly from the accounting system to ensure this continues. 1/30/2026 Operations Director Update policies and procedures to require an annual reconciliation between the SF-425 and SEFA reports to ensure this continues. This occurs before submitting the SEFA report. 1/30/2026 Operations Director Reconcile all grant programs active in 2024 using updated processes and resolve any discrepancies with federal reports or billing. 1/30/2026 Initial Review - Operations Director & Grants Manager Secondary Review & Corrections (if needed) - Accounting Firm Develop a plan to ensure regular and sufficient training on Uniform Guidance tracking regulatory changes, and how to implement changes. Update policies and procedures. 11/30/2025 Operations Director & Executive Director Update policies and procedures to require an additional level of review and approval for SF-425 and SEFA reports and reconciliations for accuracy and completeness before they are submitted. 12/31/2025 Operations Director with final approval from the Executive Director