Finding 1166194 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2025-12-22
Audit: 377089
Organization: Washington Maritime Blue (WA)
Auditor: CLARK NUBER PS

AI Summary

  • Core Issue: There is a significant deficiency in internal control over compliance related to reporting subawards as required by the Transparency Act.
  • Impacted Requirements: The organization failed to report a covered subaward of $49,646 and did not submit reports on time, violating 2 CFR Part 170.
  • Recommended Follow-Up: Ensure all covered subawards are reported accurately and on time to comply with the Transparency Act moving forward.

Finding Text

Significant deficiency in internal control over compliance related to reporting. Federal Agency: United States Department of Commerce Program Title: Congressionally Identified Awards and Projects Assistance Listing Number: 11.469 Project Number: NA25NMFX469G0061 Award Period: November 1, 2023 - October 31, 2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act) that are codified in 2 Code of Federal Regulations (CFR) Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register the covered subawards in the System for Award Management (SAM) and report the required subaward data no later than the last day of the month following the month the subaward was made. Condition/Context for Evaluation During the award period ended June 30, 2025, Washington Maritime Blue did not report a covered subaward as required by the Transparency Act. Transaction Tested: 1 Dollar Amount of Transactions Tested: $10,953 Subaward Not Reported: 1 Subaward Not Reported: $49,646 Report Not Timely: 1 Report Not Timely: $10,953 Subaward Amount Incorrect: NA Subaward Amount Incorrect: NA Subaward Missing Key Elements: 1 Subaward Missing Key Elements: $49,646 Effect or Potential Effect The Organization did not comply with the subaward reporting requirements as specified in 2 CFR 170. Questioned Costs Not applicable. Cause Though the Organization has established internal controls for submitting covered subawards as required by the Transparency Act, the Organization made an incorrect determination that the covered subaward was under the required reporting limit. Repeat Finding No Recommendation We recommend that the Organization ensure required reporting of covered subawards is made in accordance with the Transparency Act. Views of Responsible Officials Management agrees that the required FSRS report was not made. After the issue was raised as part of the Single Audit, management took measures to enter the required subawards.

Corrective Action Plan

Description: Significant deficiency in internal control over compliance related to reporting. Cause: Though the Organization has established internal controls for submitting covered subawards as required by the Transparency Act, the Organization made an incorrect determination that the covered subaward was under the required reporting limit. Effect: The Organization did not comply with the subaward reporting requirements as specified in 2 CFR 170. Corrective Action: • The Organization’s management and Board of Directors understand the requirement and importance of complying with the Federal Funding Accountability and Transparency Act. Our Accounting & Finance Policy and Subrecipient Monitoring Policy have both been updated to clearly assign the responsibility for timely reporting of subawards. The covered subaward that was not reported in FY25 was reported promptly as soon as this issue was raised as part of the audit. Contact Person: Daniel Pulse, CFO Anticipated completion date: November 2025, Corrective action has been completed.

Categories

Reporting Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 1166195 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.024 BUILD TO SCALE $349,856
11.469 CONGRESSIONALLY IDENTIFIED AWARDS AND PROJECTS $222,222
11.012 INTEGRATED OCEAN OBSERVING SYSTEM (IOOS) $141,686
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $111,425
12.017 READINESS AND ENVIRONMENTAL PROTECTION INTEGRATION (REPI) PROGRAM $102,455
17.259 WIOA YOUTH ACTIVITIES $100,069
20.817 AIR EMISSIONS AND ENERGY INITIATIVE $13,750
93.262 OCCUPATIONAL SAFETY AND HEALTH PROGRAM $2,800