Finding Text
Finding No.: 2023-021 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: Compact of Free Association, As Amended Questioned Costs: $ Undeterminable Area: Special Test and Provisions – Annual Performance Reviews Criteria: Education Sector NGA Section 4c. states that in furtherance of the progress made under JEMFAC Resolution 2015-MT-2 all personnel funded from Education Sector, Supplemental Education Grant (SEG) and Ebeye Special Needs (ESN) grants are required to undergo an annual performance evaluation and such evaluation shall be maintained as part of the personnel files and made available when requested for purposes of grant oversight or audits. Furthermore, 2 CFR 200.303(a) states that a recipient of a Federal award 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. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the COSO. Condition: We were not provided with a complete listing of personnel funded by the Education Sector, SEG and ESN grants and evidence that the annual performance evaluation was conducted for such personnel. Thus, we were unable to ascertain compliance with this grant special terms and conditions. Cause: RepMar lacks adequate internal control policies and procedures to facilitate monitoring of and compliance with grant special terms and conditions. Effect: RepMar is potentially in noncompliance with applicable special tests and provision. We were unable to execute sufficient appropriate audit procedures. Accordingly, questioned cost is undeterminable. Recommendation: RepMar should establish adequate internal control policies and procedures to facilitate monitoring of and compliance with grant special terms and conditions. Views of Responsible Officials: RepMar’s Corrective Action Plan does not indicate disagreement and provides planned corrective action.