Finding Text
Program: Forest Service Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.664 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Vermont Land Trust is required to prepare a complete and accurate Schedule of Expenditures of Federal Awards that includes, for each federal award, the correct Assistance Listing number, current Assistance Listing title, award number, award year, name of the federal agency, and name of the passthrough entity (if applicable). Only awards with expenditures incurred during the current audit period should be presented. Condition: In the SEFA submitted for audit, Vermont Land Trust included a federal award that had been fully expended and closed out in prior fiscal years. The expenditures that were included were for fiscal year 2024 fourth quarter expenditures. Effect of Condition: The SEFA report provided by management was overstated by approximately $9,900. Inclusion of fully expended prior-year awards could have resulted in inaccurate reporting on the final SEFA and the Data Collection Form (SF-SAC) had the error not been identified and corrected during the audit. Recommendation: Vermont Land Trust should establish and document a formal SEFA preparation procedure that includes reconciliation of all awards to the general ledger and grant closeout records to ensure only awards with current-year expenditures are included. A SEFA preparation checklist with designated review and approval steps should be implemented and retained as evidence of the control. View of Responsible Officials and Planned Corrective Action: Management acknowledges this finding. As a result of limitations in the SEFA preparation and reconciliation process during the prior fiscal year, certain FY2024 fourth-quarter expenditures were not properly accrued and were instead recorded in FY2025. In connection with the transition of key finance staff, these expenditures were inadvertently included on the first draft of the Schedule of Expenditures of Federal Awards as a part of a federal award that had been fully expended and closed out the in the prior fiscal year. The error was identified and corrected during the audit. Vermont Land Trust has taken targeted steps to address the specific circumstances that resulted in this finding. Management performed a detailed review and reconciliation of active federal awards, including the award affected by fourth-quarter accrual activity, to confirm proper period recognition and award closeout status. As a result, the fully expended award was appropriately removed from the SEFA during the audit. To prevent similar issues during periods of staff transition or year-end close, management has implemented additional review procedures focused on fourth-quarter federal expenditures and accruals.These procedures include verification of award status prior to SEFA preparation and reconciliation of SEFA amounts to the general ledger and grant tracking records. Management believes these targeted actions appropriately address the conditions identified in the finding, and based on subsequent review, no similar issues have been identified. Planned Implementation Date of Corrective Action: Implemented during FY2025 Person Responsible for Corrective Action: Tracy Zschau, President & CEO