Finding 1186610 (2025-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-03-25
Audit: 394315
Organization: American Rivers, Inc. (DC)
Auditor: RSM US LLP

AI Summary

  • Core Issue: American Rivers did not report subawards over $30,000 as required by the Federal Funding Accountability and Transparency Act (FFATA), leading to a material weakness in compliance.
  • Impacted Requirements: The failure to submit reports resulted from a misunderstanding of new reporting requirements, affecting federal spending transparency on USASpending.gov.
  • Recommended Follow-up: Complete the overdue reporting immediately and establish a process to verify future changes with the grantor to ensure ongoing compliance.

Finding Text

Item 2025-002 – Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting Not Performed Type of Finding: Material weakness in Internal Control over Compliance; Other Matter Compliance Finding Federal Award Agency: Department of Commerce Pass-through Entity: N/A Federal Program: Habitat Conservation Assistance Listing Number: 11.463 Federal Award Identification Number: NA19NMF4630270; NA23NMF4630019; NA23NMF4630020; NA24NMFX463C0004-T1-01 Federal Award Year: Year ended June 30, 2025 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended, hereafter referred as the “Transparency Act” that are codified in 2 CFR Parts 25 and 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to System for Award Management (SAM.gov). Condition: American Rivers failed to submit report for the new subrecipient awards under the Federal Funding Accountability and Transparency Act. This failure is a result of improper implementation and understanding of new requirements to submit such reporting under a new platform. The reports have been subsequently prepared, reviewed and submitted after the deadline. Cause: American Rivers was not aware of the change in filing systems and thus determined that they were no longer required to file. Effect: Incomplete data was available to the public on USASpending.gov, reducing federal spending transparency as intended by the Transparency Act. This noncompliance could also lead to a loss of federal funds. Questioned costs: None Context: FFATA reporting was not completed for any subawards made during the year. Repeat finding: No Recommendation: Reporting should be completed as soon as possible. When there are changes in the future, management should verify the changes by contacting the grantor organization to ensure compliance. Views of responsible officials: American Rivers agrees with the finding.

Corrective Action Plan

Finding Number: 2025-002 – Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting Not Performed Planned Corrective Action: American Rivers hired a Grants Director in January 2026 and the FFATA reporting will be the director’s responsibility to ensure compliance with all FFATA and other required reporting. Anticipated Completion Date: 02/28/2026 Responsible Contact Person: Vickie Barrow-Klein, Chief Financial Officer

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1186611 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
81.087 RENEWABLE ENERGY RESEARCH AND DEVELOPMENT $1.26M
15.685 NATIONAL FISH PASSAGE $661,901
66.466 GEOGRAPHIC PROGRAMS - CHESAPEAKE BAY PROGRAM $453,085
15.512 CENTRAL VALLEY IMPROVEMENT ACT, TITLE XXXIV $443,794
15.507 WATERSMART (SUSTAIN AND MANAGE AMERICA’S RESOURCES FOR TOMORROW) $394,670
15.677 HURRICANE SANDY DISASTER RELIEF ACTIVITIES-FWS $203,761
97.045 COOPERATING TECHNICAL PARTNERS $162,157
97.061 CENTERS FOR HOMELAND SECURITY $136,869
15.663 NFWF-USFWS CONSERVATION PARTNERSHIP $123,945
10.699 PARTNERSHIP AGREEMENTS $95,067
21.027 COVID-19 - CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $92,952
15.686 NATIONAL FISH HABITAT PARTNERSHIP $90,550
10.729 INFLATION REDUCTION ACT - NATIONAL FOREST SYSTEM $68,965
15.608 FISH AND AQUATIC CONSERVATION - AQUATIC INVASIVE SPECIES $67,758
15.962 NATIONAL WILD AND SCENIC RIVERS SYSTEM $50,999
66.437 GEOGRAPHIC PROGRAMS – LONG ISLAND SOUND PROGRAM $18,945
97.029 FLOOD MITIGATION ASSISTANCE $16,098
15.954 NATIONAL PARK SERVICE CONSERVATION, PROTECTION, OUTREACH, AND EDUCATION $13,541
11.463 HABITAT CONSERVATION $7,636
15.670 ADAPTIVE SCIENCE $6,788
11.473 OFFICE FOR COASTAL MANAGEMENT $5,330
10.932 REGIONAL CONSERVATION PARTNERSHIP PROGRAM $3,248