Finding 1208810 (2023-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2026-04-24

AI Summary

  • Core Issue: The organization failed to implement adequate controls and documentation for procurement, leading to non-compliance with federal requirements.
  • Impacted Requirements: OMB’s Uniform Administrative Requirements and 2 CFR 200.318 mandate proper procurement procedures and documentation, which were not followed.
  • Recommended Follow-Up: Strengthen internal controls, ensure thorough vendor reviews, and maintain all necessary documentation to comply with federal procurement standards.

Finding Text

2023-002 Implement Controls and Documentation Over Procurement Federal Program Information Federal Agency: U.S. Department of the Interior Award Name: Natural Resource Stewardship Assistance Listing Number(s): 15.944 Award Year: 2023 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that grant recipients follow procurement procedures for the acquisition of property or services under a federal award. Grantees are required to comply with certain procurement standards as defined in 2 CFR 200.318. These standards include the requirement that the grantee must use its own documented procurement procedures provided that they conform to applicable federal law. In addition, the grantee must maintain records sufficient to detail the history of procurement. Condition and Context During planning procedures for our audit, we concluded that the prior year finding over procurement was not yet remediated. Based on our procedures, there was no supporting documentation retained for those transactions subject to procurement and approvals were not formally documented. In addition, no evidence was provided to prove a suspension and debarment check was performed. Cause The Organization did not have adequate policies or controls in place to maintain formal evidence of vendor approval. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, there is a risk that contracts may be awarded to vendors in a manner that is not consistent with Federal procurement requirements. Questioned Costs Due to the condition noted above, Federal procurement requirements were not followed and resulted in the following questioned costs. AL Number(s) Name of Federal Program Questioned Costs 15.944 Natural Resource Stewardship $37,539 Recommendation The Organization should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal requirements and supporting documentation is maintained to support such conclusion. The Organization should ensure that prior to entering into transactions, a review is performed over vendor selection, and all required documentation is retained. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Audit Finding Reference: 2023-002 Implement Controls & Documentation Over Procurement (Material Weakness) Planned Corrective Action: Procurement supporting documentation will be maintained for all vendor transactions $10,000 and greater, including a suspension and debarment check to ensure the vendor organization is not excluded from being eligible to receive federal funds due to past misconduct. Note, the audit finding was originally included in the 2022 single audit report completed in early 2025. Planned Implementation Date of Corrective Action: March 14, 2025. Person Responsible for Corrective Action: Nick Fisichelli, President & CEO

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1208811 2023-003
    Material Weakness Repeat
  • 1208812 2023-003
    Material Weakness Repeat
  • 1208813 2023-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.944 NATURAL RESOURCE STEWARDSHIP $585,932
15.945 COOPERATIVE RESEARCH AND TRAINING PROGRAMS – RESOURCES OF THE NATIONAL PARK SYSTEM $169,398
15.946 CULTURAL RESOURCES MANAGEMENT $140,031
47.083 INTEGRATIVE ACTIVITIES $13,970
43.001 SCIENCE $11,277
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $10,886
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $9,222
11.478 CENTER FOR SPONSORED COASTAL OCEAN RESEARCH COASTAL OCEAN PROGRAM $8,692
10.652 FORESTRY RESEARCH $7,599