Finding Text
Reporting ALN 10:854: Rural Economic Development Loan and Grant Criteria: Rural Economic Development Loan and Grant Programs are subject to 2 CFR 200, subpart F Audit Requirements. These regulations state that a non-federal entity that expends $1,000,000 or more during the entity’s fiscal year in federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. The determination of when a federal award is expended must be based on when the activity related to the federal award occurs. Generally, the activity related to the Federal award pertains to events that require the non-federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as (2 CFR 200.501 and 2 CFR 200.502): • Expenditure/expense transactions associated with grants, cooperative agreements, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, and direct appropriations; • The disbursement of funds to subrecipients; • The use of loan proceeds under loan and loan guarantee programs; • The receipt of property (including surplus property); • The receipt or use of program income; • The distribution or use of food commodities; • The disbursement of amounts entitling the non-Federal entity to an interest subsidy; and • The period when insurance is in force. Condition: The Cooperative transferred $2,000,000 in loan funds to a subrecipient in 2025. The Cooperative was unaware that they needed a single audit and did not prepare a schedule of expenditures of federal awards (SEFA). There are also no written procedures on how to prepare a SEFA. Context: The Cooperative retained support for the federal funds expended and have documentation from federal agencies to prepare a SEFA, and the Rural Economic Development Loan Agreement refers to 7 CFR 4280, Subpart A, which requires the audit. Effect: Non-compliance with federal regulations. Questioned Costs: None. Cause: This is the first year the Cooperative received these loan funds and were unaware that a single audit was needed. Auditor Recommendation: We recommend the Cooperative retain support for all federal funds expended in order to determine if the $1,000,000 threshold is met, triggering a single audit. We also recommend the Cooperative put procedures in place on how to prepare the SEFA. Fergus Electric Cooperative Response: Fergus worked in conjunction and regularly communicated with the local Montana USDA REDL/G office to understand program requirements, provide requested information, and meet federal guidelines. Loan agreement RD 4280-5, (Dated 10/31/2024) refers to 7 CFR part 4280, Subpart A, as (“Regulations”). Fergus was unaware that 2 CFR 200 regulations are associated with 7 CFR part 4280, Subpart A. Fergus regretfully acknowledges that we were not informed or aware of obligations to meet the regulatory requirements within 2 CFR 200. Fergus has adopted and implemented a policy, Federal Funding Compliance, to establish formal procedures and ensure ongoing compliance with applicable federal regulations, including 7 CFR 4280, Subpart A and 2 CFR 200.