Finding 1224785 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-07-27
Audit: 407987
Organization: Ecotrust (OR)
Auditor: APRIO LLP

AI Summary

  • Core Issue: The Organization failed to submit the required SF 425 Federal Financial Report for FY 2025 on time, indicating a lack of effective internal controls.
  • Impacted Requirements: Noncompliance with federal reporting requirements as outlined in the Uniform Guidance and the American Rescue Plan Technical Assistance Investment Program.
  • Recommended Follow-Up: Improve controls for federal financial reporting, clarify responsibilities, ensure continuity during staff absences, and provide regular training on reporting requirements.

Finding Text

Federal Award Identification: 2023-70417-39322 Federal Program: American Rescue Plan Technical Assistance Investment Program Assistance Listing: 10.234 Federal Agency: U.S. Department of Agriculture Pass-through Entity: Not applicable - direct award Award Period Audited: Fiscal year ended December 31, 2025 Criteria: The Uniform Guidance and the terms and conditions of the American Rescue Plan Technical Assistance Investment Program require non Federal entities to submit required financial reports, including the SF 425 Federal Financial Report, within prescribed timeframes. Annual financial reports are generally due within 90 calendar days after the end of the reporting period, unless otherwise specified by the federal awarding agency. Condition: Ecotrust and its Subsidiaries (collectively, the Organization) did not submit the required annual SF 425 Federal Financial Report for the fiscal year ended December 31, 2025, within the prescribed timeframe. The report was submitted after the applicable due date but prior to the issuance of the auditor’s reports. Context: This condition was identified during testing of the Reporting compliance requirement. As part of audit procedures, we inquired of management regarding the status and timing of submission of the SF-425 Federal Financial Report. In connection with these procedures, we also noted that the SF 425 for the fiscal year ended December 31, 2024 had not been submitted within the prescribed timeframe. Cause: The condition resulted from a misunderstanding of applicable federal reporting requirements and unclear assignment of responsibility for federal financial reporting, including inadequate procedures to ensure reporting requirements were monitored during staff absences. Effect: As a result, the Organization did not ensure timely submission of required SF 425 Federal Financial Reports, resulting in noncompliance with federal reporting requirements. This condition indicates that internal controls over federal reporting were not operating effectively with respect to the timely submission of required reports, potentially limiting the federal awarding agency’s ability to perform timely oversight and monitoring. Known Questioned Costs: None. Repeat Finding Status: This is a new finding for the year ended December 31, 2025. Recommendation: The Organization should strengthen controls over federal financial reporting to ensure required SF 425 Federal Financial Reports are submitted timely in accordance with 2 CFR 200.328 and applicable award terms. Such controls should include clearly defined responsibility for federal reporting, procedures to ensure continuity of reporting during staff absences, and periodic training to reinforce awareness of federal reporting requirements. Views of Responsible Officials: Management agrees with the finding. Management acknowledges that the SF 425 Federal Financial Report was not submitted within the prescribed timeframe and has indicated that corrective actions will be taken to strengthen controls over the timely submission of required federal financial reports.

Corrective Action Plan

Ecotrust is strengthening its controls over federal financial reporting to ensure required SF‑425 Federal Financial Reports are submitted (in a timely manner) in accordance with 2 CFR 200.328 and applicable award terms. Approximately three years ago, following turnover, Ecotrust shifted grantee and sub‑grantee management from a centralized model to a distributed model in which program managers assumed responsibilities for which tools and training were insufficient. To correct the underlying deficiency, Ecotrust is taking the following specific actions: • Assigning clear, documented responsibility for the preparation and timely submission of all federal financial reports (including the SF‑425), with a designated primary preparer and a backup to ensure continuity of reporting during staff absences or turnover. • Establishing a federal reporting calendar that tracks all federal financial report due dates, with proactive advance reminders shared across the finance and program teams. • Providing periodic training to finance and program staff to reinforce awareness of federal financial reporting requirements and deadlines. • Engaging an outside consultant, Jennifer Hutton, who has grantee‑management experience gained at Mercy Corps and other non‑profits, to work with the finance team and program managers to develop the supporting processes, tools, and accountability measures.

Categories

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1224786 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.234 COVID-19: AMERICAN RESCUE PLAN TECHNICAL ASSISTANCE INVESTMENT PROGRAM $622,574
10.971 COVID-19: URBAN AGRICULTURE AND URBAN COUNTY COMMITTEE OUTREACH, TECHNICAL ASSISTANCE, AND EDUCATION $502,017
10.872 HEALTHY FOOD FINANCING INITIATIVE $229,614
10.443 OUTREACH AND ASSISTANCE FOR SOCIALLY DISADVANTAGED AND VETERAN FARMERS AND RANCHERS $198,315
10.937 PARTNERSHIPS FOR CLIMATE-SMART COMMODITIES $178,291
10.575 FARM TO SCHOOL GRANT PROGRAM $116,147
10.175 FARMERS MARKET AND LOCAL FOOD PROMOTION PROGRAM $61,334
10.699 PARTNERSHIP AGREEMENTS $42,000
10.771 RURAL COOPERATIVE DEVELOPMENT GRANTS $31,080