Finding 1227938 (2025-002)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-08-26
Audit: 409850
Organization: North Pacific Research Board (AK)
Auditor: CLARK NUBER PS

AI Summary

  • Core Issue: NPRB failed to issue a required management decision for a subrecipient's audit finding, indicating a significant deficiency in internal controls over compliance.
  • Impacted Requirements: This noncompliance violates 2 CFR 200.332 and 2 CFR 200.521, which mandate monitoring and management decisions for subrecipients.
  • Recommended Follow-Up: Update procedures to ensure timely review of subrecipient audit reports, communicate management decisions, and retain necessary documentation.

Finding Text

Significant Deficiency in Internal Control Over Compliance and Noncompliance Related to Management Decisions for Subrecipient Audit Findings Identifying Award Information Federal Agency: U.S. Department of Commerce, National Oceanic and Atmospheric Administration (NOAA) Assistance Listing Number: 11.472 Federal Program: Unallied Science Program Criteria Under the requirements for pass-through entities in 2 CFR 200.332, 2 CFR 200.521, and related sections, the pass-through entity is required to monitor the activities of a subrecipient. This includes among other things, obtaining the Single Audit reports for the subrecipient and identify any findings report directly related to the pass-through entity’s subaward to the subrecipient. The pass-through entity is responsible for issuing a management decision for audit findings that affect subawards it issues to subrecipients under a Federal award. Condition and Context Among the five sub-awards we tested, one subrecipient had an audit finding directly related to NPRB’s subaward to that subrecipient. NPRB did not retain documentation evidencing that NPRB followed up with the subrecipient to issue a management decision related to the finding. Cause NPRB did not have procedures and controls in place to ensure the required management decisions were issued to subrecipients. Effect NPRB did not comply with the manage decision requirement for pass-through entities that are codified in Title 2 U.S. Code of Federal Regulations. Known Question Costs Not applicable. Repeat Finding This is not a repeat finding. Recommendations We recommend that management update procedures to ensure subrecipient Single Audit reports are reviewed and management decisions are communicated, and related documentation is retained. Views of Responsible Officials Management concurs with the finding and has provided the attached corrective action plan.

Corrective Action Plan

Assistance Listing Number (ALN) & Program Name: 11.472 Unallied Science Program (U.S. Dept. of Commerce, NOAA) Fiscal Year: FY2025 Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Related to Management Decisions for Subrecipient Audit Findings. NPRB has taken significant corrective action to strengthen its subrecipient monitoring procedures. Effective October 1, 2025, NPRB transitioned its accounting, financial operations, and grants management and reporting from its former fiscal agent to direct management by NPRB staff. NPRB is updating its written subaward procedures to establish a formal process for monitoring subrecipient compliance with applicable Single Audit requirements under 2 CFR Part 200. The procedures require NPRB to determine the applicability of Single Audit requirements to its subrecipients, obtain and review applicable subrecipient Single Audit reports, document the results of those reviews, and retain supporting documentation. NPRB has also established a tracking process and calendar for subrecipient monitoring. Identified audit findings related to NPRB’s subawards will be evaluated and documented, required management decisions will be issued and communicated to the subrecipient, and corrective actions will be tracked through resolution. Documentation of NPRB’s review, management decisions, follow-up, and resolution will be retained as part of the applicable subaward file.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1227935 2025-001
    Material Weakness Repeat
  • 1227936 2025-001
    Material Weakness Repeat
  • 1227937 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.472 COOPERATIVE RESEARCH PROGRAM $2.04M