Finding 1237648 (2025-007)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-09-28
Audit: 412567
Organization: Walker Basin Conservancy (CA)

AI Summary

  • Core Issue: A significant deficiency was found in internal controls, specifically regarding board approval for disbursements over $25,000.
  • Impacted Requirements: Compliance with policies requiring board approval for costs to ensure they are authorized and allowable under federal guidelines.
  • Recommended Follow-Up: Management should enhance procedures to ensure all large disbursements receive proper board approval before payment and monitor compliance regularly.

Finding Text

Federal Agency: U.S. Department of the Interior - BOR Federal Program Name: Providing Water to At-Risk Natural Desert Terminal Lakes Assistance Listing Number: 15.508 Federal Award Identification Year: 2025 Pass-Through Agency: National Fish and Wildlife Foundation Award Period: 7/1/19-10/31/25 Compliance Requirement Affected: Allowable Activities & Costs Type of Finding: Significant Deficiency in Internal Control over Compliance and other matters Criteria: The organization’s policies require board approval for disbursements exceeding $25,000 to ensure costs charged to the federal program are properly authorized and allowable in accordance with the award terms and conditions and 2 CFR 200.403. Condition: The auditor tested a sample of 40 disbursements and identified one disbursement of $30,000 that exceeded the approval threshold but did not have the required board approval. Questioned costs: Known- dollar amount determined: $30,000 Context: The population of disbursements subject to the board‑approval requirement consisted of 21 transactions totaling $822,697. Effect: The lack of required approval increases the risk that unallowable or unauthorized costs could be charged to the federal program without appropriate oversight. Cause: Management did not consistently ensure that disbursements exceeding the approval threshold were submitted for and received board approval prior to payment. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that management strengthen procedures to ensure that all disbursements exceeding the board‑approval threshold receive documented approval prior to payment, and that compliance with this requirement is monitored consistently. Management’s Views: See Separate Corrective Action Plan.

Corrective Action Plan

Allowable Activities & Costs – Board approval U.S. Department of the Interior – BOR Providing Water to At-Risk Natural Desert Terminal Lakes – Assistance Listing No. 15.508 Recommendation: We recommend that management strengthen procedures to ensure that all disbursements exceeding the board‑approval threshold receive documented approval prior to payment, and that compliance with this requirement is monitored consistently. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Plan: The finance team has been increased to include a director of finance and an accounting manager position. The position assists in the expansion of separation of duties and increased internal controls. The Conservancy has revised its procurement forms and process to ensure documented approval prior to payment. Name(s) of the contact person(s) responsible for corrective action: Peter Stanton Planned completion date for corrective action plan: October 2025.

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1237647 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.508 Providing Water to At-Risk Natural Desert Terminal Lakes $3.52M
15.237 Rangeland Resource Management $290,478
15.245 Plant Conservation and Restoration Management $169,516
15.808 U.S. Geological Survey Research and Data Collection $108,995
15.246 Threatened and Endangered Species $101,314
15.611 Wildlife Restoration and Basic Hunter Education and Safety $90,959
15.660 Endangered Species - Candidate Conservation Action Funds $88,753
15.554 Cooperative Watershed Management $72,826
15.247 Wildlife Resource Management $48,174
10.724 Sierra Front Wildfire Crisis Strategy Landscape Fuels and Vegetation Management $41,132
15.631 Partners for Fish and Wildlife $29,646
94.006 AmeriCorps State and National $7,086
10.890 Rural Development Cooperative Agreement $1,164
66.640 Nonpoint Source (NPS) 319(h) C9-97908122 $546