FAC Explorer

Finding 1238441 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-09-29
Audit: 413311
Organization: The Land Trust Alliance, Inc. and Affiliates (DC)
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: The Land Trust Alliance reported subawards late, missing the FFATA deadline.
  • Impacted Requirements: Compliance with 2 CFR Part 170 for timely reporting of subawards of $30,000 or more to SAM.
  • Recommended Follow-Up: Implement procedures for consistent and timely reporting of subawards to ensure compliance.

Finding Text

Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type Other matters compliance finding and significant deficiency in internal control over compliance. Agency U.S. Department of Agriculture Assistance Listing Numbers 10.676, Forest Legacy Program Criteria As stated in 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the System for Award Management (SAM). The reporting in SAM is required no later than the last day of the month following the month in which the subaward obligation was made. Condition and Context During our audit procedures, we noted that Land Trust Alliance (the Alliance) had entered into three subaward obligations with a value of $57,650 each. Expenses recognized during 2025 under these three subawards were $28,861, $14,413, and $11,433, respectively. The Alliance reported each of these subaward obligations on SAM on June 30, 2026, which was after the deadline required under FFATA. Cause The Alliance’s subaward activities are not a significant component of its federally funded activities. Thus, execution of the required reporting was not fully aligned across the relevant teams, resulting in the late filing of the FFATA reporting. Effect Failure to timely report hinders the grantor’s ability to monitor and administer the program. However, the limited nature of the Alliance’s subaward activities served to mitigate the risk of a material noncompliance related to the major program. Repeat Finding No. Recommendation We recommend that the Alliance implement a procedure to allow for the consistent, timely reporting of subaward obligations of $30,000 or more to the SAM system. Views of Responsible Officials and Planned Corrective Action See attached corrective action plan. Questioned Costs None

Corrective Action Plan

Submitted to: U.S. Department of Agriculture The Land Trust Alliance, Inc. (“the Alliance”) respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: CBIZ CPAs 1899 L Street, NW, Suite 850 Washington, DC 20036 Audit Period: January 1, 2025 through December 31, 2025 The finding from the December 31, 2025 schedule of findings is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING – FEDERAL AWARD PROGRAM AUDIT U.S. Department of Agriculture 2025-001 - Federal Funding Accountability and Transparency Act (FFATA) Reporting – Assistance Listing No. 10.676, Forest Legacy Program Recommendation: The Alliance should implement a procedure to allow for the consistent, timely reporting of subaward obligations of $30,000 or more to the SAM system. Action Taken: The Alliance had already submitted the required reporting in SAM.gov for each of the three subawards on June 30, 2026. Execution of the required reporting was not fully aligned across the relevant teams, resulting in the late filing of the FFATA reporting. As a result of the detection of the misalignment, Management has implemented the following actions: 1. Enhanced federal awards training: The Alliance engaged “Management Concepts”, a third-party firm expert in federal grants management, to deliver a three-day training on federal award compliance requirements back in May 2026. All staff responsible for managing federal awards participated actively in the training. 2. Policy clarification: The Alliance has explicitly incorporated the applicable requirement into its Subaward Management Policy, providing clear and consistent guidance for staff responsible for subaward administration. 3. Strengthened end-to-end process and Standard Operating Procedures (SOP): The Alliance has established and communicated an enhanced process with clearly defined roles, responsibilities, and coordination points across internal teams to support consistent execution of FFATA reporting, when applicable. If the U.S. Department of Agriculture has questions regarding this plan, please contact Ashley Demosthenes at 202-638-4725 or ADemosthenes@lta.org

Categories

Subrecipient Monitoring Reporting Significant Deficiency Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
10.931 AGRICULTURAL CONSERVATION EASEMENT PROGRAM $619,690
10.932 REGIONAL CONSERVATION PARTNERSHIP PROGRAM $544,837
10.676 FOREST LEGACY PROGRAM $392,685
12.017 READINESS AND ENVIRONMENTAL PROTECTION INTEGRATION (REPI) PROGRAM $71,203
10.734 INFLATION REDUCTION ACT - FOREST LEGACY PROGRAM $69,308
81.087 RENEWABLE ENERGY RESEARCH AND DEVELOPMENT $26,046
66.436 SURVEYS, STUDIES, INVESTIGATIONS, DEMONSTRATIONS, AND TRAINING GRANTS AND COOPERATIVE AGREEMENTS - SECTION 104(B)(3) OF THE CLEAN WATER ACT $3,315