FAC Explorer

Finding 1238981 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 413839
Organization: SUSTAINABLE FORESTRY INITIATIVE AND AFFILIATE (DC)
Auditor: CLIFTONLARSONALLEN LLP

AI Summary

  • Core Issue: The Sustainable Forestry Initiative failed to submit required FFATA reports for first-tier subawards of $30,000 or more, leading to noncompliance with federal reporting requirements.
  • Impacted Requirements: Compliance with the Federal Funding Accountability and Transparency Act (FFATA) and 2 CFR Part 170, which mandate timely reporting of subawards through SAM.gov.
  • Recommended Follow-Up: Strengthen internal controls by establishing written policies, assigning responsibilities, maintaining a tracking log, implementing a review process, and conducting periodic reconciliations.

Finding Text

Federal Agency: Department of Agriculture Federal Program Name: Urban and Community Forest Improvement Program-Inflation Reduction Act Assistance Listing Number: 10.727 Award Period: February 15, 2024 – December 31, 2028 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Federal Funding Accountability and Transparency Act (FFATA) and 2 CFR Part 170 require recipients of federal awards to report information regarding first-tier subawards meeting applicable reporting thresholds within the prescribed reporting period through SAM.gov. Condition: During our testing of FFATA reporting requirements, we noted that Sustainable Forestry Initiative did not submit required FFATA reports for all first-tier subawards of $30,000 or more in SAM.gov. Questioned costs: None Context: FFATA reporting was not submitted in SAM.gov. Cause: Management did not maintain adequate internal controls to ensure that all reportable first-tier subawards were identified, monitored, and reported timely in SAM.gov. Specifically, responsibilities for FFATA reporting were not formally assigned, and there was no secondary review process to verify compliance with reporting deadlines. Effect: Failure to submit timely and accurate FFATA reports resulted in noncompliance with federal reporting requirements and reduced transparency regarding the expenditure of federal funds. Required information concerning subaward recipients was not available through the federal reporting system within the timeframe established by FFATA. Repeat Finding: No Recommendation: We recommend that management strengthen internal controls over FFATA compliance by: 1. Establishing written policies and procedures governing FFATA reporting requirements. 2. Assigning responsibility for identifying reportable subawards and submitting reports. 3. Maintaining a tracking log of all subawards subject to FFATA reporting. 4. Implementing a supervisory review process to verify submission of all required reports within prescribed deadlines. 5. Performing periodic reconciliations between subaward records and information reported through SAM.gov. Views of responsible officials: Management concurs with the finding. Management will implement formal procedures for identifying and tracking FFATA-reportable subawards, designate responsible personnel for filing required reports, and establish a supervisory review process to ensure reports are submitted completely and timely. Management has taken corrective action prior to the finalization of the audit.

Corrective Action Plan

Federal Program: Urban and Community Forest Improvement Program – Inflation Reduction Act Assistance Listing Number: 10.727 Federal Agency: U.S. Department of Agriculture Name of Contact Person Responsible for Corrective Action: Samory Ligondé, Controller Management Response: Management concurs with the finding and recognizes the importance of timely and complete reporting under the Federal Funding Accountability and Transparency Act (FFATA) and 2 CFR Part 170. The Organization maintains written policies addressing federal award administration, including applicable FFATA reporting requirements. In response to the matters identified during the audit, management has strengthened the procedures and controls supporting implementation of these requirements. Responsibility for identifying subawards subject to FFATA reporting has been assigned jointly to the Controller and the applicable program lead responsible for administration of the federal award. This approach is intended to combine centralized financial and compliance oversight with the program-level knowledge necessary to identify reportable subaward activity; however, the Controller is ultimately responsible for coordinating and ensuring completion of the required federal FFATA reporting. Management has reviewed the subawards associated with the major federal program audited and has submitted all previously outstanding FFATA reports identified through that review. In addition, management has implemented a supervisory review process to verify that required FFATA reports are submitted within prescribed deadlines. As part of this process, finance staff, in coordination with the applicable program lead, will periodically reconcile the organization’s subaward agreements and related records to FFATA information reflected in SAM.gov. Lastly, Management will also maintain appropriate documentation of reportable subawards and completed submissions to support ongoing monitoring and supervisory review. Management believes these actions, which were completed by the end of the audit process, appropriately address the matters identified in the finding and strengthen the organization’s existing controls over FFATA compliance.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting Significant Deficiency Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
10.727 INFLATION REDUCTION ACT URBAN & COMMUNITY FORESTRY PROGRAM $554,251
10.731 INFLATION REDUCTION ACT LANDSCAPE SCALE RESTORATION $237,222
10.912 ENVIRONMENTAL QUALITY INCENTIVES PROGRAM $99,141
10.732 BIPARTISAN INFRASTRUCTURE LAW STATE, PRIVATE & TRIBAL AGREEMENTS $77,081
66.950 NATIONAL ENVIRONMENTAL EDUCATION TRAINING PROGRAM $67,034
10.674 WOOD UTILIZATION ASSISTANCE $38,943
10.684 INTERNATIONAL FORESTRY PROGRAMS $10,810
43.001 SCIENCE $4,499