November 6, 2023
Response to Findings
Andrew Lubner Paloma Bolasny
Awarding Officer Agreement Technical Representative
National Park Service National Park Service
The National Council for Preservation Education (NCPE) respectfully submits the following response to the finding and corrective action plan for the year ending October 31, 2019.
Hicks and Associates, CPAs
1795 Alysheba Way, Suite 6206
Lexington, KY 40509
Audit Period: November 1, 2018 – October 31, 2019
The findings from the FYE October 31, 2019, schedule of findings and questioned costs are discussed below and include NCPE management responses. The finding is numbered consistently with the number assigned in the schedule.
Finding: Internal Control > Compliance
2019-001 – Eligibility
Recommendation: NCPE should have internal controls in place for the retention of federal program records. NCPE should also have procedures in place to allow for the review of an individual’s eligibility to receive a federal award.
Response: NCPE’s Executive Committee hired a new manager in 2017 to create, track, and retain important records to comply with the terms and conditions of federal agreements. In addition to the application form completed by all interns, an award letter was introduced in 2019. The Award Letter is sent by the National Park Service (NPS) site supervisor to the successful candidate, with NCPE copied, to confirm their appointment and provide essential details about the internship like duration, rate of pay, location, paid time off, etc. This letter with the completed application form documents an intern's eligibility to participate in the program for a specific duration and rate of pay.
For the current audit, applications or resumes were missing for 6 of the interns sampled (of 185 interns total). It was this lack of documentation that resulted in the questioned costs. Requiring a completed application is now standard practice but this wasn’t always the case when students applied directly to a site supervisor and not through the bi-annual application round on PreserveNet (NCPE’s website for preservationists and preservation resources). Site supervisors are aware of the program’s eligibility requirement, however, and management is confident these interns met the criteria for participation in the program. In the future, however, efforts will be intensified to improve record keeping.
If NPS has any questions concerning these responses, please contact me or NCPE’s Treasurer, Doug Appler.
Sincerely,
Julee Johnson
Julee Johnson
Director, Internship Program