Finding Number 2023-003
• Significant deficiency in internal controls over compliance related to procurement.
Federal Agency: U.S. Department of Commerce
Program Title: Pacific Fisheries Data Program
Assistance Listing Number: 11.437
Award Numbers: NOAA-NMFS-AK-2023-2007663
Award Period: October 1, 2022 to September 30, 2027
Criteria
• 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Procurement Standards require that awardees use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward.
Condition/Context for Evaluation
• IPHC's internal controls over procurement do not include the controls and procedures required by 2 CFR 200.
Questioned Costs
• Not applicable.
Cause
• IPHC has not yet modified its procurement policies with the requirements of the 2 CFR Part 200 Procurement Standards.
Effect or Potential Effect
• As a result, IPHC cannot be certain that procurements were conducted in accordance with the 2 CFR Part 200 Procurement Standards.
Repeat Finding
• Not applicable.
Recommendation
• We recommend that IPHC update its procurement policy to include all procurement requirements of 2 CFR Part 200.
- Procurement standards 2 CFR 200 Subpart D or 200.318-200.327
- Requirement for documented policies consistent with standards 200.318(a)
Contact Person(s):
• Executive Director: David Wilson (david.wilson@iphc.int);
• Assistant Director: Andrea Keikkala (andrea.keikkala@iphc.int)
Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable.
Corrective action planned: As this was the IPHC’s first full GAAP Audit, Single Audit of federal grant funds, and also our first year transitioned from a Cash-basis of accounting to an Accrual-basis of accounting, there are a number of policies and procedures that are in the process of being amended. It will take the Secretariat several months to bring our written process guides into alignment with “2 U.S. Code of Federal Regulations (CFR) Part 200”, as well as our Financial Regulations (2021) that will be considered for amendment at the upcoming 100th Session of the IPHC Finance and Administration Committee (FAC100) and subsequent 100th Session of the IPHC Annual Meeting (AM100) in late January 2024.
During the 2nd quarter of FY2024 (1 January – 31 March 2024) the IPHC will undertake a thorough review of “2 U.S. Code of Federal Regulations (CFR) PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS” and update our procurement policies and processes accordingly.
Anticipated completion date: Deadline: 1 April 2024.