Finding Text
2024-001 – Internal Control over Compliance and Compliance with Reporting
Information on the Major Federal Program:
Federal Agency: Department of Interior
Program Name: National Park Service Second Century Endowment and
Appropriation
Assistance Listing Number: 15.U01
Award Number: H.R. 4680/P.L. 114-289
Award Period: October 1, 2023 to September 30, 2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
In accordance with the requirements 2 CFR §1402.300(b), a non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of the Federal Funding and Accountability Act (FFATA), which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170, Reporting Subaward and Executive Compensation Information.
In accordance with 2 CFR Part 170, Appendix A, under FFATA, the Foundation is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System.
Condition – During our testing of reporting, we selected fourteen subrecipient awards. For all samples tested, the Foundation did not comply with the mandatory FFATA report filing requirements.
Transactions Tested
Subaward not reported
Report not timely
Subaward amount incorrect Subaward missing key elements
14
14
14
Not applicable – no report was submitted
Not applicable – no report was submitted
Dollar Amount of Tested 2024 Subawards
Subaward not reported
Report not timely
Subaward amount incorrect Subaward missing key elements
$ 4,984,134 $ 4,984,134 $ 4,984,134 Not applicable – no report was submitted Not applicable – no report was submitted
Cause - The Foundation did not have adequate policies and procedures in place to ensure compliance with the FFATA filing requirements.
Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance and awarding agency taking administrative action.
Questioned Costs – None.
Context - This is a condition identified based upon our review of the Foundation’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these finding is detailed in the condition section above.
Repeat Finding – This is a repeat finding from prior year. This was reported as finding 2023-003 in the 2023 report.
Recommendation – BDO noted management’s actions to address prior year finding, however, the Foundation’s grant agreement do not have a Federal Award Identification Number (FAIN) which is a requirement to file FFATA, management is still unable to file the required FFATA reporting. BDO recommends that the Foundation continue to work with federal grantor/agencies to determine the required information and immediately file the required requirements.
Views of Responsible Officials – The Foundation’s management has been given a legal opinion from counsel that the Appropriation and the Endowment are exempt from Uniform Guidance and the Single Audit. As such, will continue to work with Department of Interior to remedy this situation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.