Finding 561181 (2023-003)

2023-003 Surveys, Studies, Investigations, Demonstrations, and Training Grants and Cooperative – Assistance Listing No. 66.436; Grant No.84039801, 84039601,94039501; Grant Period – Year ended December 31, 2023. Statement of Condition: Compliance over subrecipient monitoring. Entity did identify the award and applicable requirements, however entity did not evaluate each subrecipient’s risk of noncompliance nor did it monitor subrecipient activities as listed in the contracts “Subaward Performance Reporting” and monitoring procedures per 2 CFR Sections 200.332 (b) and (d) through (f). Criteria: National Association of Wetland Managers’ internal control policies and procedures, and the Uniform Guidance 2 CFR Sections 200.332 (b) and (d)-(f). Cause: Management’s lack of understanding of criteria. Effect: Non-compliance. Questioned Costs: Not identified. Perspective: N/A. Identification: Non-repeat. Recommendation: Management should review above criteria, and implement required procedures. Views of Responsible Officials: NAWM disagrees with the statement of condition and is submitting documentation for NAWM’s activities regarding monitoring procedures per 2 CFR Sections 200.332 (d) through (f) for Assistance Listing No. 66.436; Grant No. 84039801, 84039601, 94039501; Grant Period – Year ended December 31, 2023. Each grant has its own documentation letter addressing each element listed above in its file submitted. A copy of each subawardee’s NICRA is included in their respective files as well as copies of audit findings for each subawardee. Additionally, each subawardee has been awarded federal grants by the U.S EPA and other federal agencies in the past which they have completed successfully. All of these factors, including the information collected on each subaward contract which contain a lot of the required information, and including a search online of the SAM.gov status of each entity, was used to determine any potential risk of noncompliance and no risk was identified by either NAWM or EPA. Auditors’ Evaluation of Views of Responsible Officials: Management’s Response is in conflict with above Statement of Condition, Criteria, and Cause.