Finding Text
2023-004 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: Internal control weakness over subrecipient monitoring. Ineffective control procedures over subrecipient monitoring.
Criteria: National Association of Wetland Managers’ internal control policies and procedures and the Uniform Guidance.
Cause: Oversight
Effect: Increased risk of noncompliance.
Questioned Costs: Not identified.
Perspective: N/A.
Identification: Non-repeat.
Recommendation: Management should review above criteria, and modify control or perform control procedures.
Views of Responsible Officials: NAWM has draft sub recipient monitoring documents available that were drafted in 2021 in anticipation of having subawardees for the grants awarded in 2022. However, as has been explained to Ron Beaulieu, we did not finalize them because our EPA project officer assured NAWM in a phone conversation that our project partners were not technically considered sub awardees and therefore were not subject to OMB sub award policies. It is clear now that NAWM was given incorrect information. The draft documents are in the submitted files. NAWM has already started to finalize those policies and procedures now that we have the corrected information regarding subawardee status.
NAWM’s standard operating procedures for monitoring progress and activities related to each grant on our grants include regular meetings, frequent communications with our Project Officer, and submission of quarterly progress reports. For the awards with subawardees, they were active participants in all of these activities. Specific activities to monitor project progress include:
• Monthly calls with whole project team (NAWM, subawardee, project officer)
• Monthly calls with project advisory committee (including project team)
• NAWM is in continual contact with subawardees and project officer. During regular meetings we discuss project progress and status of each project component, and take notes to document our discussion.
• Progress reports are required with each invoice submitted by each subawardee, examples of which are included in each subawardee folder.
• NAWM also submits quarterly progress reports on each grant to EPA.
Auditors’ Evaluation of Views of Responsible Officials: We agree that NAWM should finalize
subrecipient policies and procedures. NAWM should also implement these policies immediately. However, the specific activities listed in the second paragraph of management’s response are in conflict with above Statement of Condition. Those activities address project progress, not NAWM’s internal control procedures over subrecipient compliance.