Finding Text
MW 2024‐001 REPORTING
United States Environmental Protection Agency
ALN 66.456 – National Estuary Program
Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923
2024 Funding
Criteria: Per 2 CFR 200.303, non‐Federal entities must establish and maintain effective internal
controls to provide reasonable assurance of compliance with the Uniform Guidance and the terms
and conditions outlined by the Environmental Protection Agency. EPA recipients must submit the
Federal Financial Report (SF‐425) at least annually. EPA recipients must submit the SF‐425 no later
than 90 calendar days for annual reports. Final reports are due no later than 120 calendar days after
the end date of the period of performance of the award.
Condition: The Federal Financial Report Standard Form 425 was submitted late to the Environmental
Protection Agency on March 10, 2025.
Cause: The Environmental Protection Agency had informed the Council that these reports were only
due at closeout of the grant; therefore, the Council did not submit these reports. However, the Office
of Inspector General (OIG) stated that this was not the correct procedure. As a result of the OIG's EPA
audit, the Council filed these reports on March 10, 2025 with the EPA to be in compliance.
Effect: Potential for unintended errors to occur without being immediately identified and corrected.
The Council was not in compliance with the Uniform Guidance and the National Estuary Program.
Questioned Costs: None.
Perspective: All of the reports identified above were not reviewed.
Recommendation: The Chief Operating Officer should obtain in writing any adjustments or
clarifications to the grant awards to ensure the requested reports are prepared and reviewed.
Management Response: EPA has never requested the SF425 (Federal Financial Reporting Form) from
year’s prior and we were told verbally that we were only required to submit them at grant closeout.
During a current EPA OIG audit, we were informed that the procedural process we were following
was incorrect and that yearly reports were required to be submitted. To bring the IRL Council back
into compliance with all federal awards, the Chief Operating Officer completed the FY 2024 forms
and submitted them to EPA on March 10, 2025.