Finding 568218 (2024-003)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-06-27

AI Summary

  • Core Issue: NWIFC did not provide proof of review and approval for progress reports before submission to PSMFC.
  • Impacted Requirements: This violates reporting requirements under 2 CFR Section 200.329 and internal control standards outlined in 2 CFR § 200.303.
  • Recommended Follow-Up: Ensure adherence to reporting policies and maintain documentation for review to mitigate risks and comply with grant requirements.

Finding Text

Program Information: U.S. Department of Commerce NOAA Hatchery Genetic Mgmt – Assistance Listing #11.437 Award Number: NA18NMF4370324 Award Period: 7/01/2018 – 6/30/2024 Criteria: Reporting requirements are contained in the following: Monitoring and reporting program performance, 2 CFR Section 200.329. • Per the award documents, the grantee shall prepare and provide progress reports to Pacific States Marine Fisheries Commission (PSMFC). These run January to June and July to December and are due 15 days after each period. Per 2 CFR § 200.303 Internal controls, the non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: NWIFC could not provide support showing review and approval of the progress reports prior to submitting them to PSMFC. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: It appears the policies and procedures for reporting were not followed. Effect: Failing to comply with the grant award requirements, the program may be subject to higher risk status and a decreased amount of funding. Questioned Costs: Not applicable – The condition relates to the lack of review and approval of the required reports before submitting to the funding agency, which does not directly impact the allowability or support for costs charged to the program. No costs are being questioned as a result. Repeat Finding: No. Recommendation: We recommend that the NWIFC adhere to program policies and procedures as documented and supporting documentation is kept available for review. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Person(s) responsible for corrective action: Todd Bolster, Director of Administration and Dietrich Schmitt, Grants Program Manager. Management’s Response/Corrective Action Plan: For this tribal pass-through program, narrative, non-financial progress reports are collected from tribes, reviewed and approved by the NWIFC Grants Program Manager and submitted to PSFMC. Effective immediately, the NWIFC grants program manager will increase internal controls by including documentation of internal review and approval prior to progress reports being submitted to PSMFC. Anticipated completion date: July 2025.

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 568217 2024-002
    Material Weakness Repeat
  • 1144659 2024-002
    Material Weakness Repeat
  • 1144660 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
15.036 Single Agreement $8.52M
66.121 Psp Epa Fy19-21 Implementation $3.05M
66.121 Psp Epa Fy22-24 Implementation $2.28M
66.121 Psp Epa Capacity $592,301
11.438 Coastal Salmon Recovery $550,676
11.437 Noaa Hatchery Genetic Mgmt $328,316
66.926 General Assistance Program $308,052
66.121 Psp Epa Fy16-18 Implementation $135,385
11.438 Hatchery Reform-Nwifc $89,128
66.608 Twqd/wqx 3.0 Schema $48,750
10.025 Usda Emer Response Training $47,329
15.608 Treaty Indian Catch Monitoring $25,409