Finding 2024-001: North American Wetlands Conservation Fund
Assistance Listing Number: 15.623
U.S. Department of Interior
Pass-through: N/A
Compliance Requirement: Reporting
Grant No.: N/A
Type of finding: Internal Control Over Compliance (significant deficiency) and Compliance (noncompliance)
Recommendation: The Organization should strengthen its internal with adopted policies and procedures that include evaluation of grant terms and conditions to ensure compliance with reporting requirements.
Action Taken: FFATA reports were completed in May 2025 for any funds withdrawn for the years 2024 and 2025 and the Trust is awaiting guidance on reporting retroactively for previous years. Rio Grande Headwaters Land Trust added a step to our ASAP.gov withdrawal instructions: Ensure to file a FFATA report on Sam.gov immediately if the funds drawn down are pass through (or schedule a reminder on your calendar for prior to the end of the next calendar month). The Executive Director is now the sole grant reviewer and signer on grant agreements, as well as the only ASAP.gov and SAM.gov admin which will allow the Land Trust to ensure compliance with reporting requirements in the future.
If there are questions regarding this plan, please call the responsible party listed below.
Sincerely yours,
Laura Cusick
Executive Director
Rio Grande Headwaters Land Trust