Finding 569027 (2024-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-06-30

AI Summary

  • Core Issue: The Organization failed to report subawards over $30,000 as required by FFATA.
  • Impacted Requirements: Noncompliance with federal reporting standards, leading to significant deficiencies in internal controls.
  • Recommended Follow-up: Implement stronger internal controls and policies to ensure compliance with reporting obligations.

Finding Text

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) Criteria: The Federal Funding and Accountability Transparency Act (FFATA) requires recipients who make first-tier subawards that equal or exceed $30,000 in federal funds to report each sub-award to the Federal Funding Accountability and Transparency Act Subaward Reporting System no later than the end of the month following the month in which the subaward was issued. Condition: The Organization did not report subaward activity as required by FFATA. Cause: Management was unaware of this reporting requirement. Questioned Costs: None Effect: The Organization did not comply with FFATA reporting requirements. Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures that include the evaluation of grant terms and conditions to ensure compliance with reporting requirements. Management's Response: See Corrective Action Plan.

Corrective Action Plan

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 Action Taken: FFATA reports were completed in May 2025 for any funds withdrawn for the years 2024 and 2025 and the Trust is awaiting guidance on reporting retroactively for previous years.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

Categories

Subrecipient Monitoring Reporting Significant Deficiency

Other Findings in this Audit

  • 1145469 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
15.623 North American Wetlands Conservation Fund $1.17M