Finding 569036 (2024-002)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-06-30
Audit: 360694
Organization: Galveston Bay Foundation, Inc. (TX)

AI Summary

  • Core Issue: Required information was missing from the subrecipient agreement, violating federal guidelines.
  • Impacted Requirements: Compliance with OMB 2 CFR §200.331(a) regarding necessary details for subawards.
  • Recommended Follow-Up: Implement policies to ensure all required information is included in future subrecipient agreements.

Finding Text

Finding #2024-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Environmental Protection Agency, Assistance Listing #66.456, National Estuary program, Passed through Texas Commission on Environmental Quality: Contract period: 09/01/23 – 08/31/25, Contract number: 582-24-50165. Criteria: In accordance with Uniform Guidance OMB 2 CFR §200.331(a), pass through entities must provide subrecipients with specific information at the time of the subaward, including the assistance listing number, federal award identification number (FAIN), name of the federal awarding agency, pass through entity and contact information for awarding official, federal award date of award to the recipient by the Federal agency, access to subrecipient’s records and retention period, and a statement regarding the close-out terms and conditions. Condition and context: We reviewed one of the two subrecipient awards for the required information described in the criteria above and noted such provisions were not included in the subrecipient agreement. Effect: Failure to communicate required information may result in subrecipients not properly complying with federal requirements, increasing the risk of noncompliance. Recommendation: Policies and procedures should be implemented to ensure all required information is included in the subrecipient agreement before issuance. View of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Finding #2024-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Environmental Protection Agency, Assistance Listing #66.456, National Estuary program, Passed through Texas Commission on Environmental Quality: Contract period: 09/01/23 – 08/31/25, Contract number: 582-24-50165. Condition and context: We reviewed one of the two subrecipient awards for the required information described in the criteria above and noted such provisions were not included in the subrecipient agreement. Recommendation: Policies and procedures should be implemented to ensure all required information is included in the subrecipient agreement before issuance. Planned corrective action: Management agrees with the finding and would like to provide additional context to this situation. This agreement occurred during the early implementation phase of a multi-year grant in 2023, when the Foundation was still establishing internal processes for managing subawards under federal funding requirements. At the time of this transaction: The federal award had not yet been formally executed, though the federal agency provided authorization to begin incurring expenses. The subrecipient, a partner organization, drafted and issued the agreement using their standard contract template. Since that time, the Foundation has updated its procedures for subsequent subrecipient agreements to include the required Uniform Guidance information as outlined in 2 CFR §200.331(a). This was an isolated incident during a transitional period, and management is confident that current processes address this issue. To prevent recurrence, the Foundation will: Continue to follow updated subrecipient agreement templates, which include all required award and federal compliance language. Provide refresher training to staff involved in grant and contract administration on subrecipient vs. vendor classifications and associated federal requirements. Perform an annual compliance review of all subrecipient agreements to ensure ongoing adherence. Responsible officer: Dawn Asbury, Controller. Estimated completion date: July 31, 2025.

Categories

Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 569035 2024-001
    Significant Deficiency
  • 569037 2024-001
    Significant Deficiency
  • 569038 2024-001
    Significant Deficiency
  • 569039 2024-001
    Significant Deficiency
  • 1145477 2024-001
    Significant Deficiency
  • 1145478 2024-002
    Significant Deficiency
  • 1145479 2024-001
    Significant Deficiency
  • 1145480 2024-001
    Significant Deficiency
  • 1145481 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
11.463 Habitat Conservation $125,192
66.130 Geographic Programs - Gulf Coast Ecosystem Restoration Council Comprehensive Plan Component $99,967
11.419 Coastal Zone Management Administration Awards $56,006
11.U01 Mmc Skin Lesions Workshop $31,589
66.475 Geographic Programs – Gulf of Mexico Program $16,378
15.630 Coastal $14,000
20.219 Recreational Trails Program $11,916
66.306 Environmental Justice Collaborative Problem-Solving Cooperative Agreement Program $7,335
11.451 Gulf Coast Ecosystem Restoration Science, Observation, Monitoring, and Technology $7,183
11.473 Office for Coastal Management $6,669
15.658 Natural Resource Damage Assessment and Restoration $6,595
15.623 North American Wetlands Conservation Fund $5,051
66.951 Environmental Education Grants Program $5,000
15.614 Coastal Wetlands Planning, Protection and Restoration $4,618
66.456 National Estuary Program $3,443
11.999 Marine Debris Program $935