Finding Text
2022-006 - Internal Control Over Compliance and Compliance – Reporting
Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis
ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023
Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health
ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023
Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Per grant agreement for major program ALN 81.214, NGA Center is required to prepare and submit progress reports and financial reports (SF-425 Federal Financial Report) on a quarterly basis.
Per grant agreement for major program 93.421, NGA Center is required to prepare and submit progress report (Performance Progress and Monitoring Report) and financial report (SF-425 Federal Financial Report) every year.
Condition – During our reporting requirement testing for major program ALN 81.214, we noted the following:
• For two (2) out of two (2) quarterly financial reports selected for testing, NGA Center was not able to provide the completed and final version of the Federal Financial Report (SF-425) with the submitted date information, thus, BDO was not able to verify the timely submission of the reports. Also, for one (1) of the quarterly SF-425, there was no evidence of submission to the Federal agency.
• For one (1) out of two (2) quarterly progress report selected for testing, NGA Center was unable to provide a copy of the report, including the evidence of submission of the report to the Federal agency.
During our reporting requirement testing for major program ALN 93.421, we noted the following:
• There is no evidence of review and approval for both annual Federal Financial Report and annual Performance Progress and Monitoring Report prior to submission to the Federal agency.
• Also, both annual Federal Financial Report and annual Performance Progress and Monitoring Report were submitted late to the Federal Agency.
Questioned Costs – None.
Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample and with the provisions of the grant agreements.
Cause – Management did not have proper internal controls and policies and procedures in place over the review, approval and submission of the required reporting requirements.
Effect – Without proper internal controls and policies and procedures in place over the review and approval of the required quarterly and annual financial and progress reports, NGA Center was not able to demonstrate compliance to reporting requirements, including submission and review and approval of the reports.
Repeat Finding – This is not a repeat finding.
Recommendation - We recommend that NGA Center strengthen its policies, procedures and controls over the review and approval of the required quarterly and annual financial and progress reports, to ensure compliance with the grant requirements and ensure the amounts reported are accurate. We also recommend that the submitted reports and supporting documentation be maintained for a prescribed period.
Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.