Finding 972687 (2021-008)

Material Weakness
Requirement
M
Questioned Costs
-
Year
2021
Accepted
2024-05-09
Audit: 305892
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: CFSC failed to provide essential information to subrecipients at the time of subaward, leading to material non-compliance.
  • Impacted Requirements: Compliance with 2 CFR Part 200.331(a) regarding clear identification and communication of subaward details.
  • Recommended Follow-Up: Revise policies to ensure all required award information is communicated to subrecipients promptly.

Finding Text

Finding 2021-008 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR Part 200.331(a) - Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not identified at the time of subaward for three of the three subawards selected for testing from the Office for Coastal Management: • Federal Award date by the Federal Agency • Whether or not the award was R&D • The indirect cost rate for the Federal Award (including if the de minimus rate is charged) Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: No Effect: CFSC did not identify the required elements of the subaward to the subrecipients at the time of subaward, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 396242 2021-005
    Significant Deficiency
  • 396243 2021-006
    Material Weakness
  • 396244 2021-007
    Material Weakness
  • 396245 2021-008
    Material Weakness
  • 396246 2021-009
    Material Weakness Repeat
  • 396247 2021-010
    Material Weakness Repeat
  • 972684 2021-005
    Significant Deficiency
  • 972685 2021-006
    Material Weakness
  • 972686 2021-007
    Material Weakness
  • 972688 2021-009
    Material Weakness Repeat
  • 972689 2021-010
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.473 Office for Coastal Management $936,822
10.664 Cooperative Forestry Assistance $30,709
15.228 Blm Fuels Management and Community Fire Assistance Program Activities $22,109