EIN: 061648104
UEI: FMCZPHD6AF58
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 19, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 19, 2025 (430 days ago).
What is a management decision? →In a cost reimbursement award, only costs incurred are allowed to be billed for reimbursement. NMLC billed for certain payroll tax costs that were not incurred. Context: Audit procedures identified multiple instances where payroll taxes were billed, even though those payroll taxes are limited to earned income thresholds. Cause: The employer portion of payroll taxes are billed as a flat fifteen percent above gross wages which does not consider certain payroll taxes that are limited to certain thresholds based on the individuals cumulative earned income. For example, federal and state unemployment taxes. Effect: NMLC overbilled for certain payroll taxes that were not incurred. Recommendation: NMLC should implement procedures to allow for tracking of actual payroll taxes incurred for labor charged to the award ensuring that only costs incurred are billed. Planned Corrective Action: We agree with this finding and will create and implement additional internal controls to allow for tracking of actual payroll taxes incurred for labor charged to the award ensuring that only costs incurred are billed. Anticipated Completion Date: January 31, 2025. Responsible Contact Person: Megan Keller, Director of Finance and Operations
Show full finding ▾Hide full finding ▴Criteria and Condition: In a cost reimbursement award, only costs incurred are allowed to be billed for reimbursement. NMLC billed for certain payroll tax costs that were not incurred. Context: Audit procedures identified multiple instances where payroll taxes were billed, even though those payroll taxes are limited to earned income thresholds. Cause: The employer portion of payroll taxes are billed as a flat fifteen percent above gross wages which does not consider certain payroll taxes that are limited to certain thresholds based on the individuals cumulative earned income. For example, federal and state unemployment taxes. Effect: NMLC overbilled for certain payroll taxes that were not incurred. Recommendation: NMLC should implement procedures to allow for tracking of actual payroll taxes incurred for labor charged to the award ensuring that only costs incurred are billed. Planned Corrective Action: We agree with this finding and will create and implement additional internal controls to allow for tracking of actual payroll taxes incurred for labor charged to the award ensuring that only costs incurred are billed. Anticipated Completion Date: January 31, 2025. Responsible Contact Person: Megan Keller, Director of Finance and Operations
Planned Corrective Action: We agree with this finding and will create and implement additional internal controls to allow for tracking of actual payroll taxes incurred for labor charged to the award ensuring that only costs incurred are billed. Anticipated Completion Date: January 31, 2025. Responsible Contact Person: Megan Keller, Director of Finance and Operations
FAC accepted this audit on March 24, 2021 — management decision was due September 24, 2021.
Under accounting principles generally accepted in the United States of America (GAAP), revenue from landowner easement projects should be recognized at a time when those services are provided by NMLC. Context: Audit procedures identified instances where revenue from landowner easement projects was recognized in full upon commencement of the project rather than as services provided. Cause: NMLC was following professional guidance surrounding revenue recognition that was not in accordance with GAAP, which caused revenue to be recognized in advance of services being performed. Effect: A material audit adjustment to correctly state revenue for 2019 and 2020 was posted. Questioned Costs: This finding does not result in questioned costs. Recommendation: Appropriate written policies and procedures should be established to ensure proper revenue recognition under GAAP
Show full finding ▾Hide full finding ▴2020-001: Revenue Recognition Criteria and Condition: Under accounting principles generally accepted in the United States of America (GAAP), revenue from landowner easement projects should be recognized at a time when those services are provided by NMLC. Context: Audit procedures identified instances where revenue from landowner easement projects was recognized in full upon commencement of the project rather than as services provided. Cause: NMLC was following professional guidance surrounding revenue recognition that was not in accordance with GAAP, which caused revenue to be recognized in advance of services being performed. Effect: A material audit adjustment to correctly state revenue for 2019 and 2020 was posted. Questioned Costs: This finding does not result in questioned costs. Recommendation: Appropriate written policies and procedures should be established to ensure proper revenue recognition under GAAP
Views of Responsible Officials and Planned Corrective Actions: We disagree with certain aspects of this finding. We do not believe that it is fair to characterize the way in which we have been recognizing and classifying landowner contributions as a lack of understanding on our part of accepted revenue recognition criteria. Believing that it was consistent with standard practices for accrual accounting, our previous auditor viewed the landowner contributions as ?promises to give? or pledges and advised us to book them as revenue at the time we signed an agreement or letter of intent with the landowner. Pulakos, CPA takes a different view of these contributions, viewing them more as a fee for service. Based on that view, they have decided that we were recognizing the revenue incorrectly and have advised us to recognize it only once we have completed the project milestones per our agreements with the landowners. It is common in the land trust community to book these contributions both ways. We have agreed to change the timing of revenue recognition to that of recognizing it after the agreement is complete and will implement this practice for future revenue recognition.
For the year ending June 30, 2020, NMLC did not have a written procurement policy to properly implement all the requirements of 2 CFR section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In accordance with these requirements, non-federal entities must have written procedures for procurement transactions. Such policy should incorporate all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Context: While audit procedures did not identify any instances of inappropriate procurement activity, there were no policies in place to govern procurement related matters. Cause: NMLC does not have a written procurement policy in place that incorporates all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Effect: Non-compliance with the Uniform Guidance could jeopardize future federal funding. Questioned Costs: This finding does not result in questioned costs. Recommendation: NMLC should implement a procurement policy that incorporates all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance.
Show full finding ▾Hide full finding ▴2020-002: Procurement ? Community Economic Adjustment Assistance for Compatible Use and Land Use Studies (CFDA # 12.610) Criteria and Condition: For the year ending June 30, 2020, NMLC did not have a written procurement policy to properly implement all the requirements of 2 CFR section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In accordance with these requirements, non-federal entities must have written procedures for procurement transactions. Such policy should incorporate all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Context: While audit procedures did not identify any instances of inappropriate procurement activity, there were no policies in place to govern procurement related matters. Cause: NMLC does not have a written procurement policy in place that incorporates all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Effect: Non-compliance with the Uniform Guidance could jeopardize future federal funding. Questioned Costs: This finding does not result in questioned costs. Recommendation: NMLC should implement a procurement policy that incorporates all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions: NMLC agrees and will implement a procurement policy.
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