EIN: 202147701
UEI: GSA_MIGRATION
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 13, 2022. 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 March 13, 2023, which was (1257 days ago).
What is a management decision? →Finding 2020-001: Reconciliation of Asset and Liability Accounts/ Delay in Audit Process Federal Programs: All Programs Criteria: As stated in 2 CFR 200.303, the non-Federal entity (i.e. RET Americas) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or in the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: At the commencement of our audit fieldwork, we noted that several asset and liability accounts were not properly reconciled as of September 30, 2020. We also noted some schedules and reconciliations were not available for examination at commencement of audit fieldwork. Due to the above, management spent a substantial amount of time reconciling accounts resulting in an audit delay. Consequently, many adjustments were posted to the preliminary trial balance. Upon further inquiry, it was noted that management does not perform monthly close-out procedures for each account, and thus, some accounts remained unreconciled throughout the duration of the year. We believe this practice could result in unreliable internal financial information, and also represents a deficiency in internal controls. Cause: RET Americas did not have the proper internal controls in place to ensure timely and accurate reconciliation of its asset and liability accounts. Effect or Potential Effect: Without timely and accurate reconciliation of all asset and liability accounts, there exists the potential for undetected errors or misappropriation of funds, as well as internal financial statements that are incomplete, inaccurate and unreliable and delays in the audit process. Questioned Costs: None noted. Context: Asset and liability account reconciliations were not performed adequately and/or on a timely basis. Identification as a Repeat Finding: 2019-001 Recommendation: We recommend that all asset and liability accounts be reconciled on a regular basis (i.e. monthly), as well as before the start of the audit. This process should result in prevention of, or timely detection of, errors, omissions, and misappropriation of funds. We also recommend that these procedures be formalized in writing and incorporated into the accounting policies and procedures manual.
RET fully accepts that it has much work to do to ensure that all balance sheet accounts, not just bank and cash balances, are reconciled monthly. The Accounting Policies and Procedures Manual (FFM) reflects this requirement. In addition, when a project has ended, RET is working to ensure that bank accounts and other balance sheet accounts continue to be reconciled each month until the bank accounts are closed (or the balance is zero), and all balance sheet accounts are zeroed out. The responsible Accounting Officers have been required to fully implement these provisions of the FFM without failure. The management will continue following up on these issues to ensure full compliance.
2019-001
Finding 2020-002: Federal Financial Reporting Federal Programs: All Programs Criteria: Grantor requires that RET Americas submit a quarterly Federal Financial Report (FFR), SF- 425, in accordance with the quarterly schedule indicated in its grant agreement, within 30 days following the end of each calendar quarter. Condition: During our audit, we noted instances where we were unable to agree the numbers within the Federal financial reports submitted to the Federal grantor with the pre-audited numbers reported in RET Americas? financial records. While it appears that the adjusted total expenditures are appropriately stated, cash on-hand and cash disbursements as stated in the Federal financial reports did not agree to RET Americas? preliminary financial records. We also noted several instances where Federal financial reports were not submitted within the deadlines outlined in the grant agreements. Cause: RET Americas did not have the proper internal controls in place around its grants management to ensure timely and accurate Federal financial reports as part of compliance with the Federal regulations. Effect or Potential Effect: RET Americas misreported its Federal activity on its Federal financial reports. Questioned Costs: None noted. Context: Federal financial reports were not prepared adequately and/or submitted on a timely basis. The issue is considered systemic in nature. Identification as a Repeat Finding: 2019-002 Recommendation: We recommend RET Americas implement policies and procedures to ensure that amounts noted in Federal financial reports agree to the figures presented within RET Americas? financial statements. The established policies and procedures should also ensure tracking the progress of the preparation and submission of Federal financial reports throughout the year in order to ensure that they are submitted timely and in accordance with specific grant terms.
RET acknowledges that there were instances in FY2020 when the FFRs submitted did not agree with the expenditure shown in RET America?s financial records. This was caused by the fact that in some cases up-to-date financial records for a particular project were not available by the time the FFR had to be submitted making it necessary to estimate the amount of project expenditure based on the direct project expenditure as per the latest data received from the field, prior to monthly closure of the books.
2019-002
Finding 2020-003: Compliance with U.S. Government Terrorism Requirements Federal Programs: All Programs Criteria: The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 was enacted in order to deter and punish terrorist acts in the United States and around the world and to enhance law enforcement investigatory tools. Executive Order (EO) 13224, which was signed into law during 2001, provides a means by which to disrupt the financial support network for terrorists and related organizations by authorizing the U.S. Treasury, in consultation with other U.S. Government agencies, to designate and block the assets of foreign individuals and entities that commit, or pose a significant risk of committing, acts of terrorism. Condition: During our audit, we noted several cases in which RET Americas did not perform, or did not maintain proper support to demonstrate that it performed, terrorist screening of its contractors, consultants, vendors, employees, etc. in accordance with the above-noted requirements. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. Cause: RET Americas does not have policies and procedures in place with respect to these requirements. Effect or Potential Effect: RET Americas could inadvertently contract with and/or make payments to vendors, consultants, employees and contractors who have been disbarred, suspended or otherwise excluded from receiving Federal funds. Questioned Costs: None noted. Context: RET Americas failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: 2019-003 Recommendation: We recommend RET Americas develop a formal policy with respect to this requirement to ensure screening processes are conducted properly, timely and that the process is properly documented. Furthermore, management should regularly communicate these policies and procedures to all employees, and it should emphasize the importance of maintaining full compliance with U.S. Government ?anti-terrorism? provisions.
RET has in the past overlooked the screening of prospective and incoming employees based on the USA PATRIOT Act of 2001 requirements. This requirement has now been made mandatory not only for external suppliers, but also employees before signing contracts with RET. The requirement that these checks should be carried out on all employees, contractors, consultants, and vendors involved with USG funded projects is already clearly stated in RET operating manuals; there will be additional enforcement going forward to ensure these checks are carried out and filed so they can be expeditiously retrieved when required for audit purposes.
2019-003
Finding 2020-004: Report Submission Federal Programs: All Programs Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, paragraph 512 ?Report submission? states the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Condition: RET Americas did not submit the required documents by the report submission date. Cause: RET Americas did not have internal controls in place around its grants management to properly ensure timely submission of the required documents as part of compliance with the Federal regulations. Effect or Potential Effect: RET Americas was not in compliance with Federal regulations described under 2 CFR 200.512. Questioned Costs: None noted. Context: RET Americas failed to submit the audit, data collection form and reporting package in the time required. RET Americas has a fiscal year end of September 30, 2020, which would require RET Americas to submit all required documents to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's report or by December 31, 2021 (after extension granted). Identification as a Repeat Finding: 2019-004 Recommendation: We recommend RET Americas ensure future compliance with this regulation. It is imperative that RET Americas establish and implement policies and procedures around its year end close, ensuring timely and accurate reporting in a manner which would allow for all required reporting deadlines to be met.
RET acknowledges that it was not able to comply with the key reporting deadline mentioned above. We believe the root cause of the delay is the fact that we do not have timely reconciliations of all balance sheet accounts prepared each month, which is addressed in finding 001 above. As noted above, we are working on this issue by ensuring that all project finance officers as well as those with head office accounting responsibilities are aware of what is required of them, and that there is a system in place to review all reconciliations to ensure that they are accurate and timely.
2019-004
Finding 2020-005: Procurement Federal Programs: All Programs Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, paragraph 318 ?General procurement standards? states that the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards. Furthermore, paragraph 319 ?Competition? states that all procurement transactions must be conducted in a manner providing full and open competition consistent with these standards. Condition: RET Americas does not consistently follow its own internal procurement policy, as we noted multiple instances where it had failed to document its competitive bid process by obtaining quotations. Cause: RET Americas did not adhere to its procurement policy in that it failed to perform the prescribed procurement procedures throughout the fiscal year. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to, and thus, there lies the potential that RET Americas will not receive the best value for its purchases. The procurement process should also allow for an evaluation of potential conflicts of interest with prospective vendors and contractors. Furthermore, failure to perform the proper procurement procedures could result in disallowance of federal expenditures based on lack of fair competition. Questioned Costs: None noted. Context: RET Americas failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: 2019-005 Recommendation: We recommend all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompany the procurement documentation. Without proper procurement documentation, there is a risk that RET Americas will not perform proper evaluation of each element of cost to determine reasonableness. We also believe all long-standing contractual engagements should evidence occasional re-evaluation to ensure such relationships are free of conflicts and are continuing to provide RET Americas with an acceptable standard of service. Lastly, we suggest RET Americas incorporate such provisions into its procurement policies, and communicate such policies to all employees, not only to provide transparency with respect to such transactions, but also to ensure RET Americas are in compliance with specific donor requirements regarding general procurement justification.
RET?s procurement procedures included in its operating manuals were designed to ensure that all donors, including the US government, could be assured that they were getting the best possible value for money. In some cases, owing to the challenging environments in which RET frequently operates, it is impractical to follow every requirement of these procurement policies owing, for example, to a lack of available suppliers in remote locations. In such cases a waiver should be signed by a senior RET official which should be included in the purchase file along with brief details explaining why the standard procedures could not be fully followed. RET notes that this requirement was not always followed and is taking steps to ensure full compliance in the future.
2019-005
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 30, 2021. 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 October 30, 2021, which was (1756 days ago).
What is a management decision? →Finding 2019-001: Reconciliation of Asset and Liability Accounts Federal Programs: CFDA 19.518 Criteria: As stated in 2 CFR 200.303, the non-federal entity (i.e. RET Americas) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or in the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: At the commencement of our audit fieldwork, we noted that several asset and liability accounts were not properly reconciled as of September 30, 2019. As a result, a significant amount of time was spent by management during the audit process reconciling accounts, resulting in audit adjustments, as well as a revised version of the Schedule of Expenditures of Federal Awards (SEFA). Upon further inquiry, it was noted that management does not perform monthly close-out procedures for each account, and thus, some accounts remained unreconciled throughout the duration of the year. We believe this practice could result in unreliable internal financial information, and also represents a deficiency in internal controls.Cause: RET Americas did not have the proper internal controls in place to ensure timely and accurate reconciliation of its asset and liability accounts. Effect or Potential Effect: Without timely and accurate reconciliation of all asset and liability accounts, there exists the potential for undetected errors or misappropriation of funds, as well as internal financial statements that are incomplete, inaccurate and unreliable. Questioned Costs: None noted. Context: Asset and liability account reconciliations were not performed adequately and/or on a timely basis. Identification as a Repeat Finding: Not applicable Recommendation: Accordingly, we recommend that all asset and liability accounts be reconciled on a regular basis (i.e. monthly), as well as before the start of the audit. This process should result in prevention of, or timely detection of, errors, omissions, and misappropriation of funds. We also recommend that these procedures be formalized in writing and incorporated into the accounting policies and procedures manual.
Views of Responsible Officials: RET recognizes the need to reconcile all the assets and liabilities as recommended. It is correct that monthly close-out procedures are currently inadequate, and we intend to improve them. As a matter of internal accounting policy, RET reconciles bank and cash balances monthly. However, this practice is not extended to the rest of the balance sheet items. These will now also be reconciled monthly. The Accounting Policies and Procedures Manual will be updated accordingly.
Finding 2019-002: Federal Financial Reporting Federal Programs: CFDA 19.518 Criteria: Grantor requires that RET Americas submit a quarterly Federal Financial Report (FFR), SF-425, in accordance with the quarterly schedule indicated in its grant agreement, within 30 days following the end of each calendar quarter. Condition: During our audit, we noted instances where we were unable to agree the numbers within the federal financial reports submitted to the Federal grantor with the numbers reported in RET Americas? financial records. While it appears that the total expenditures are appropriately stated, cash on-hand and cash disbursements as stated in the federal financial reports did not agree to RET Americas? financial records. We also noted several instances where federal financial reports were not submitted within the deadlines outlined in the grant agreements. Cause: RET Americas did not have the proper internal controls in place around its grants management to ensure timely and accurate Federal financial reports as part of compliance with the Federal regulations. Effect or Potential Effect: RET Americas misreported its federal activity on its federal financial reports. Questioned Costs: None noted. Context: Federal financial reports were not prepared adequately and/or submitted on a timely basis. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable Recommendation: We recommend RET Americas implement policies and procedures to ensure that amounts noted in Federal financial reports agree to the figures presented within RET Americas? financial statements. The established policies and procedures should also ensure tracking the progress of the preparation and submission of federal financial reports throughout the year in order to ensure that they are submitted timely and in accordance with specific grant terms.
Views of Responsible Officials: It is correct that some FFRs submitted did not agree with the expenditure shown in RET America?s financial records. This was caused by the fact that in some cases up-to-date financial records for a particular project were not available by the time the FFR had to be submitted making it necessary to estimate the amount of project expenditure based on the direct project expenditure as per the data received from the field, prior to monthly closure of the books. As noted, this also resulted in FFRs in some cases being submitted late. Since RET Americas is now enforcing the discipline of routine, on-time, monthly reporting for all projects, we expect this problem to be resolved.
Finding 2019-003: Compliance with U.S. Government Terrorism Requirements Federal Programs: CFDA 19.518 Criteria: The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 was enacted in order to deter and punish terrorist acts in the United States and around the world and to enhance law enforcement investigatory tools. Executive Order (EO) 13224, which was signed into law during 2001, provides a means by which to disrupt the financial support network for terrorists and related organizations by authorizing the U.S. Treasury, in consultation with other U.S. Government agencies, to designate and block the assets of foreign individuals and entities that commit, or pose a significant risk of committing, acts of terrorism. Condition: During our audit, we noted several cases in which RET Americas did not perform, or did not maintain proper support to demonstrate that it performed, terrorist screening of its contractors, consultants, vendors, employees, etc. in accordance with the above-noted requirements. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. Cause: RET Americas does not have policies and procedures in place with respect to these requirements. Effect or Potential Effect: RET Americas could inadvertently contract with and/or make payments to vendors, consultants, employees and contractors who have been disbarred, suspended or otherwise excluded from receiving Federal funds. Questioned Costs: None noted. Context: RET Americas failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable Recommendation: We recommend RET Americas develop a formal policy with respect to this requirement to ensure screening processes are conducted properly, timely and that the process is properly documented. Furthermore, management should regularly communicate these policies and procedures to all employees, and it should emphasize the importance of maintaining full compliance with U.S. Government ?anti-terrorism? provisions.
Views of Responsible Officials: RET Americas has in the past overlooked the screening of prospective and incoming employees based on the USA PATRIOT Act of 2001 requirements. This has now been made mandatory for not only external suppliers, but also employees before signing contracts with RET Americas. The requirement that these checks should be carried out on all employees, contractors, consultants, and vendors involved with USG funded projects is already clearly stated in RET Americas operating manuals; there will be additional enforcement going forward to ensure these checks are carried out and filed so they can be retrieved when required.
Finding 2019-004: Report Submission Federal Programs: CFDA 19.518 Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, paragraph 512 ?Report submission? states the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Condition: RET Americas did not submit the required documents by the report submission date. Cause: RET Americas did not have internal controls in place around its grants management to properly ensure timely submission of the required documents as part of compliance with the Federal regulations. Effect or Potential Effect: RET Americas was not in compliance with federal regulations described under 2 CFR 200.512. Questioned Costs: None noted. Context: RET Americas failed to submit the audit, data collection form and reporting package in the time required. RET Americas has a fiscal year end of September 30, 2019, which would require RET Americas to submit all required documents to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's report or by December 31, 2020 (after extension granted). Identification as a Repeat Finding: Not applicable Recommendation: We recommend RET Americas ensure future compliance with this regulation. It is imperative that RET Americas establish and implement policies and procedures around its year end close, ensuring timely and accurate reporting in a manner which would allow for all required reporting deadlines to be met.
Views of Responsible Officials: RET Americas regrets that it was not able to comply with the key reporting deadline mentioned despite being aware of it and having had an extension occasioned by Covid-19 related hiccups. We have put in place mechanisms to ensure that future reports will be submitted before deadlines. These kinds of delays, partly occasioned by the failure to have reconciliations of assets and liabilities mentioned in points above, have now been addressed and the accounts closures are expected to be smoother. We plan to ensure that our next report for the 12-month period ending 30 September 2020 will be submitted before the deadline of 30 June 2021.
Finding 2019-005: Federal Programs: CFDA 19.518 Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, paragraph 318 ?General procurement standards? states that the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards. Furthermore, paragraph 319 ?Competition? states that all procurement transactions must be conducted in a manner providing full and open competition consistent with these standards. Condition: RET Americas does not consistently follow its own internal procurement policy, as we noted multiple instances where it had failed to document its competitive bid process by obtaining quotations. Cause: RET Americas did not adhere to its procurement policy in that it failed to perform the prescribed procurement procedures throughout the fiscal year. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to, and thus, there lies the potential that RET Americas will not receive the best value for its purchases. The procurement process should also allow for an evaluation of potential conflicts of interest with prospective vendors and contractors. Furthermore, failure to perform the proper procurement procedures could result in disallowance of federal expenditures based on lack of fair competition. Questioned Costs: None noted. Context: RET Americas failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable Recommendation: We recommend all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompany the procurement documentation. Without proper procurement documentation, there is a risk that RET Americas will not perform proper evaluation of each element of cost to determine reasonableness. We also believe all long-standing contractual engagements should evidence occasional re-evaluation to ensure such relationships are free of conflicts and are continuing to provide RET Americas with an acceptable standard of service. Lastly, we suggest RET Americas incorporate such provisions into its procurement policies, and communicate such policies to all employees, not only to provide transparency with respect to such transactions, but also to ensure RET Americas are in compliance with specific donor requirements regarding general procurement justification.
Views of Responsible Officials: RET Americas took great pains to ensure that the procurement procedures included in its operating manuals would ensure that all donors, including the US government, could be assured that they were getting the best possible value for money. In some cases, owing to the challenging environments in which RET Americas necessarily operates, it was impractical to follow every requirement of these procurement policies owing, for example, to a lack of available suppliers. In these cases, we expect and require a waiver, signed by a senior RET Americas official, to be included in the purchase file providing brief details of why the policies could not be fully followed. This requirement will be strictly followed in such instances.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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