EIN: 237391796
UEI: T2B7XG7JGRM6
Audited by: Baker Tilly US, LLP
Oversight agency: 81 [Department of Energy]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. 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 September 30, 2026 (32 days from today).
What is a management decision? →During our testing of the internal controls over compliance and compliance with procurement, suspension and debarment compliance requirements, we identified one procurement agreement out of a total of three tested where the Organization did not have documented controls over the application of their procurement policy. Additionally, the Organization did not retain documentation of controls over their verification that the vendor contracted was not suspended or debarred prior to entering into the contract. Management has subsequently determined that the vendor was not suspended or debarred. Questioned Costs: None. Context: The population consisted of three vendor charges or contracts entered into during the period that exceeded the Organization's micro-purchase policy. Three of the items were tested, two of which had no exceptions in testing and the other had the exceptions identified in the condition above. The one exception was paid $31,661 from the award. Cause: NGAC's personnel did not adhere to NGAC's documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a covered transaction and did not retain proper documentation supporting procurement controls and compliance. Effect: Failure to obtain and retain sufficient supporting documentation could result in an incorrect application of procurement policies and procedures. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This finding was identified during the year ending June 30, 2024 as finding 2024-002. Recommendation: We recommend management ensure that procurement and suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Management's Response: NGA management agrees with the finding and recommendations presented by Baker Tilly auditors and has developed a corrective action plan in response.
Show full finding ▾Hide full finding ▴Agency: U.S. Department of Health and Human Services Federal Assistance Listing Number: 93.528, National Forum for State and Territorial Chief Executives HHS OA, Yr 10 and Yr 11, National Forum Contract Number: 2U98OA09028 Criteria: In accordance with 2 CFR §200.318(a), General Procurement Standards, the nonfederal 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 identified in General Procurement Standards. Additionally, §200.318(i) states that the nonfederal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection and the basis for the contract price. In accordance with §200.213 and §180.300, Suspension and Debarment, nonfederal entities cannot enter into awards, subawards or contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a nonfederal entity. In addition, in accordance with §180.415(b), nonfederal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person or under which an excluded person is a principal, unless the nonfederal entity obtains an exception under §180.135. Condition: During our testing of the internal controls over compliance and compliance with procurement, suspension and debarment compliance requirements, we identified one procurement agreement out of a total of three tested where the Organization did not have documented controls over the application of their procurement policy. Additionally, the Organization did not retain documentation of controls over their verification that the vendor contracted was not suspended or debarred prior to entering into the contract. Management has subsequently determined that the vendor was not suspended or debarred. Questioned Costs: None. Context: The population consisted of three vendor charges or contracts entered into during the period that exceeded the Organization's micro-purchase policy. Three of the items were tested, two of which had no exceptions in testing and the other had the exceptions identified in the condition above. The one exception was paid $31,661 from the award. Cause: NGAC's personnel did not adhere to NGAC's documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a covered transaction and did not retain proper documentation supporting procurement controls and compliance. Effect: Failure to obtain and retain sufficient supporting documentation could result in an incorrect application of procurement policies and procedures. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This finding was identified during the year ending June 30, 2024 as finding 2024-002. Recommendation: We recommend management ensure that procurement and suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Management's Response: NGA management agrees with the finding and recommendations presented by Baker Tilly auditors and has developed a corrective action plan in response.
Jordan Kramer Chief Financial Officer 202-624-7787 January 2024 Management's Corrective Action Plan: NGA has previously developed and communicated our procurement processes and procedures to all staff members. We will provide additional training for employees involved in sourcing decisions during meetings, focusing on the accurate documentation of decision-making processes. In response to this finding, NGA will review the vendor selection processes for events over the past six months to ensure appropriate documentation is captured in the finance system. Ongoing training will be provided to new program staff regarding procurement documentation requirements to maintain compliance with established policies. When circumstances necessitate working with a specific entity or time constraints preclude a competitive process, program leaders and finance will collaborate to produce a memorandum detailing the work’s unique requirements and the criteria underlying vendor selection. Additionally, the CFO will coordinate with management to notify supervisors when procedures are not followed and to pursue corrective actions, ensuring all individuals complete the necessary compliance steps. The NGA Management Team deeply values the partnership with its Baker Tilly auditors as we address these concerns. Your expertise and guidance are crucial to our improvement process. Please ask any questions or provide feedback on management's action plans.
2024-002
FAC accepted this audit on March 21, 2025 — management decision was due September 21, 2025.
During our testing of the procurement, suspension and debarment compliance requirements, we identified one procurement sample out of a total of two tested where the Organization did not have documented controls over the application of their procurement policy. Additionally, the Organization did not retain documentation of controls over their verification that the vendor contracted was not suspended or debarred prior to entering into contract with the vendor. Management has subsequently determined that the vendor was not suspended or debarred. Questioned Costs: None. Context: The population consisted of two vendor contracts entered into during the period subject to procurement. Both items were tested, one of which had no exceptions in testing and the other had the exceptions identified in the condition above. Cause: NGA Center's personnel did not adhere to NGA Center's documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a covered transaction and did not retain proper documentation supporting procurement controls.
Show full finding ▾Hide full finding ▴Criteria: In accordance with 2 CFR §200.318(a), General Procurement Standards, 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 identified in General Procurement Standards. Additionally, §200.318(i) states that the nonfederal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Nonfederal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified one procurement sample out of a total of two tested where the Organization did not have documented controls over the application of their procurement policy. Additionally, the Organization did not retain documentation of controls over their verification that the vendor contracted was not suspended or debarred prior to entering into contract with the vendor. Management has subsequently determined that the vendor was not suspended or debarred. Questioned Costs: None. Context: The population consisted of two vendor contracts entered into during the period subject to procurement. Both items were tested, one of which had no exceptions in testing and the other had the exceptions identified in the condition above. Cause: NGA Center's personnel did not adhere to NGA Center's documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a covered transaction and did not retain proper documentation supporting procurement controls.
NGA had previously developed and socialized our procurement process and procedure with our staff members. In response to this finding, NGA will continue to train program staff on the documentation requirements regarding procurement decisions required to comply with our established policy. We will continue to review new contract requests carefully to ensure that all the necessary compliance documentation is captured and easily accessible to auditors in the future. Also, in cases where circumstances require that NGA work with a specific entity, we work with program leaders to produce a memo to file highlighting the particular requirements of the work and decision criteria that lead to our selection of individual vendors. The CFO will also work with management to inform supervisors when procedures are not followed. They may follow up with individuals who have not completed the compliance requirements or steps.
2023-006
FAC accepted this audit on June 26, 2024 — management decision was due December 26, 2024.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 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 – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 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 – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: December 2024 Management’s Corrective Action Plan NGA has begun to produce quarterly versions of the Statement of Federal Awards (SEFA). This routine process has enabled staff to proactively identify new awards and lapsed agreements to keep the SEFA current. Given the importance of this schedule to NGA’s continued management of federal funds, we have emphasized and trained staff to follow all applicable federal requirements when managing funds on this schedule. We expect our action plan to continue until December 2024 as we have encountered several issues this fiscal year that required reconciliation of prior years.
2023-006 - Internal Control Over Compliance and Compliance – Procurement, Suspension and Debarment Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Criteria - In accordance with 2 CFR §200.318(a), General Procurement Standards, 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 identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition – During our testing of the procurement, suspension and debarment compliance requirements, we identified one procurement sample out of a total of two procurement samples tested wherein management was unable to provide evidence that the suspension and debarment check was performed prior to entering into contract with the vendor. Management has subsequently determined that the vendor was not suspended or debarred. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center’s personnel did not adhere to NGA Center’s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a covered transaction. Effect – Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering a contract with an entity that is barred from performing work for the Federal government. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. 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.
Show full finding ▾Hide full finding ▴2023-006 - Internal Control Over Compliance and Compliance – Procurement, Suspension and Debarment Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Criteria - In accordance with 2 CFR §200.318(a), General Procurement Standards, 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 identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition – During our testing of the procurement, suspension and debarment compliance requirements, we identified one procurement sample out of a total of two procurement samples tested wherein management was unable to provide evidence that the suspension and debarment check was performed prior to entering into contract with the vendor. Management has subsequently determined that the vendor was not suspended or debarred. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center’s personnel did not adhere to NGA Center’s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a covered transaction. Effect – Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering a contract with an entity that is barred from performing work for the Federal government. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. 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.
2023-006 - Internal Control Over Compliance and Compliance – Procurement, Suspension and Debarment Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: July 2024 Management’s Corrective Action Plan NGA has always mandated that all vendors paid using federal funds be checked on SAM.gov for debarment or other issues. NGA believes this finding reflects a single isolated incident in which this check was completed, but records were not saved as a PDF within our vendor records. NGA has reiterated and retrained staff on the importance of documentation retention and ensuring that accounting staff consistently retrain these records. NGA expects this issue to have been fully addressed as of July 2024.
2023-007 – Data Collection Form and Single Audit Reporting Package Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 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 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition – NGA Center did not comply with the required submission date of the data collection form and reporting package to the FAC for the year ended June 30, 2023. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Effect – NGA Center could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that management closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴2023-007 – Data Collection Form and Single Audit Reporting Package Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 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 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition – NGA Center did not comply with the required submission date of the data collection form and reporting package to the FAC for the year ended June 30, 2023. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Effect – NGA Center could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that management closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-007 – Data Collection Form and Single Audit Reporting Package Data Collection Form and Single Audit Contact: Alice Bernardi Title: Controller Phone Number: 202-624-5347 Anticipated Completion Date: February 2025 Management’s Corrective Action Plan NGA Management has determined that our business needs and federal requirements mandate the routine completion of our audit before the first week in February. Over the past two years, delays have been encountered primarily due to the timing of NGA's pre-audit and fieldwork assignments. Timely completion of the audit process is a shared responsibility with our audit partners. We have observed that some topics related to NGA's business model require extensive back and forth, and we will seek to develop documentation that can be used as a resource for orienting new auditors on our projects to avoid time-consuming, repetitive conversations. To ensure adherence to this critical timeline, NGA will initiate its pre-audit and fieldwork assignments at least two months earlier than in the past two years. NGA will adjust next year's audit schedule accordingly, with the expectation that this revised timeline will be fully implemented for our fiscal year 2024 audit, which will be completed in February 2025.
FAC accepted this audit on October 27, 2023 — management decision was due April 27, 2024.
2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles 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 2 CFR Section 200.430 Compensation – Personal Services: “Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.” 2 CFR Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. 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.
Show full finding ▾Hide full finding ▴2022-004 – Internal Control Over Compliance and Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles 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 2 CFR Section 200.430 Compensation – Personal Services: “Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.” 2 CFR Section 200.430(i): “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition – During our payroll disbursement testing for major program ALN 81.214, we noted that for one (1) out of eight (8) samples for testing, there was no proper review on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. During our payroll disbursement testing for major program ALN 93.421, forty (40) samples were selected for testing. We noted the following: • For two (2) samples, the project codes used to record the payroll expense in the general ledger were not the same as the project codes entered by the employees in the timesheets. • For one (1) sample, the project code used to record the payroll expense in the general ledger was not found in the timesheet. • For one (1) sample, the hours used to record payroll expense in the general ledger did not agree with the hours entered by the employee in the timesheet. • For one (1) sample, there were two different salary rates used for regular hours worked by the employee. • For six (6) samples, there was no proper review process on the calculation of compensated absences and fringe benefits. In particular, the expense calculation was prepared, reviewed and approved by only one individual, the CFO. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements using a statistically valid sample. Cause – NGA Center is not adhering to the internal control policies and procedures to ensure that payroll costs are in accordance with the time and effort reporting requirements. NGA Center does not have procedures in place to ensure adequate documentation that the hours entered in the timesheet are correctly charged to the project codes. Effect – NGA Center was unable to provide documentation to demonstrate that the payroll expenditures charged to the programs accurately reflected the actual time incurred on the programs and whether they were properly supported in accordance with 2 CFR Part 200.430 Compensation-personal service.These errors resulted in incorrect amounts charged to the Federal programs. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that NGA Center improve internal controls over the review of timesheets and hours charged to the grants, including the maintenance of adequate records and documentation. In addition, we recommend improvement on the preparation and review of compensated absences and fringe benefits. The preparation and review should be performed by different individuals to reduce the risk of both erroneous and inappropriate actions. 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.
2022-004- Internal Control Over Compliance and Compliance – Activities Allowed or Unallowed and Allowable Costs/ Cost Principles Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: Done. Management’s Corrective Action Plan: Since August 2022, in response to technical issues with an import file that caused some timesheet allocations to not be correctly coded, the CFO has added a layer of review for payroll entries to match import file values to approved timesheets. NGA accounting team members began to train and reach out to employees to reinforce the importance of completing timesheets accurately and promptly following NGA employee policies. NGA accounting since February 2023, has completed the indirect cost, compensated absences, and fringe calculations as a part of the same process for uploading payroll entries. This ensures that the calculations are accurately calculated based on the payroll file. This has ensured that these entries are produced each payroll period and correspond to supervisor-approved timesheets under 2 CFR 200.430 Compensation – Personal Services.
2022-005 - Internal Control Over Compliance and Compliance – Cash Management 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. In accordance with 2 CFR Section 200.305(b)(3), for non-Federal entities funded under the reimbursement method, reimbursement requests should be supported by documentation to verify that the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition – During our cash management testing for major program ALN 81.214, we noted the following: • For three (3) out of four (4) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of four (4) sample selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests were not reconciled with the general ledger. For the first three quarters of fiscal year 2022, the compensated absences and fringe benefits were included in the cash drawdown requests, however, NGA Center did not record the transactions in the general ledger during those quarters. Also, certain contractual services recorded in the general ledger during the last quarter of fiscal year 2022 were excluded on the cash drawdown request. During our cash management testing for major program ALN 93.421, we noted the following: • For two (2) out of two (2) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of two (2) samples selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests are not reconciled with the general ledger. During the first half of fiscal year 2022, compensated absences and fringe benefits were included in the cash drawdown request, however, NGA Center did not record the transactions in the general ledger during that period. Also, certain contractual services recorded in the general ledger during the last three quarters were excluded on the cash drawdown requests. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with the provisions of the grant agreements and general compliance principles. Cause – NGA Center did not appear to exercise due diligence in requesting Federal funds consistent with the grant agreements and its actual cash needs. Effect – NGA Center is not in compliance with the stated provisions. The opportunity to use the money for other immediate cash needs is unnecessarily delayed when funds are not requested timely. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that NGA Center comply with the provisions of the grant agreements and request Federal funds consistent with the grant agreement funding techniques and clearance patterns for these programs. 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.
Show full finding ▾Hide full finding ▴2022-005 - Internal Control Over Compliance and Compliance – Cash Management 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. In accordance with 2 CFR Section 200.305(b)(3), for non-Federal entities funded under the reimbursement method, reimbursement requests should be supported by documentation to verify that the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition – During our cash management testing for major program ALN 81.214, we noted the following: • For three (3) out of four (4) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of four (4) sample selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests were not reconciled with the general ledger. For the first three quarters of fiscal year 2022, the compensated absences and fringe benefits were included in the cash drawdown requests, however, NGA Center did not record the transactions in the general ledger during those quarters. Also, certain contractual services recorded in the general ledger during the last quarter of fiscal year 2022 were excluded on the cash drawdown request. During our cash management testing for major program ALN 93.421, we noted the following: • For two (2) out of two (2) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of two (2) samples selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests are not reconciled with the general ledger. During the first half of fiscal year 2022, compensated absences and fringe benefits were included in the cash drawdown request, however, NGA Center did not record the transactions in the general ledger during that period. Also, certain contractual services recorded in the general ledger during the last three quarters were excluded on the cash drawdown requests. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with the provisions of the grant agreements and general compliance principles. Cause – NGA Center did not appear to exercise due diligence in requesting Federal funds consistent with the grant agreements and its actual cash needs. Effect – NGA Center is not in compliance with the stated provisions. The opportunity to use the money for other immediate cash needs is unnecessarily delayed when funds are not requested timely. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that NGA Center comply with the provisions of the grant agreements and request Federal funds consistent with the grant agreement funding techniques and clearance patterns for these programs. 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.
2022-005- Internal Control Over Compliance and Compliance – Cash Management Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: June 2024 Management’s Corrective Action Plan:NGA has developed procedures to capture all required documentation during the federal disbursement request process. Staff were informed in January 2023 of the requirements for federal drawdown documentation and the CFO proceeded with a desk audit of compliance for the first and second quarter of fiscal year 2023 in April 2023. The CFO will continue to monitor compliance and adequate document retention in the second half of the fiscal year and provide training to staff when documents are not available in shared drive folders. We will also implement a regular review of the SEFA beginning in September 2023 and use that review to ensure that revenue and cash transactions correspond to the expense reports they were based on.
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.
Show full finding ▾Hide full finding ▴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.
2022-006- Internal Control Over Compliance and Compliance - Reporting Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: April 2024 Management’s Corrective Action Plan: NGA has developed a grant reporting procedure to document all the required steps including retention of support documents. This policy was finalized in August 2023 and the NGA grants management team plans to roll out and implement this process with all internal stakeholders responsible for the management of federal funds. We will continue to socialize the importance of accurate and timely grant reporting including ensuring that all federal grant reimbursements are reported following applicable federal contracts.
FAC accepted this audit on February 14, 2022 — management decision was due August 14, 2022.
FAC accepted this audit on December 20, 2020 — management decision was due June 20, 2021.
FAC accepted this audit on February 4, 2020 — management decision was due August 4, 2020.
Finding Number: 2019-001 Prior Year Finding Number: N/A Compliance Requirement: Procurement and Suspension and Debarment Information of Federal Program - Nuclear Legacy Cleanup Program CFDA #: 81.065 Grant Number: Various Grant Year: 04/23/2018 ? 04/21/2023 Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation?s Health CFDA #: 93.421 Grant Number: Various Grant Year: 08/01/2018 ? 07/31/2023 NON-ACA/PPHF Building Capacity of the Public Health System to Improve Population Health through National Nonprofit Organizations CFDA #: 93.424 Grant Number: Various Grant Year: 07/01/2013 ? 06/30/2019 Criteria ? In accordance with 2 CFR Part 180 non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition ? We noted that 6 of the 6 procurement samples tested (2 for each of the above federal programs), the Organization could not provide evidence whether the Excluded Parties List System search was performed prior to entering into contract with the vendors. Questioned Costs ? None. Context ? This is a condition identified per review of the Organization?s compliance with specified requirements using a statistically valid sample. Effect ? The Organization could inadvertently contract with vendors that are suspended or debarred from doing business with the Federal government. In addition, contracts may be executed to unqualified vendors. Cause ? The Organization does not have adequate policies and procedures to ensure compliance with the requirements regarding procurement and suspension and debarment with regards to checking the Excluded Parties List System prior to executing contract with vendors. Recommendation ? We recommend that the Organization establish policies and procedures to ensure adherence to Federal regulations relating to procurement and suspension and debarment requirements. In particular, the Organization should develop policies and procedures to ensure that vendors are not debarred or suspended by the federal government prior to entering in agreements with them.
Show full finding ▾Hide full finding ▴Finding Number: 2019-001 Prior Year Finding Number: N/A Compliance Requirement: Procurement and Suspension and Debarment Information of Federal Program - Nuclear Legacy Cleanup Program CFDA #: 81.065 Grant Number: Various Grant Year: 04/23/2018 ? 04/21/2023 Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation?s Health CFDA #: 93.421 Grant Number: Various Grant Year: 08/01/2018 ? 07/31/2023 NON-ACA/PPHF Building Capacity of the Public Health System to Improve Population Health through National Nonprofit Organizations CFDA #: 93.424 Grant Number: Various Grant Year: 07/01/2013 ? 06/30/2019 Criteria ? In accordance with 2 CFR Part 180 non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition ? We noted that 6 of the 6 procurement samples tested (2 for each of the above federal programs), the Organization could not provide evidence whether the Excluded Parties List System search was performed prior to entering into contract with the vendors. Questioned Costs ? None. Context ? This is a condition identified per review of the Organization?s compliance with specified requirements using a statistically valid sample. Effect ? The Organization could inadvertently contract with vendors that are suspended or debarred from doing business with the Federal government. In addition, contracts may be executed to unqualified vendors. Cause ? The Organization does not have adequate policies and procedures to ensure compliance with the requirements regarding procurement and suspension and debarment with regards to checking the Excluded Parties List System prior to executing contract with vendors. Recommendation ? We recommend that the Organization establish policies and procedures to ensure adherence to Federal regulations relating to procurement and suspension and debarment requirements. In particular, the Organization should develop policies and procedures to ensure that vendors are not debarred or suspended by the federal government prior to entering in agreements with them.
The Organization became aware the outside financial services firm, Rose Financial Services (RFS) was not performing this validation in the March/April 2019 period and instituted the validation process at that time. Beginning the new fiscal year July 1, 2019, the Organization is now performing all financial processing in house with permanent staff who are trained to perform this validation on all new vendors. As of July 1, 2019, RFS ceased all financial processing and reporting functions.
Finding Number: 2019-002 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed, Allowable Cost/Cost Principles Information of Federal Program - Nuclear Legacy Cleanup Program CFDA #: 81.065 Grant Number: Various Grant Year: 04/23/2018 ? 04/21/2023 NON-ACA/PPHF Building Capacity of the Public Health System to Improve Population Health through National Nonprofit Organizations CFDA #: 93.424 Grant Number: Various Grant Year: 07/01/2013 ? 06/30/2019 Criteria ? 2 CFR 200.303 requires that a recipient 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 statues, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.34a states that charges may be reported on a cash or accrual basis as long as the methodology is disclosed and is consistently applied. Condition ? During our disbursement testing, we selected 40 non-payroll transactions for each of the 3 major federal programs for testing. We noted 3 non-payroll transactions (2 for CFDA 81.065 and 1 for CFDA 93.424) wherein the Organization incorrectly recorded the allowable cost items in the current period that should have been reported in the prior period. Questioned Costs ? Known questioned cost is below threshold. Context ? This is a condition identified per review of the Organization?s compliance with specified requirements using a statistically valid sample. Effect ? The lack of proper cutoff procedures could result in the Organization inadvertently charging expenses in the incorrect period. The lack of proper cutoff procedures could also cause inconsistencies of reporting expenses in the proper period. Cause ? The Organization does not have adequate policies and procedures to ensure that federal expenditures are recorded and reported on the correct accounting period. Recommendation ? We recommend that the Organization improve its internal controls and implement adequate cut off policies and procedures to ensure that all federal expenditures are recorded and reported on the correct accounting period.
Show full finding ▾Hide full finding ▴Finding Number: 2019-002 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed, Allowable Cost/Cost Principles Information of Federal Program - Nuclear Legacy Cleanup Program CFDA #: 81.065 Grant Number: Various Grant Year: 04/23/2018 ? 04/21/2023 NON-ACA/PPHF Building Capacity of the Public Health System to Improve Population Health through National Nonprofit Organizations CFDA #: 93.424 Grant Number: Various Grant Year: 07/01/2013 ? 06/30/2019 Criteria ? 2 CFR 200.303 requires that a recipient 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 statues, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.34a states that charges may be reported on a cash or accrual basis as long as the methodology is disclosed and is consistently applied. Condition ? During our disbursement testing, we selected 40 non-payroll transactions for each of the 3 major federal programs for testing. We noted 3 non-payroll transactions (2 for CFDA 81.065 and 1 for CFDA 93.424) wherein the Organization incorrectly recorded the allowable cost items in the current period that should have been reported in the prior period. Questioned Costs ? Known questioned cost is below threshold. Context ? This is a condition identified per review of the Organization?s compliance with specified requirements using a statistically valid sample. Effect ? The lack of proper cutoff procedures could result in the Organization inadvertently charging expenses in the incorrect period. The lack of proper cutoff procedures could also cause inconsistencies of reporting expenses in the proper period. Cause ? The Organization does not have adequate policies and procedures to ensure that federal expenditures are recorded and reported on the correct accounting period. Recommendation ? We recommend that the Organization improve its internal controls and implement adequate cut off policies and procedures to ensure that all federal expenditures are recorded and reported on the correct accounting period.
The Organization was aware of this problem as a result of the previous year audit. The transactions for this finding relate to the prior year audit close. When these items were identified in the prior year audit, the Organization took appropriate action to prevent this from occurring in the future. Further actions this fiscal year include bringing all the accounting and financial reporting functions and removing Rose Financial Services (RFS) from all recording and reporting functions beginning July 1, 2019. Additionally, the Organization also developed of an accrual policy that will be in effect for all future years.
FAC accepted this audit on March 28, 2019 — management decision was due September 28, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on August 8, 2018 — management decision was due February 8, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
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