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NATIONAL FARMERS UNION FOUNDATIONNon-Profit

EIN: 311582315

UEI: V7MPK8TJVNJ5

Audited by: GELMAN, ROSENBERG & FREEDMAN

Oversight agency: 93 [Department of Health and Human Services]

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Data as of September 7, 2026

NATIONAL FARMERS UNION FOUNDATION7 audit years6 findings1 repeat
7
Audit Years
6
Total Findings
1
Repeat Findings
$1.1M
Federal Awards Expended (FY 2024)

FY 2024-12-31

LOW-RISK AUDITEE$1,100,709 federal awards expendedNo findings recorded this year

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on September 16, 2025. 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 16, 2026 (176 days ago).

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FY 2023-12-31

LOW-RISK AUDITEE$827,814 federal awards expended

FAC accepted this audit on September 17, 2024 — management decision was due March 17, 2025.

2023-001
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

We noted instances where procurement procedures were not documented for purchases in accordance with the Organization's threshold. Cause: The Organization did not adhere to its procurement policy in that it failed to perform the prescribed procurement procedures throughout the fiscal year. 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 the Organization 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: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures, as well as substantive testwork over transactions above a defined threshold from select expense accounts that were charged to the Federal program. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files.

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Finding 2023-001 Procurement Information on the Federal Programs: 93.103 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: We noted instances where procurement procedures were not documented for purchases in accordance with the Organization's threshold. Cause: The Organization did not adhere to its procurement policy in that it failed to perform the prescribed procurement procedures throughout the fiscal year. 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 the Organization 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: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures, as well as substantive testwork over transactions above a defined threshold from select expense accounts that were charged to the Federal program. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files.

Corrective Action Plan

Views of Responsible Officials: Management acknowledges the condition as noted and will update its procurement policy to follow current procedures and best practices based on the size and nature of its program. The Organization management and staff, including the Vice President of Finance and Business Development, and the Food Safety Project Manager, will implement a procurement process as of 9/1/2024 to ensure that relevant contracts or federally funded expenses are properly sourced.

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2023-002
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2022-001QUESTIONED COSTSOTHER MATTERS

We had several current year audit adjustments including an adjustment to tie out opening net assets, adjustments to update the year-end balance of investments, and additional audit adjustments were provided late during the audit process that impacted the numbers on the Schedule of Federal Expenditures. We will continue our prior year recommendation. Cause: The monthly and year-end closing process did not detect these corrections. Effect: If all accounts are not properly reconciled as of year-end, the Organization's consolidated financial statements may contain undetected misstatements. Questioned Costs: None noted. Context: Our audit included testwork over significant asset and liability balances. Identification as a Repeat Finding: See Finding 2022-001 Recommendation: We recommend that the Organization pay additional attention to the closing process to ensure that all accounts are reconciled in advance of the audit. Review and approval procedures should be in place to ensure that errors are detected.

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Finding 2023-002 Year-End Closing Process Information on the Federal Programs: All Criteria: In accordance with 2 CFR 200.303, the Organization 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 the 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 and the ‘‘Internal Control Integrated Framework’’, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: We had several current year audit adjustments including an adjustment to tie out opening net assets, adjustments to update the year-end balance of investments, and additional audit adjustments were provided late during the audit process that impacted the numbers on the Schedule of Federal Expenditures. We will continue our prior year recommendation. Cause: The monthly and year-end closing process did not detect these corrections. Effect: If all accounts are not properly reconciled as of year-end, the Organization's consolidated financial statements may contain undetected misstatements. Questioned Costs: None noted. Context: Our audit included testwork over significant asset and liability balances. Identification as a Repeat Finding: See Finding 2022-001 Recommendation: We recommend that the Organization pay additional attention to the closing process to ensure that all accounts are reconciled in advance of the audit. Review and approval procedures should be in place to ensure that errors are detected.

Corrective Action Plan

Views of Responsible Officials: Management understands the need to ensure all accounts are reconciled in advance of the audit. The adjustment to tie out opening net assets has been addressed and corrected, and going forward will be recorded and confirmed prior to audit except for adjustments for K-1s received after the audit starts. For year-end investments balances, some K-1s are received during fieldwork. Since it is not feasible to prepare estimates of the K-1 amounts, the entries for the investment balance changes and corresponding adjustments for intercompany adjustments, management will prepare the entries as soon as K-1s are received and send to auditors. Since this is due to timing, not internal process, management respectfully requests that this process will not reflect negatively against the organization. For audit adjustments impacting the numbers on the Schedule of Federal Expenditures, the issues have been addressed and systems have been developed to ensure timely and accurate information. Management, including the Vice President of Finance and Business Development, and the Organization's contracted financials service providers have recorded these entries as of 7/9/2024.

Prior Finding References

2022-001

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FY 2022-12-31

$1,000,628 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 26, 2023 — management decision was due January 26, 2024.

FY 2021-12-31

$1,391,336 federal awards expended

FAC accepted this audit on July 14, 2022 — management decision was due January 14, 2023.

2021-001
Other
SIGNIFICANT DEFICIENCYOTHER MATTERS

We were unable to verify that drawdown requests for CFDA 93.103 were reviewed and approved for the first three quarters of the year. Cause: There was no formal approval indication on the drawdown requests for 93.103 by the program department for the first three quarters of the year. Effect or Potential Effect: Formal documentation of drawdown approval reduces the potential for error or oversight. Questioned Costs: None identified. Context: We tested all cash receipt/drawdowns during the year. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that the Organization consistently apply the approval process by which a program staff person and the Director of Finance sign and date the face of the drawdown support, and file it along with the drawdown documentation.

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Federal Programs: CFDA 93.103 Criteria: In accordance with 2 CFR 200.303, the Organization 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 the 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 and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: We were unable to verify that drawdown requests for CFDA 93.103 were reviewed and approved for the first three quarters of the year. Cause: There was no formal approval indication on the drawdown requests for 93.103 by the program department for the first three quarters of the year. Effect or Potential Effect: Formal documentation of drawdown approval reduces the potential for error or oversight. Questioned Costs: None identified. Context: We tested all cash receipt/drawdowns during the year. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that the Organization consistently apply the approval process by which a program staff person and the Director of Finance sign and date the face of the drawdown support, and file it along with the drawdown documentation.

Corrective Action Plan

Views of Responsible Officials: Responsible officials agree with the finding. Adequate documentation was not recorded for the approval of drawdowns in the first three quarters of 2021. As of the fourth quarter 2021, drawdown approval requests are sent via e-mail to either the Chief Operating Officer or Grant Project Manager, both of whom are deemed responsible parties of adequate authority to approve. The email approvals are saved and reviewed by Vault Consulting, NFU?s outsourced accounting provider, prior to initiating the drawdown. NFU continues to follow the above procedure in 2022 for all drawdowns initiated through the date of this audit report and will do so for all subsequent drawdowns. I

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2021-002
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

We were unable to verify supervisor approval for two timesheets. Cause: The Organization requires supervisor approval of timesheets, but there were two instances where the approval was no present. Effect or Potential Effect: Approval of timesheets helps to ensure accurate recording and allocation of time charged. Questioned Costs: None identified. Context: Of our sample of 40 items there were two items that lacked supervisor approval. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that supervisor approval of timesheets be documented.

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Federal Programs: CFDA 93.103 Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, paragraph 430 ?Compensation personal services? requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, and that these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, these records must comply with established accounting policies and practices of the non-Federal entity. Condition: We were unable to verify supervisor approval for two timesheets. Cause: The Organization requires supervisor approval of timesheets, but there were two instances where the approval was no present. Effect or Potential Effect: Approval of timesheets helps to ensure accurate recording and allocation of time charged. Questioned Costs: None identified. Context: Of our sample of 40 items there were two items that lacked supervisor approval. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that supervisor approval of timesheets be documented.

Corrective Action Plan

Views of Responsible Officials: Responsible officials agree with this finding. In 2021 there were staff changes that resulted in a lapse of supervisor approval in the two instances stated above. In response to the above finding Vault Consulting, NFU?s outsourced accountants, completed an internal review of timesheet approvals through 2022 to confirm all timesheets had adequate approval. Additionally, a control within the payroll system now alerts the payroll processor when timesheets have not been approved. With these changes, NFU is confident all timesheets will have appropriate supervisory approval in 2022. I

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FY 2019-12-31

LOW-RISK AUDITEE$1,953,159 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 22, 2020 — management decision was due December 22, 2020.

FY 2018-12-31

$1,639,666 federal awards expended

FAC accepted this audit on July 7, 2019 — management decision was due January 7, 2020.

2018-001
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-002
Other
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-12-31

$900,927 federal awards expendedNo findings recorded this year

FAC accepted this audit on July 1, 2018 — management decision was due January 1, 2019.

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