Ecological Society of America, IncNon-Profit

Finding 2024-002: Subrecipient Pre-Award Risk Assessment Information on Federal Program: 47.074 Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: As part of our audit, we selected a sample of subawards charged to the major Federal programs. We noted that subaward risk assessments were not available for our inspection for those samples selected. Cause: The Society did not perform subaward risk assessments as required by Federal regulation. Effect or Potential Effect: The Society may have inadvertently failed to perform monitoring procedures appropriate for a subrecipient’s assessed level of risk. Questioned Costs: N/A Context: The Society executes subaward agreements under US Federal grants. Therefore, the Society is subject to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test work completed on subawards and individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Society's general ledger (accounting system). There was total population of three subrecipients and our sample size was one. We consider our sample to be representative of the population. Identification of Repeat Finding, if Applicable: N/A Recommendation: We recommend that the Society enhance their pre-award risk assessment policy and monitoring procedures to ensure that their subrecipients have accounting systems in place and adequate internal controls to administer the grant. The Society should also identify and apply appropriate sanctions for subrecipient noncompliance.

Finding 2023-001: Suspension and Debarment Information on Federal Program: 47.074 Criteria or Specific Requirement: Recipients of Federal funding must adhere to specific requirements on screening of all potential and current vendors, suppliers, contractors, subrecipients, fellows, etc. to ensure the recipient is not conducting business with excluded parties (as defined by the United States Government). This screening process must also be documented in writing. Condition: The Society did not consistently perform the screening process for its potential and current vendors, suppliers, contractors, subrecipients, etc. that were paid with Federal funds. Context: Payments were made during the fiscal year without performing the proper screening process. 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. The issue is deemed to be systemic. Cause: The Society did not have a formal policy in place with regard to suspension and debarment screenings, although they did occasionally perform screening of potential and current vendors, suppliers, contractors, and subrecipients. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors, subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None Identification of Repeat Finding: N/A Recommendation: We recommend that the Society establish policies and ensure that all types of parties (as noted above) are included, and educate its employees on the procedures necessary to ensure full compliance with this requirement. We also recommend that the Society document each of these screenings and retain them in the respective files, which should be completed prior to engaging in relationships with these parties. For ongoing relationships, the Society should consider performing screenings on an annual basis (and documenting them) to ensure continuous compliance in the event the suspension and debarment status of any of these parties changes. Lastly, we recommend the Society perform retrospective screenings on these parties to which it made payments during the fiscal year.