EIN: 386027814
UEI: JXAAF32AN454
Audited by: Rehmann Robson LLC
Oversight agency: 11 [Department of Commerce]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 6, 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 August 6, 2026 (32 days ago).
What is a management decision? →FAC accepted this audit on March 7, 2025 — management decision was due September 7, 2025.
2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.
Show full finding ▾Hide full finding ▴2024-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA subaward report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. Cause. The Commission does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance. Effect. The Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement.
Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. As a result, the Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Auditor Recommendation: We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. Corrective Action: Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement. Responsible Person: Joseph Bertram, Financial Operations Manager. Anticipated Completion Date: June 30, 2025.
2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.
Show full finding ▾Hide full finding ▴2024-002 – Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Agriculture - Soil & Water Conservation (ALN 10.902); Direct award; All project numbers. U.S. Department of Commerce - Congressionally Identified Awards and Projects (ALN 11.469); Direct award. U.S. Department of the Interior - Great Lakes Restoration (ALN 15.662); Direct award; All project numbers. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. Cause. The Commission does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Questioned Costs. None. Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. View of Responsible Officials. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties.
Auditor Description of Criteria, Condition and Effect: Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded a procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. During our testing it was noted that seven out of nine nonprocurement contracts for subrecipients and three out of three procurement contracts for vendors did not provide evidence that the respective vendors or subrecipients were not suspended, debarred, or otherwise excluded at the time the Commission entered into the covered transactions. The failure to monitor suspension and debarment could cause the Commission to enter into covered transactions with vendors who are not eligible to have goods or services purchased with federal monies and to subrecipients who are not eligible to receive subawards. Upon review of the excluded parties listing subsequent to year end, it was determined that none of the parties that were awarded either procurement or nonprocurement contracts were excluded parties. Auditor Recommendation. We recommend that the Commission review its procedures for issuing contracts ensure that the appropriate suspension and debarment evidence of verifications are retained for all vendors providing goods or services and subrecipients receiving subawards in excess of $25,000. The recommended best practice is to include a certification verifying suspension and debarment in every contract funded by federal dollars with every vendor or subrecipient to ensure compliance. Responsible Person: Joseph Bertram, Financial Operations Manager. Corrective Action. Management concurs with the finding. The Commission will ensure that all future contracts include certification language verifying suspension and debarment and will also collect separate certificates verifying suspension and debarment from current covered transactions where the certification was omitted from the contract in error. Management has continued its practice of checking suspension and debarment for covered transactions annually in preparation for the audit and notes that none of the Commission's vendors or subrecipients that were awarded contracts were excluded parties. Anticipated Completion Date: June 30, 2025.
FAC accepted this audit on February 7, 2024 — management decision was due August 7, 2024.
FAC accepted this audit on February 1, 2023 — management decision was due August 1, 2023.
FAC accepted this audit on December 21, 2021 — management decision was due June 21, 2022.
FAC accepted this audit on January 3, 2021 — management decision was due July 3, 2021.
FAC accepted this audit on January 6, 2020 — management decision was due July 6, 2020.
Under the Habitat Conservation program, the grantor for Project 3232 provided the Commission with an invoice packet totaling $627,511 (which was reviewed approved and posted by management in the fiscal year 2019). The packet contained a cover page stating that the costs were for August 2018 contract services. Upon further review of the details of the invoice packet, we noted that there were three invoices relating to expenses incurred in May and June of the prior fiscal year 2018 totaling $366,627. These costs had not been recognized in the prior period. Cause: The invoice packet that was received from West Michigan Shoreline Regional Development contained a cover page which specifically stated "August 2018 Contract services" and therefore all expenditures were included in fiscal year 2019. It appears as though there was an oversight on the part of staff when reviewing the support that was received. Effect: As a result of the condition, the Commission's financial information had not properly recognized the formerly mentioned expenses incurred and thus understated prior year expenses by the same amount in question and overstating expenses in the current fiscal period. As we had selected the program in the previous fiscal period for testing, the exclusion of these expenditures would not have impacted our audit approach or testing results. Additionally, we included the expenses in our audit sample in the current period and adjusted the amounts to be included in the current period schedule of federal expenditures. Recommendation: We recommend that the Commission pay closer attention to the invoice details provided by the subrecipients to ensure that expenses are recorded in the proper period. View of Responsible Officials: Management agrees with this finding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴2019-001 - Period of Performance Finding Type: Significant Deficiency in Internal Control over Compliance (Period of Performance) Program: U.S. Department of Commerce; Habitat Conservation; National Oceanic and Atmospheric Administration; CFDA Number 11.463 Criteria: Where a funding period is specified, a non-Federal entity may charge to the award only costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency. Also, if authorized by the Federal program, unobligated balances may be carried over and charged for obligations of the subsequent awarded, goods and services received and similar transactions during a given period that will require payment by the non-Federal entity during the same or a future period. Condition: Under the Habitat Conservation program, the grantor for Project 3232 provided the Commission with an invoice packet totaling $627,511 (which was reviewed approved and posted by management in the fiscal year 2019). The packet contained a cover page stating that the costs were for August 2018 contract services. Upon further review of the details of the invoice packet, we noted that there were three invoices relating to expenses incurred in May and June of the prior fiscal year 2018 totaling $366,627. These costs had not been recognized in the prior period. Cause: The invoice packet that was received from West Michigan Shoreline Regional Development contained a cover page which specifically stated "August 2018 Contract services" and therefore all expenditures were included in fiscal year 2019. It appears as though there was an oversight on the part of staff when reviewing the support that was received. Effect: As a result of the condition, the Commission's financial information had not properly recognized the formerly mentioned expenses incurred and thus understated prior year expenses by the same amount in question and overstating expenses in the current fiscal period. As we had selected the program in the previous fiscal period for testing, the exclusion of these expenditures would not have impacted our audit approach or testing results. Additionally, we included the expenses in our audit sample in the current period and adjusted the amounts to be included in the current period schedule of federal expenditures. Recommendation: We recommend that the Commission pay closer attention to the invoice details provided by the subrecipients to ensure that expenses are recorded in the proper period. View of Responsible Officials: Management agrees with this finding and has prepared a corrective action plan.
Closely review the invoice details provided by project subrecipients to ensure that expenses are recorded in the proper period.
FAC accepted this audit on January 20, 2019 — management decision was due July 20, 2019.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on January 1, 2018 — management decision was due July 1, 2018.
FAC accepted this audit on January 3, 2017 — management decision was due July 3, 2017.
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