Minnesota Land TrustNon-Profit

Internal Controls over Compliance and Other Matters Identification of Federal Funds for Purposes of Assembling the Schedule of Expenditures of Federal Awards (SEFA) – Other ALL FEDERAL PROGRAMS IDENTIFIED ON THE SEFA Criteria: Per 2 CFR 200.510(b) Schedule of expenditures of Federal awards (SEFA), “the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502, Basis for determining Federal awards expended. While the auditor is able to assist with SEFA preparation, management remains responsible for identifying all federal expenditures to enable the preparation of a complete and accurate SEFA. Condition: Management was unable to provide a complete listing of federal expenditures at the start of audit fieldwork. Cause: Internal controls were not in place to require a final review of the listing of federal expenditures by the Director of Finance prior to audit fieldwork when the listing was prepared by another staff person. Questioned Costs: None. Effect: By not having proper controls over SEFA preparation at the beginning of the audit, there is a risk that the SEFA will not reflect all the federal awards subject to the Uniform Guidance, which could lead to an incorrect major program determination and a substandard single audit. Context: We requested that the Organization provide a list of all federal expenditures at the start of audit fieldwork. During the audit, we detected federal expenditures that were not identified by the Organization as federal. Additionally, the Organization identified federal expenditures during their review of the draft financial statements, which were previously not identified as federal. identified as federal. Identification of Repeat Finding: Not a repeat finding. Recommendation: We recommend that Minnesota Land Trust implement internal controls to ensure there is an adequate communication and review process in place to capture all federal awards expended at the correct amounts in accordance with the criteria above. Views of Responsible Officials and Corrective Action Plan: The Minnesota Land Trust has internal controls to ensure that federal expenditures are accurately identified and reviewed. We will add additional internal controls to ensure a complete listing of federal expenditures is easy to provide and that the listing is reviewed by the Finance Department prior to audit fieldwork.

Internal Controls over Compliance and Other Matters C. Cash Management – Lack of Documented Procedures Related to Advance Payments U.S. ENVIRONMENTAL PROTECTION AGENCY Geographic Programs - Great Lakes Restoration Initiative – Assistance Listing No. 66.469 Criteria: The federal sub-award grant agreement number 208171 for the EPA Perch Lake Habitat Restoration Project from the State of Minnesota requires Minnesota Land Trust to comply with all federal requirements imposed on the awarded funds, which includes Title 2 U.S. Code of Federal Regulation (CFR) section 200.305. In accordance with 2 CFR section 200.305, a non-federal entity must maintain written procedures that minimize the time elapsing between the transfer of funds and disbursement. Condition: Minnesota Land Trust does not have documented procedures over advance payments that incorporate all the requirements of 2 CFR section 200.305. Cause: Internal controls were not in place to ensure Minnesota Land Trust was aware of the compliance requirements per 2 CFR 200.305 for advance payments. Questioned Costs: None. Effect: Minnesota Land Trust is not in compliance with 2 CFR section 200.305. Context: The federal sub-award grant agreement number 208171 allows for Minnesota Land Trust to request advance payments. Minnesota Land Trust requested and received advance payments related to this project during fiscal year 2023. Recommendation: We recommend that Minnesota Land Trust adopt a written advance payment policy which includes all requirements of 2 CFR section 200.305. Views of Responsible Officials: Minnesota Land Trust agrees with the finding and will adopt a documented advance payment policy consistent with the standards of 2 CFR section 200.305 to use for advance payment requests under federal awards or sub-awards.

Finding 2021-001 ? Lack of Documented Procurement Procedures ? ALN 66.469 Criteria: The grant agreement with the State of Minnesota requires the Minnesota Land Trust to comply with Title 2 U.S. Code of Federal Regulation (CFR) section 200.318 through 200.321. In accordance with 2 CFR section 200.320, a non-federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR section 200.317 through 200.320 for any method of procurement used for the acquisition of property or services required under a federal award or sub-award. Condition: Minnesota Land Trust does not have documented procurement procedures that incorporate all the requirements of 2 CFR section 200.317 through 200.320. Cause: The Minnesota Land Trust has followed the specific procurement requirements as outlined in each federal award, rather than adopting their own internal policy. Questioned Costs: None. Effect: Minnesota Land Trust is not in compliance with 2 CFR section 200.320 or the terms of the grant agreement with the State of Minnesota. Recommendation: We recommend that Minnesota Land Trust adopt a written procurement policy which includes all requirements of 2 CFR section 200.317 through 200.320. Views of Responsible Officials: Minnesota Land Trust agrees with the finding and will adopt a documented procurement policy consistent with the standards of 2 CFR section 200.317 through 200.320 to use for procurement of the acquisition of property or services required under federal awards or sub-awards.