AMERICAN SOYBEAN ASSOCIATIONNon-Profit

Criteria and Condition: Per 7 CFR §1489.21 – Reports, under the Regional Agricultural Promotion Program (RAPP), participants are required to electronically submit trip reports no later than 45 days after completion of travel (other than local travel). Trip reports must include the name(s) of the traveler(s), purpose of travel, itinerary, names and affiliations of contacts, and a summary of findings, conclusions, recommendations, and specific accomplishments.

Criteria and Condition: Title to real property acquired or improved by non-federal entities under grants and cooperative agreements vests in the non-federal entity subject to the obligations and conditions specified in 2 CFR section 200.311 (2 CFR section 200.311(a)). Real property will be used for the originally authorized purpose as long as needed for that purpose, during which time the non-federal entity must not dispose of or encumber title to or other interests in the real property (2 CFR section 200.311(b)). When real property is no longer needed for the originally authorized purpose, the non-federal entity must obtain disposition instructions from the federal awarding agency or the pass-through entity, as applicable. When real property is sold, sales procedures must be followed that provide for competition to the extent practicable and result in the highest possible return. If sold, non- federal entities must compensate the federal awarding agency for the portion of the net sales proceeds that represents the federal agency’s interest in the real property, which is the amount calculated by multiplying the current market value or sale proceeds by the federal agency’s participation in total project costs. If the property is retained, the non-federal entity must compensate the federal awarding agency for the federal portion of the current fair market value of the property. Disposition instructions may also provide for transfer of title to the federal awarding agency or a designated third party, in which case the non-federal entity is entitled to the non-federal interest in the property, which is calculated by multiplying the current market value or sale proceeds by the non-federal entity’s share in total project costs (2 CFR section 200.311(c)(3)). Context: A foreign office indicated that assets purchased with federal funds were disposed of, but were still included on the inventory listing. Cause: The federal awarding agency was not notified of the disposal of assets purchased with federal funds. Questioned Cost: No questioned costs. Effect: Assets no longer in service are included on the federal fixed asset listing. Recommendation: Fixed assets purchased with federal funds should be subject to regular inventory, with dispositions communicated to the federal agency. Classification: Compliance finding and control deficiency in internal controls.

Criteria and Condition: The Foreign Market Development Cooperator Program requires matching contributions equal to 185% of project expenditures. These contributions must include expenditures that have been incurred and are allowable under 2 CFR Part 200, Subpart E (CostPrinciples). Context: A test of the 2023 project contribution amounts for program year 2022 revealed that the contribution amount was being calculated by USSEC through an allocation rate of all program expenditures funded with non-federal revenue sources. These expenditures include unallowable costs under 2 CFR Part 200, Subpart E that are required to be excluded from the calculation of the total project contribution amount. Cause: Expenditures used to meet the matching requirement were not reviewed to determine if costs were allowable under 2 CFR Part 200, Subpart E. Questioned Cost: $-0- No questioned costs are reported as the Association has demonstrated allowable matching costs were incurred in excess of the requirement. Effect: Project expenditures that are unallowable are included within the matching contribution rate. Recommendation: We recommend that USSEC management reviews each expense included within the matching contribution total to verify that they have been incurred and are allowable under 2 CFR Part 200, Subpart E. Classification: Compliance finding and control deficiency in internal controls. View of Responsible Officials and Planned Corrective Actions: USSEC will review expenses included in the Contribution Report more closely to ensure they are allowable under 2 CFR Part 200, Subpart E. For the report being submitted in June 2024 for program year 2023, all expenses related to meals, travel-related meals, and group meals at events will be removed. Food and beverages, including alcoholic beverages will not be included in the 2023 EOY Report.

Criteria and Condition: The Foreign Market Development Cooperator Program requires equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Context: A nonstatistical test of the 7 equipment and real property selections revealed that the 3 were not properly reconciled to the equipment records during the semiannual inventory counts at a USSEC international office location. These 3 selections were recorded twice on the equipment listing. The errors in the listing was an error in maintaining proper records and did not include duplicate funds being received for the equipment purchase. Cause: The physical inventory of equipment properly occurred twice during 2023, but the individual performing the physical inventory did not do so with diligence, resulting in the equipment records not being properly reconciled with the results of the physical inventory. Questioned Cost: $-0- Effect: The effectiveness of the physical inventory of equipment relies on the individual performing the count. The lack of a diligent and accurate reconciliation of equipment during a physical inventory can result in inaccurate equipment records. Recommendation: We recommend that USSEC management provides stronger oversite of the physical inventories and equipment reconciliations that occur at remote office locations to ensure individuals performing the counts are doing so with diligence. Classification: Compliance finding and control deficiency in internal controls. View of Responsible Officials and Planned Corrective Actions: USSEC will ensure stronger oversight of fixed asset inventories and reconciliation processes.