Conservation Science Partners, Inc.

Finding 2023-002: Information on the Federal Programs: 1) Assistance Listing Number 11.431 - Climate and Atmospheric Research, United States Department of Commerce. Award Number: NA20OAR4310366. Compliance Requirements: Procurement and Suspension and Debarment. Type of Finding: Significant Deficiency. 2) Assistance Listing Number 15.246 - Threatened and Endangered Species, United States Department of the Interior. Award Number: L21AC10475-02. Compliance Requirements: Procurement and Suspension and Debarment. Type of Finding: Significant Deficiency. Criteria: Program requirements state that the Organization was required to comply with requirements related to debarment and suspension. Condition: We noted written policies were in place to verify that an entity with which the Organization plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded, however the Organization was unable to provide evidence that certain procedures described in these policies were being followed. Cause: The Organization did not properly document evidence of an effective control activities to provide reasonable assurance of federal compliance. Entities applying for sub-awards from the Organization are required to self-certify that they are not debarred, suspended, or otherwise excluded, however there is no documentation to support verifying this information using the System for Award Management (SAM.gov). Effect or Potential Effect: As a result, the Organization does not appear to meet the program compliance requirement. Questioned Costs: $0. Context: We were unable to obtain sufficient appropriate audit evidence to determine federal compliance, however our testing of direct expenditures during the audit noted no apparent covered transactions with debarred, suspended, or otherwise excluded entities, resulting in no questioned costs. Repeat Finding: Not applicable. Recommendation: Formal procedures should be established to ensure compliance with federal debarment and suspension requirements. Views of Responsible Official: See Corrective Action in Part D below.

Finding 2023-003: Information on the Federal Programs: Assistance Listing Number 11.431 - Climate and Atmospheric Research, United States Department of Commerce. Award Number: NA20OAR4310366. Compliance Requirements: Reporting. Type of Finding: Significant Deficiency. Criteria: Program requirements state that the Organization was required to comply with requirements related to reporting. Condition: We noted the entity was a direct recipient who made first tier subawards of $30,000 or more and therefore was subject to the Federal Funding Accountability and Transparency Act of 2006 (“FFATA”), which requires the Organization to report subaward data through FSRS.gov. The Organization obtained the information needed to file these reports on the subaward agreements, however no filings have been submitted to date. Cause: The Organization did not properly establish effective control activities to provide reasonable assurance of federal compliance due to being unaware of these reporting requirements. Effect or Potential Effect: As a result, the Organization does not appear to meet the program compliance requirement. Questioned Costs: $0. Context: We were unable to obtain sufficient appropriate audit evidence to determine federal compliance, and this finding appears to be systemic based on the above information. Repeat Finding: Not applicable. Recommendation: Formal procedures should be established to ensure compliance with federal reporting requirements. Views of Responsible Official: See Corrective Action in Part D below.