EIN: 462694047
UEI: MLA5YSUM4FK3
Audited by: CliftonLarsonAllen LLP
Oversight agency: 10 [Department of Agriculture]
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Data as of August 30, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 30, 2025. 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 March 30, 2026 (153 days ago).
What is a management decision? →Of the 40 payroll disbursements selected for testing, noted 31 did not have documentation of an approved pay rate, all did not have a formal review and approval documented over the payroll registers to verify completeness and accuracy, and 37 did not have a formal review and approval documented over the payroll for time and effort documentation. Questioned costs: None Context: Of the 40 payroll disbursements selected for testing, noted 31 did not have documentation of an approved pay rate, all did not have a formal review and approval documented over the payroll registers to verify completeness and accuracy, and 37 did not have a formal review and approval documented over the payroll for time and effort documentation. Per testing, noted no employee charges more than 100% of their time across federal funding or other funding sources. Cause: Due to growth of the Organization, they did not have a formal procedure to retain documentation of the review and approval over effective payrates, payroll registers or time and effort documentation. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities. Repeat Finding: No Recommendation: We recommend the Organization implement a compensating control to formally document their review and approval over payrates, payroll registers and time & effort studies. This review would include comparing the payroll processed and allocated to the grant to the approved time and effort documentation by funding source to ensure payroll costs are not being overcharged. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: Partnerships for Climate-Smart Commodities Assistance Listing Number: 10.937 Federal Award Identification Number and Year: NR233A750004G064 - 2023 Award Period: 7/20/2023-6/30/2028 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Requirement: Allowable Costs and Activities Criteria or specific requirement: Standards require that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: Of the 40 payroll disbursements selected for testing, noted 31 did not have documentation of an approved pay rate, all did not have a formal review and approval documented over the payroll registers to verify completeness and accuracy, and 37 did not have a formal review and approval documented over the payroll for time and effort documentation. Questioned costs: None Context: Of the 40 payroll disbursements selected for testing, noted 31 did not have documentation of an approved pay rate, all did not have a formal review and approval documented over the payroll registers to verify completeness and accuracy, and 37 did not have a formal review and approval documented over the payroll for time and effort documentation. Per testing, noted no employee charges more than 100% of their time across federal funding or other funding sources. Cause: Due to growth of the Organization, they did not have a formal procedure to retain documentation of the review and approval over effective payrates, payroll registers or time and effort documentation. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities. Repeat Finding: No Recommendation: We recommend the Organization implement a compensating control to formally document their review and approval over payrates, payroll registers and time & effort studies. This review would include comparing the payroll processed and allocated to the grant to the approved time and effort documentation by funding source to ensure payroll costs are not being overcharged. Views of responsible officials: There is no disagreement with the audit finding.
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937 Recommendation: We recommend the Organization implement a compensating control to formally document their review and approval over payrates, payroll registers and time & effort studies. This review would include comparing the payroll processed and allocated to the grant to the approved time and effort documentation by funding source to ensure payroll costs are not being overcharged. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization’s practice is to require management approval before employee payrates are changed and before each payroll is initiated in the system. This practice was in place in 2024, but documentation of management approval had not been consistently maintained. The Organization will implement a process where any changes to an employee payrate is approved by a member of management via email prior to the change taking effect. Similarly, the Organization will implement a process where before payroll is processed each pay period, a member of management will review and document their approval of the payroll register via email or via the payroll system itself. In late 2024, the Organization began conducting quarterly time studies by position and adjusting allocations as time spent deviates from the most recent time study. These time studies are approved by the Organization’s management via email correspondence. Name(s) of the contact person(s) responsible for corrective action: Angie Sullivan, Director of Operations Planned completion date for corrective action plan: October 31, 2025
Of the 5 claims for reimbursement selected for testing, noted 4 did not have a formal review documented by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over the cash management compliance requirement. When testing matching, the two claims that were tested included an indirect match that was not reported correctly, although the matching requirement was met. Questioned costs: None Context: While performing audit procedures, it was noted that four of five grant claims tested that were submitted for reimbursement did not have formal documentation of review by someone other than the preparer. Cause: Due to limited personnel, the Organization had not implemented formal controls related to reimbursement requests. Effect: There could be the possibility that the client would over- or under-report certain items for reimbursement on claims if there are no reviews in place. Repeat Finding: No Recommendation: We recommend the Organization implement a formal control where someone other than the preparer document their review of the claim prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: Partnerships for Climate-Smart Commodities Assistance Listing Number: 10.937 Federal Award Identification Number and Year: NR233A750004G064 - 2023 Award Period: 7/20/2023-6/30/2028 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Requirement: Cash Management and Matching Criteria or specific requirement: Grant claims filed by the Organization to granting agencies must be accurate, reconcile to the Organizations general ledger system and for cost-reimbursable grants, represent costs incurred. Internal controls should be signed and implemented to prevent and detect errors in the data reported on the grant claims. Segregation of duties is an internal control intended to prevent or decrease to occurrence of errors or intentional fraud. Segregation of duties ensure that no single employee has control over all phases of a transaction. There should be a secondary review of each grant claim prior to being certified and filed to ensure that there are no errors, irregularities, or misrepresentations. Condition: Of the 5 claims for reimbursement selected for testing, noted 4 did not have a formal review documented by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over the cash management compliance requirement. When testing matching, the two claims that were tested included an indirect match that was not reported correctly, although the matching requirement was met. Questioned costs: None Context: While performing audit procedures, it was noted that four of five grant claims tested that were submitted for reimbursement did not have formal documentation of review by someone other than the preparer. Cause: Due to limited personnel, the Organization had not implemented formal controls related to reimbursement requests. Effect: There could be the possibility that the client would over- or under-report certain items for reimbursement on claims if there are no reviews in place. Repeat Finding: No Recommendation: We recommend the Organization implement a formal control where someone other than the preparer document their review of the claim prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission. Views of responsible officials: There is no disagreement with the audit finding.
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937 Recommendation: We recommend the Organization implement a formal control where someone other than the preparer document their review of the claim prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has created a process to ensure that claims are reviewed and approved prior to submission to the funder. This starts with the Claim/Billing Approval Form that is prepared by the Grants Manager/Designee and is routed to the Project Manager along with the supporting documentation. Once the form has been approved and electronically signed by both staff, it will be saved in the Organization’s internal files, and the claim will be initiated in the funder portal. Name(s) of the contact person(s) responsible for corrective action: Jill Matchett, Grants Manager Planned completion date for corrective action plan: October 10, 2025
During our testing, we noted that the Organization did not implement a formal procurement policy or suspension and debarment policy to follow but instead followed each federal agencies policies as part of the federal award. During our testing, we noted the Organization did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned costs: None Context: While performing audit procedures, it was noted that the Organization did not implement a formal procurement policy along with no separate policies for suspension and debarment. During our testing, it was noted that the Organization did not maintain documentation over verification the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration prior to entering into a signed contract. Cause: The Organization follows regulations implemented by each federal contract and works with the federal agency contact to ensure compliance with purchasing. The Organization did not implement entity-wide procedures and policies to be followed in accordance with the Uniform Guidance for procurement, suspension, and debarment. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend that the Organization implement a procurement policy that addresses the five procurement methods allowed under Uniform Guidance. Internal controls should be implemented to make sure procurement methods are properly followed and documentation is maintained. We recommend the Organization develop and implement controls to ensure compliance with suspension and debarment requirements and keep an electronic or manual file indicating that such review was done to verify that they are following compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: Partnerships for Climate-Smart Commodities Assistance Listing Number: 10.937 Federal Award Identification Number and Year: NR233A750004G064 - 2023 Award Period: 7/20/2023-6/30/2028 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Procurement, Suspension and Debarment. Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have policies and procedures in place to following in relation to procurement, suspension, and debarment. Condition: During our testing, we noted that the Organization did not implement a formal procurement policy or suspension and debarment policy to follow but instead followed each federal agencies policies as part of the federal award. During our testing, we noted the Organization did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned costs: None Context: While performing audit procedures, it was noted that the Organization did not implement a formal procurement policy along with no separate policies for suspension and debarment. During our testing, it was noted that the Organization did not maintain documentation over verification the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration prior to entering into a signed contract. Cause: The Organization follows regulations implemented by each federal contract and works with the federal agency contact to ensure compliance with purchasing. The Organization did not implement entity-wide procedures and policies to be followed in accordance with the Uniform Guidance for procurement, suspension, and debarment. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend that the Organization implement a procurement policy that addresses the five procurement methods allowed under Uniform Guidance. Internal controls should be implemented to make sure procurement methods are properly followed and documentation is maintained. We recommend the Organization develop and implement controls to ensure compliance with suspension and debarment requirements and keep an electronic or manual file indicating that such review was done to verify that they are following compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937 Recommendation: We recommend that the Organization implement a procurement policy that addresses the five procurement methods allowed under Uniform Guidance. Internal controls should be implemented to make sure procurement methods are properly followed and documentation is maintained. We recommend the Organization develop and implement controls to ensure compliance with suspension and debarment requirements and keep an electronic or manual file indicating that such review was done to verify that they are following compliance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization is in the process of reviewing and updating their current procurement policy to reflect the Uniform Grant Guidance requirements. We believe that this can be completed by October 15, 2025. The Organization has created a formal process for verifying suspension and debarments in SAM.gov. The verification details are as follows: clear screenshot, search parameters, date of search, search results, and name of reviewer. Once the verification is complete, the document is placed in the project folder for future reference. Name(s) of the contact person(s) responsible for corrective action: Jill Matchett, Grants Manager Planned completion date for corrective action plan: October 10, 2025
Of the two financial reports and two performance reports tested, there was no formal review documented by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over the reporting compliance requirement. When testing matching, the two financial reports that were tested did not report the correct amount for the indirect match incurred as part of the federal award. Questioned costs: None Context: No instance of noncompliance with the matching requirement, however during our testing of two financial reports, the Organization incorrectly reported the amount of the match incurred as part of the federal award. Of the two financial reports and two performance reports tested, there was no formal review documented by someone other than the preparer who submitted and certified the report. Cause: Due to limited personnel, the Organization had not implemented formal controls related to grant reports Effect: There could be the possibility that the client would over- or under-report certain items for reimbursement on claims if there are no reviews in place. Repeat Finding: No Recommendation: We recommend the Organization implement a formal control where someone other than the preparer documents their review of the financial and performance reports prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: Partnerships for Climate-Smart Commodities Assistance Listing Number: 10.937 Federal Award Identification Number and Year: NR233A750004G064 - 2023 Award Period: 7/20/2023-6/30/2028 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Requirement: Reporting and Matching Criteria or specific requirement: Grant reports filed by the Organization to granting agencies must be accurate and complete by reconciling to the Organizations financial reports and accounting records. Internal controls should be signed and implemented to prevent and detect errors in the data reported on the grant reports. Segregation of duties is an internal control intended to prevent or decrease to occurrence of errors or intentional fraud. Segregation of duties ensure that no single employee has control over all phases of a transaction. There should be a secondary review of each grant report prior to being certified and filed to ensure that there are no errors, irregularities, or misrepresentations. Condition: Of the two financial reports and two performance reports tested, there was no formal review documented by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over the reporting compliance requirement. When testing matching, the two financial reports that were tested did not report the correct amount for the indirect match incurred as part of the federal award. Questioned costs: None Context: No instance of noncompliance with the matching requirement, however during our testing of two financial reports, the Organization incorrectly reported the amount of the match incurred as part of the federal award. Of the two financial reports and two performance reports tested, there was no formal review documented by someone other than the preparer who submitted and certified the report. Cause: Due to limited personnel, the Organization had not implemented formal controls related to grant reports Effect: There could be the possibility that the client would over- or under-report certain items for reimbursement on claims if there are no reviews in place. Repeat Finding: No Recommendation: We recommend the Organization implement a formal control where someone other than the preparer documents their review of the financial and performance reports prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission. Views of responsible officials: There is no disagreement with the audit finding.
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937 Recommendation: We recommend the Organization implement a formal control where someone other than the preparer documents their review of the financial and performance reports prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization is finalizing the Federal Grant Report Review and Submission Protocol whose purpose is to ensure that all federal funding programmatic reports and FFRs are accurate, complete, and compliant with grant requirements and federal regulations before they are submitted to the funding agency. This form will be filed in the project folder.
FAC accepted this audit on September 30, 2024 — management decision was due March 30, 2025.
The Organization claimed approximately $150,000 in payroll charges for reimbursement under its major program using an estimate of grant time developed when the grant was applied for. The Organization has deemed this budget estimate to be reasonable with how the employees working on the grant spent their time, however there is no formal documentation of the actual time and effort of these employees. The Organization does review this and no employee charges more than 100% of their time to any federal grant. Cause: The Organization does not prepare personnel activity reports or any other form of time and effort documentation; it uses budget estimates considered by those within the Organization who write the grants. Effect: The Organization is using budget estimates to charge time for employees to its federal grants. If the Organization were to track actual time or conduct a time study, the actual amount charged may be different than the amounts currently charged. Since actual time is not tracked, it is not possible to quantify this amount. The Organization believes that the allocation percentages in the budget approximate actual time spent, and the allocations are reviewed and updated by management periodically. Recommendation: The Organization should track actual time spent on grants and consider preparing personnel activity reports for all employees that charge time to federal grants. This documentation serves as evidence of actual time spent by employees on federally funded grant projects. Management response: The Organization will conduct quarterly time studies by position and make adjustments to allocations as time spent deviates from the most recent time study or original budget.
Show full finding ▾Hide full finding ▴Criteria: Title 2, Subpart E – Cost Principles Section 200.430 contains the rules for compensation- personal services relative to the allowable cost requirement of the Organization’s major grant. The standards for documentation of personnel expenses require a process for reviewing after-the-fact interim charges made to a federal award based on budget estimates. Condition: The Organization claimed approximately $150,000 in payroll charges for reimbursement under its major program using an estimate of grant time developed when the grant was applied for. The Organization has deemed this budget estimate to be reasonable with how the employees working on the grant spent their time, however there is no formal documentation of the actual time and effort of these employees. The Organization does review this and no employee charges more than 100% of their time to any federal grant. Cause: The Organization does not prepare personnel activity reports or any other form of time and effort documentation; it uses budget estimates considered by those within the Organization who write the grants. Effect: The Organization is using budget estimates to charge time for employees to its federal grants. If the Organization were to track actual time or conduct a time study, the actual amount charged may be different than the amounts currently charged. Since actual time is not tracked, it is not possible to quantify this amount. The Organization believes that the allocation percentages in the budget approximate actual time spent, and the allocations are reviewed and updated by management periodically. Recommendation: The Organization should track actual time spent on grants and consider preparing personnel activity reports for all employees that charge time to federal grants. This documentation serves as evidence of actual time spent by employees on federally funded grant projects. Management response: The Organization will conduct quarterly time studies by position and make adjustments to allocations as time spent deviates from the most recent time study or original budget.
The Organization will conduct quarterly time studies by position and make adjustments to allocations as time spent deviates from the most recent time study or original budget. We will utilize our outsourced accounting firm to assist in preparing a time study template and will utilize our audit firm to confirm these time studies meet Uniform Guidance Requirements.
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