EIN: 474893498
UEI: UUY2F5RYN1J7
Audited by: Carr, Rigs & Ingram, LLC
Oversight agency: 66 [Environmental Protection Agency]
View federal awards & risk assessment →
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 22, 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 November 22, 2025 (282 days ago).
What is a management decision? →The Federal Financial Report Standard Form 425 was submitted late to the Environmental Protection Agency on March 10, 2025. Cause: The Environmental Protection Agency had informed the Council that these reports were only due at closeout of the grant; therefore, the Council did not submit these reports. However, the Office of Inspector General (OIG) stated that this was not the correct procedure. As a result of the OIG's EPA audit, the Council filed these reports on March 10, 2025 with the EPA to be in compliance. Effect: Potential for unintended errors to occur without being immediately identified and corrected. The Council was not in compliance with the Uniform Guidance and the National Estuary Program. Questioned Costs: None. Perspective: All of the reports identified above were not reviewed. Recommendation: The Chief Operating Officer should obtain in writing any adjustments or clarifications to the grant awards to ensure the requested reports are prepared and reviewed. Management Response: EPA has never requested the SF425 (Federal Financial Reporting Form) from year’s prior and we were told verbally that we were only required to submit them at grant closeout. During a current EPA OIG audit, we were informed that the procedural process we were following was incorrect and that yearly reports were required to be submitted. To bring the IRL Council back into compliance with all federal awards, the Chief Operating Officer completed the FY 2024 forms and submitted them to EPA on March 10, 2025.
Show full finding ▾Hide full finding ▴MW 2024‐001 REPORTING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Criteria: Per 2 CFR 200.303, non‐Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance and the terms and conditions outlined by the Environmental Protection Agency. EPA recipients must submit the Federal Financial Report (SF‐425) at least annually. EPA recipients must submit the SF‐425 no later than 90 calendar days for annual reports. Final reports are due no later than 120 calendar days after the end date of the period of performance of the award. Condition: The Federal Financial Report Standard Form 425 was submitted late to the Environmental Protection Agency on March 10, 2025. Cause: The Environmental Protection Agency had informed the Council that these reports were only due at closeout of the grant; therefore, the Council did not submit these reports. However, the Office of Inspector General (OIG) stated that this was not the correct procedure. As a result of the OIG's EPA audit, the Council filed these reports on March 10, 2025 with the EPA to be in compliance. Effect: Potential for unintended errors to occur without being immediately identified and corrected. The Council was not in compliance with the Uniform Guidance and the National Estuary Program. Questioned Costs: None. Perspective: All of the reports identified above were not reviewed. Recommendation: The Chief Operating Officer should obtain in writing any adjustments or clarifications to the grant awards to ensure the requested reports are prepared and reviewed. Management Response: EPA has never requested the SF425 (Federal Financial Reporting Form) from year’s prior and we were told verbally that we were only required to submit them at grant closeout. During a current EPA OIG audit, we were informed that the procedural process we were following was incorrect and that yearly reports were required to be submitted. To bring the IRL Council back into compliance with all federal awards, the Chief Operating Officer completed the FY 2024 forms and submitted them to EPA on March 10, 2025.
MW 2024‐001 REPORTING Recommendation: The Chief Operating Officer should obtain in writing any adjustments or clarifications to the grant awards to ensure the requested reports are prepared and reviewed. Management’s Response: EPA has never requested the SF425 (Federal Financial Reporting Form) from year’s prior and we were told verbally that we were only required to submit them at grant closeout. During a current EPA OIG audit, we were informed that the procedural process we were following was incorrect and that yearly reports were required to be submitted. To bring the IRL Council back into compliance with all federal awards, the Chief Operating Officer completed the FY 2024 forms and submitted them to EPA on March 10, 2025. Responsible Party: Daniel Kolodny, Chief Operating Officer Anticipated Completion Date: Remedial action completed on March 10, 2025.
The Council did not have a process in place to verify that subrecipients and vendors for covered transactions were not suspended or debarred. Cause: Management was not aware of this procurement requirement. Effect: The Council could inadvertently enter a covered transaction with a suspended or debarred party, resulting in the disallowance of payments made to that party as eligible costs under the Federal program. Questioned Costs: None. Perspective: Many of the subawards made by the Council were to other local governments or universities, which are entities unlikely to be suspended or debarred. As part of our compliance testing, we tested a sample of subrecipients and vendors for suspension and debarment, noting no exceptions. Recommendation: We recommend the Council continue with the controls that were implemented in late 2024 to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. As the control was not in place for the majority of 2024, it is a repeat finding. Management Response: The IRL Council amended its Operating Procedures following the FY 2023 finding to include suspension and debarment procedures into procurement methods for activities that are federally funded. The IRL Council Chief Operating Officer, immediately checked all current vendors for compliance within SAM.gov and all new or amended agreements have since been checked in SAM.gov for compliance. As noted by Carr, Riggs, and Ingram there were no instances of exception in their testing. Due to the timing of the FY 2023 finding, FY 2024 would also be considered a finding regardless of any corrective action taken.
Show full finding ▾Hide full finding ▴SD 2024‐002 SUSPENSION AND DEBARMENT United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. Pursuant to 2 CFR section 180.300, the Council may not contract with or make subawards to parties that are identified as being suspended or debarred by the Federal Government. The Council must verify the parties’ eligibility to receive payment from a program funded by a Federal grant prior to entering a covered transaction (as defined in 2 CFR section 180.220). Condition: The Council did not have a process in place to verify that subrecipients and vendors for covered transactions were not suspended or debarred. Cause: Management was not aware of this procurement requirement. Effect: The Council could inadvertently enter a covered transaction with a suspended or debarred party, resulting in the disallowance of payments made to that party as eligible costs under the Federal program. Questioned Costs: None. Perspective: Many of the subawards made by the Council were to other local governments or universities, which are entities unlikely to be suspended or debarred. As part of our compliance testing, we tested a sample of subrecipients and vendors for suspension and debarment, noting no exceptions. Recommendation: We recommend the Council continue with the controls that were implemented in late 2024 to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. As the control was not in place for the majority of 2024, it is a repeat finding. Management Response: The IRL Council amended its Operating Procedures following the FY 2023 finding to include suspension and debarment procedures into procurement methods for activities that are federally funded. The IRL Council Chief Operating Officer, immediately checked all current vendors for compliance within SAM.gov and all new or amended agreements have since been checked in SAM.gov for compliance. As noted by Carr, Riggs, and Ingram there were no instances of exception in their testing. Due to the timing of the FY 2023 finding, FY 2024 would also be considered a finding regardless of any corrective action taken.
SD 2024‐002 SUSPENSION AND DEBARMENT Recommendation: We recommend the Council continue with the controls that were implemented in late 2024 to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. As the control was not in place for the majority of 2024, it is a repeat finding. Management’s Response: The IRL Council amended its Operating Procedures following the FY 2023 finding to include suspension and debarment procedures into procurement methods for activities that are federally funded. The IRL Council Chief Operating Officer, immediately checked all current vendors for compliance within SAM.gov and all new or amended agreements have since been checked in SAM.gov for compliance. As noted by Carr, Riggs, and Ingram there were no instances of exception in their testing. Due to the timing of the FY 2023 finding, FY 2024 would also be considered a finding regardless of any corrective action taken. Anticipated Completion Date: Remedial action completed on December 31, 2024.
2023-003
The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
Show full finding ▾Hide full finding ▴SD 2024‐003 SUBRECIPIENT MONITORING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes all requirements imposed by the pass‐through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass‐through entity imposes on the subrecipient in order for the pass‐through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
SD 2024‐003 SUBRECIPIENT MONITORING Recommendations: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management’s Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring. Responsible Party: Daniel Kolodny, COO Anticipated Completion Date: June 1, 2025.
2023-004
FAC accepted this audit on August 26, 2024 — management decision was due February 26, 2025.
On December 19, 2022 the grantee drew down their entire award of $909,800, but only $300,000 was for reimbursable expenses. The remaining $609,800 was an advance which is not permitted under the award terms or Uniform Guidance. The erroneous advance was identified by the grantor and returned by the Council on December 29, 2022. Cause: Council management misunderstood the award terms and the allowability of advances. Effect: Draws of funds in excess of amounts needed for actual and immediate cash requirements can result in the return of funds. Questioned Costs: None. Perspective: During our testing, we did not note any other instances in which funds were drawn on an advance basis, in excess of costs already incurred by the Council. The Council misunderstood guidance from the grantor, which led to the draw down of funds in advance of current needs. Recommendation: Management should obtain clarification in writing from the grantor on guidance outside of the established procedures to prevent future misunderstandings.
Show full finding ▾Hide full finding ▴2023-001 CASH MANAGEMENT U.S. Department of Environmental Protection ALN 66.456 – National Estuary Program Federal Award ID Number: 4T-02D39922 2023 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. As required by 2 CFR 200.305(b), grant recipients may only draw funds for the minimum amounts needed for actual and immediate cash requirements to pay employees, contractors, subrecipients or to satisfy other obligations for allowable costs under the grant agreement. Disbursements within five (5) business days of the drawdown are deemed to comply with this requirement. Condition: On December 19, 2022 the grantee drew down their entire award of $909,800, but only $300,000 was for reimbursable expenses. The remaining $609,800 was an advance which is not permitted under the award terms or Uniform Guidance. The erroneous advance was identified by the grantor and returned by the Council on December 29, 2022. Cause: Council management misunderstood the award terms and the allowability of advances. Effect: Draws of funds in excess of amounts needed for actual and immediate cash requirements can result in the return of funds. Questioned Costs: None. Perspective: During our testing, we did not note any other instances in which funds were drawn on an advance basis, in excess of costs already incurred by the Council. The Council misunderstood guidance from the grantor, which led to the draw down of funds in advance of current needs. Recommendation: Management should obtain clarification in writing from the grantor on guidance outside of the established procedures to prevent future misunderstandings.
2023-001 CASH MANAGEMENT Recommendation: The IRL Council should obtain clarification in writing from the grantor on guidance outside of the established procedures to prevent future misunderstandings. Management’s Response: Initial discussions with EPA staff regarding fiscal management of the funds from the Bipartisan Infrastructure Law (BIL) suggested that management of the cash for the BIL award was different than the Section 320 grant award. During these discussions, cash flow was brought up as a possible concern by IRL Council staff. EPA staff initially indicated that the grant funds were not reimbursable and that all funds would be available as soon as an award was made. The Council was not made aware that the RAIN polices would be in effect for BIL funds. The Council interpreted EPA correspondences as authorization to withdraw funds immediately upon receiving the award. Upon making the draw, EPA provided the IRL Council with clarifying information with regards to the RAIN policy. The IRL Council responded quickly to this new information and the appropriate amount of funds were returned in a timely manner. The EPA was satisied with the corrective response and outcome. The IRL Council will continue to manage all EPA federal grants as a reimbursable grant award to ensure the RAIN policy is followed correctly. For any other Federal agency grants that may be awarded, strict adherence to that agency’s policies for treasury draws will be made. Responsible Party: Daniel Kolodny, Chief Operating Officer
The grantor identified payments made to a subrecipient for which the solicitation was held open for less than 30 days, prompting the grantor to ask the Council to replace those expenditures with other grant-eligible expenditures. Cause: Management was not aware of this requirement. Effect: The Council reclassified $48,120 of expenditures to be funded by other revenue sources and recorded $48,120 of deferred revenue that will be recognized in fiscal year 2024 when payments are made to the new subrecipient. Questioned Costs: None. Perspective: In our sample of procurements tested, we did not identify any other instances of non-compliance. Recommendation: Management should review all procurements for compliance with award terms, Uniform Guidance, and Federal Acquisition Regulations prior to submitting issuing the purchase order or subrecipient contract.
Show full finding ▾Hide full finding ▴2023-002 PROCUREMENT U.S. Department of Environmental Protection ALN 66.456 – National Estuary Program Federal Award ID Number: 4T-02D39922 2023 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. As stated in FAR Section 5.203, Publicizing and Response Time, the Council is required to allow for at least a 30-day response time for the receipt of bids or proposals from the date of issuance of the solicitation. Condition: The grantor identified payments made to a subrecipient for which the solicitation was held open for less than 30 days, prompting the grantor to ask the Council to replace those expenditures with other grant-eligible expenditures. Cause: Management was not aware of this requirement. Effect: The Council reclassified $48,120 of expenditures to be funded by other revenue sources and recorded $48,120 of deferred revenue that will be recognized in fiscal year 2024 when payments are made to the new subrecipient. Questioned Costs: None. Perspective: In our sample of procurements tested, we did not identify any other instances of non-compliance. Recommendation: Management should review all procurements for compliance with award terms, Uniform Guidance, and Federal Acquisition Regulations prior to submitting issuing the purchase order or subrecipient contract.
PROCUREMENT 2023-002 PROCUREMENT Recommendation: The IRL Council should review all procurements for compliance with award terms, Uniform Guidance, and Federal Acquisition Regulations prior to submitting issuing the purchase order or subrecipient contract. Management’s Response: The IRL Council Operating Procedures Manual lists 14 days as the minimum response time for competitive procurement of services. However, during an EPA review of IRL Council procurement practices, a single instance was found to be less than 30 days per federal procurement standards. In a letter to EPA dated May 3, 2024, the IRL Council proposed a corrective action that would replace the contractor that had been procured less than the 30-day response time with one that had been procured consistent with federal policy and defer revenues to FY 2024 for the new project. The Corrective action was approved by EPA by issuance of Award 4T-02D39922 modification 3 on June 16, 2024. The IRL Council will amend its Operating Procedures Manual to ensure that all future procurements, whether federally funded or otherwise, require a minimum 30-day response time. Responsible Parties: Daniel Kolodny, Chief Operating Officer and Duane De Freese, Executive Director Anticipated Completion: November 15, 2024
The Council did not have a process in place to verify that subrecipients and vendors for covered transactions were not suspended or debarred. Cause: Management was not aware of this procurement requirement. Effect: The Council could inadvertently enter a covered transaction with a suspended or debarred party, resulting in the disallowance of payments made to that party as eligible costs under the Federal program. Questioned Costs: None. Perspective: Many of the subawards made by the Council were to other local governments or universities, which are entities unlikely to be suspended or debarred. As part of our compliance testing, we tested a sample of subrecipients and vendors for suspension and debarment, noting no exceptions. Recommendation: We recommend the Council implement controls to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. We suggest the Council include a clause in the subrecipient contracts stating the contractor is not suspended or debarred. This clause would need to be included in any modifications to the contracts that provide for additional funding. For other covered transactions, the Council should document their verification of the vendor’s status on the System for Award Management (SAM) Exclusions website.
Show full finding ▾Hide full finding ▴2023-003 SUSPENSION AND DEBARMENT U.S. Department of Environmental Protection ALN 66.456 – National Estuary Program Federal Award ID Number: 4T-02D39922 and CE-00D90119 2023 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Pursuant to 2 CFR section 180.300, the Council may not contract with or make subawards to parties that are identified as being suspended or debarred by the Federal Government. The Council must verify the parties’ eligibility to receive payment from a program funded by a Federal grant prior to entering a covered transaction (as defined in 2 CFR section 180.220). Condition: The Council did not have a process in place to verify that subrecipients and vendors for covered transactions were not suspended or debarred. Cause: Management was not aware of this procurement requirement. Effect: The Council could inadvertently enter a covered transaction with a suspended or debarred party, resulting in the disallowance of payments made to that party as eligible costs under the Federal program. Questioned Costs: None. Perspective: Many of the subawards made by the Council were to other local governments or universities, which are entities unlikely to be suspended or debarred. As part of our compliance testing, we tested a sample of subrecipients and vendors for suspension and debarment, noting no exceptions. Recommendation: We recommend the Council implement controls to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. We suggest the Council include a clause in the subrecipient contracts stating the contractor is not suspended or debarred. This clause would need to be included in any modifications to the contracts that provide for additional funding. For other covered transactions, the Council should document their verification of the vendor’s status on the System for Award Management (SAM) Exclusions website.
2023-003 SUSPENSION AND DEBARMENT Recommendations: CRI recommends the IRL Council implement controls to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. CRI suggests the Council include a clause in the subrecipient contracts stating the contractor is not suspended or debarred. This clause would need to be included in any modifications to the contracts that provide for additional funding. For other covered transactions, the Council should document their verification of the vendor’s status on the System for Award Management (SAM) Exclusions website. Management’s Response: The IRL Council will establish the following policies and controls to monitor and ensure compliance with SAM.gov requirements. • The IRL Council’s procurement process for federally funded projects will include an afidavit where applicants attach their SAM.gov proof at the time of proposal submission. • The IRL Council staff will review all proposal submissions to include SAM.gov review and provide screenshots of when the information was checked. These screenshots will be saved in the procurement file. • Current vendors and/or recipients of federal funds will be checked for SAM.gov compliance on an annual basis. The annual checks will be screenshot and uploaded into the vendor files. Vendor files will be updated accordingly with the date of the Sam.gov check by Finance. The annual compliance check will be a standard part of the end-of fiscal year closeout process. • Current vendors working on federally funded projects will be checked for SAM.gov compliance at the time of any change order, amendment, or contract adjustment that is requested. At the time of the change order, amendment or contract adjustment Sam.gov compliance will be checked and a Sam.gov screenshot will be uploaded into the vendor files. Responsible Party: Daniel Kolodny, Chief Operating Officer Anticipated Completion Date: December 31, 2024.
Subrecipient awards did not consistently include the required language including the ALN and the pass-through of Federal award requirements. Additionally, the Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: In some cases, the Council used the contract template for a subaward for a state financial assistance program rather than for a Federal award and, as a result, required information and language was missing from the contract. Further, the Council did not update its procedures over subrecipient monitoring to include follow-up of any deficiencies pertaining to the subrecipients’ use of the Federal funding detected through audits, on-site reviews or other means. Effect: Without the required language in the subrecipient contracts, subrecipients may not have the information necessary for them to establish appropriate controls over compliance required by the Federal award and to appropriately identify the Federal award and related expenditures on their Schedule of Expenditures of Federal Awards, if applicable. Additionally, without the monitoring of the results of audits and on-site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. Required language was not included in two of the eight subrecipient awards tested. For one of these two contracts, the contract was originally funded with local share and applied to the Federal award only after the grantor modified the award to allow the Council to apply pre-award expenditures to the grant program. Recommendation: The Council should review existing subrecipient agreements and amend any contracts that may be missing the required Uniform Guidance language. Management should ensure that future contracts use the template appropriate for the funding source (Federal, state or non-grant funded). To ensure compliance with the requirements for subrecipient monitoring, the Council should establish processes to (1) review and reports required by the subrecipient contract; (2) document the Council’s follow-up on action taken by the subrecipient on any deficiencies detected through audits, on-site reviews or other means; and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient.
Show full finding ▾Hide full finding ▴2023-004 SUBRECIPIENT MONITORING U.S. Department of Environmental Protection ALN 66.456 – National Estuary Program Federal Award ID Number: 4T-02D39922 and CE-00D90119 2023 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes the requirement for the subaward contract to include information such as the federal award identification (Assistance Listing Number (ALN) and name of the federal program), all requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: Subrecipient awards did not consistently include the required language including the ALN and the pass-through of Federal award requirements. Additionally, the Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: In some cases, the Council used the contract template for a subaward for a state financial assistance program rather than for a Federal award and, as a result, required information and language was missing from the contract. Further, the Council did not update its procedures over subrecipient monitoring to include follow-up of any deficiencies pertaining to the subrecipients’ use of the Federal funding detected through audits, on-site reviews or other means. Effect: Without the required language in the subrecipient contracts, subrecipients may not have the information necessary for them to establish appropriate controls over compliance required by the Federal award and to appropriately identify the Federal award and related expenditures on their Schedule of Expenditures of Federal Awards, if applicable. Additionally, without the monitoring of the results of audits and on-site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. Required language was not included in two of the eight subrecipient awards tested. For one of these two contracts, the contract was originally funded with local share and applied to the Federal award only after the grantor modified the award to allow the Council to apply pre-award expenditures to the grant program. Recommendation: The Council should review existing subrecipient agreements and amend any contracts that may be missing the required Uniform Guidance language. Management should ensure that future contracts use the template appropriate for the funding source (Federal, state or non-grant funded). To ensure compliance with the requirements for subrecipient monitoring, the Council should establish processes to (1) review and reports required by the subrecipient contract; (2) document the Council’s follow-up on action taken by the subrecipient on any deficiencies detected through audits, on-site reviews or other means; and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient.
2023-004 SUBRECIPIENT MONITORING Recommendations: The Council should review existing subrecipient agreements and amend any contracts that may be missing the required Uniform Guidance language. Management should ensure that future contracts use the template appropriate for the funding source (Federal, state or non-grant funded). To ensure compliance with the requirements for subrecipient monitoring, the Council should establish processes to (1) review and reports required by the subrecipient contract; (2) document the Council’s follow-up on action taken by the subrecipient on any deficiencies detected through audits, on-site reviews or other means; and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient. Management’s Response: The timing of the federal award received from the EPA and the allocation of funds to certain projects approved in the workplan, resulted in several projects that had been completed and were originally funded through other revenue sources such as state license plate funds. The award time frame positioned these projects to be considered allowable pre-award expenses, however due to the timing of completion and award issuance, the agreements could not be amended to add the required federal subrecipient Uniform Guidance Language. The IRL Council will establish the following controls and implement actions to ensure subrecipient compliance: • Review all projects and activities currently allocated and funded by federal sources to insure the Uniform Guidance Language is in place with their respective agreements. For any agreement still in force, language will be amended immediately. For any agreement completed, the subrecipient shall be notified of the source of funds including the federal award identifier and amount of funding pertaining to that agreement to allow for subrecipient audit compliance. • All future subrecipient agreements funded by federal sources will not be executed until the respective federal award is in place and the Uniform Guidance Language is included. • All future and amended federally funded agreements will include language requesting audit reports and any finding with respect to the expenditure of federal funds. • The IRL Council will issue a written decision for audit findings pertaining to the Federal award provided to the subrecipient. Responsible Party: Daniel Kolodny, Chief Operating Officer Anticipated Completion Date: December 31, 2024.
FAC accepted this audit on May 6, 2021 — management decision was due November 6, 2021.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Browse other Single Audit organizations in Florida →
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and filing records.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
