EIN: 521257425
UEI: HB7NVH9YCEH1
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 20, 2026. 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 February 20, 2027 (177 days from today).
What is a management decision? →Soliya reported program expenditures on the SEFA in excess of the amount permitted under the federal award. Specifically, program costs were recorded based on amounts submitted for reimbursement rather than amounts ultimately determined to be eligible and reimbursable under the award. As a result, federal expenditure reported on the SEFA submitted to the auditors was overstated by $6,015. The SEFA presented herein was adjusted to reflect the correct amount of eligible expenditures. Cause: Soliya did not maintain effective controls over the review of grant expenditures and SEFA reporting to ensure that only eligible grant costs were reported as federal expenditures. In addition, management did not adequately identify, track, and exclude costs not permitted under the award from amounts reported on the SEFA. Effect: As a result, the SEFA included expenditures exceeding the amount permitted under the award, causing federal expenditures to be overstated. This resulted in inaccurate federal reporting and increased the risk of noncompliance with applicable award requirements and Uniform Guidance cost principles. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: Soliya should strengthen controls over grant accounting and SEFA preparation to ensure costs not permitted under the federal award are identified, reviewed, and excluded from federal expenditures reported on the SEFA. This should include procedures to review costs for compliance with award requirements, reconcile grant activity to supporting documentation, and verify that only eligible expenditures are reported. Views of Responsible Officials: Management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the instances of noncompliance.
Show full finding ▾Hide full finding ▴Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Uniform Guidance in 2 CFR Section 200.302(a), Financial Management, states that each state must expend and account for the federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other nonfederal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award.Condition:Soliya reported program expenditures on the SEFA in excess of the amount permitted under the federal award. Specifically, program costs were recorded based on amounts submitted for reimbursement rather than amounts ultimately determined to be eligible and reimbursable under the award. As a result, federal expenditure reported on the SEFA submitted to the auditors was overstated by $6,015. The SEFA presented herein was adjusted to reflect the correct amount of eligible expenditures. Cause: Soliya did not maintain effective controls over the review of grant expenditures and SEFA reporting to ensure that only eligible grant costs were reported as federal expenditures. In addition, management did not adequately identify, track, and exclude costs not permitted under the award from amounts reported on the SEFA. Effect: As a result, the SEFA included expenditures exceeding the amount permitted under the award, causing federal expenditures to be overstated. This resulted in inaccurate federal reporting and increased the risk of noncompliance with applicable award requirements and Uniform Guidance cost principles. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: Soliya should strengthen controls over grant accounting and SEFA preparation to ensure costs not permitted under the federal award are identified, reviewed, and excluded from federal expenditures reported on the SEFA. This should include procedures to review costs for compliance with award requirements, reconcile grant activity to supporting documentation, and verify that only eligible expenditures are reported. Views of Responsible Officials: Management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the instances of noncompliance.
We will strengthen our controls around reporting of expenses on consolidated SEFA report for our subsidiary and related organizations. We will exclude expenses that exceed the total budget and recommend posting adjustments in the books so that these are not included in grant expenses.
FAC accepted this audit on August 21, 2025 — management decision was due February 21, 2026.
The internal controls implemented to ensure the timely submission of the quarterly financial report and quarterly performance report within 30 days after the end of the reporting period did not function as intended. During our testing of reporting compliance, BDO noted that the following reports were not submitted on time due to staff unavailability for preparation and submission: • One financial report (quarter 1) for ALN 19.801 • One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001 Cause: The Organization's internal controls, designed to ensure compliance with reporting regulations, failed to function as intended. As a result, they did not effectively address the requirement to submit financial reports in a timely manner and meet the established deadlines. Effect: The failure of the Organization's internal controls to operate as designed has led to delays in the submission of the required financial reports, potentially resulting in non-compliance with the requirements of CFR Section §200.328(c). Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend that management evaluate the current controls to confirm they are strong and capable of effectively meeting the requirements for timely financial report submission. Additionally, management should ensure there are sufficient staff members available to prepare and submit the reports. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴2024-001 Internal Control over Compliance and Compliance with Reporting Criteria: CFR Section §200.328(c) states in part: “The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period.” Condition: The internal controls implemented to ensure the timely submission of the quarterly financial report and quarterly performance report within 30 days after the end of the reporting period did not function as intended. During our testing of reporting compliance, BDO noted that the following reports were not submitted on time due to staff unavailability for preparation and submission: • One financial report (quarter 1) for ALN 19.801 • One financial report (quarter 2) and one programmatic report (quarter 1) for ALN 98.001 Cause: The Organization's internal controls, designed to ensure compliance with reporting regulations, failed to function as intended. As a result, they did not effectively address the requirement to submit financial reports in a timely manner and meet the established deadlines. Effect: The failure of the Organization's internal controls to operate as designed has led to delays in the submission of the required financial reports, potentially resulting in non-compliance with the requirements of CFR Section §200.328(c). Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend that management evaluate the current controls to confirm they are strong and capable of effectively meeting the requirements for timely financial report submission. Additionally, management should ensure there are sufficient staff members available to prepare and submit the reports. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
We are fully committed to meet our reporting obligations for all of our donors. During 2024, the federal government had changed its login process to Payment Management System (PMS) and that resulted in access problems for our users at that time. Replacement account activation was gradual and took some time before we got the access to all the projects on PMS. We are already tracking both financial and narrative reports from the signing stage of projects, and most of the reports are prepared on time. Going forward, we will further strengthen our backup plans for submission of reports, both online and through email. We will develop a backup plan and strengthen delegation plans for each region during the times when the primary contact is not available
During our subrecipient testing for the major program, we were unable to verify the submission dates of the FFATA Report via the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) website. The Organization was unable to provide evidence of submission, lacking retained documentation that evidenced the actual submission dates of the FFATA reports. Cause: It was determined that the absence of supporting documentation was a result of the FSRS system migration to SAM.gov. The Organization neglected to keep documentation to support submission. Effect: The inability to verify the submission dates of the FFATA reports due to missing documentation may lead to compliance issues with federal reporting requirements. Questioned Costs: None. Context: This is a condition identified per review of the Organization’s compliance with the reporting provisions of the Uniform Guidance. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: BDO recommends that the Organization establish a comprehensive system for retaining submission records, including timestamps and confirmation receipts, to ensure all future FFATA report submissions are verifiable. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and Transparency Act (FFATA), the department is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. The non-Federal entity or Federal agency must report each obligating action described in paragraph a.1. of this award term to http://www.fsrs.gov. In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting Subaward and Executive Compensation Information. Condition: During our subrecipient testing for the major program, we were unable to verify the submission dates of the FFATA Report via the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) website. The Organization was unable to provide evidence of submission, lacking retained documentation that evidenced the actual submission dates of the FFATA reports. Cause: It was determined that the absence of supporting documentation was a result of the FSRS system migration to SAM.gov. The Organization neglected to keep documentation to support submission. Effect: The inability to verify the submission dates of the FFATA reports due to missing documentation may lead to compliance issues with federal reporting requirements. Questioned Costs: None. Context: This is a condition identified per review of the Organization’s compliance with the reporting provisions of the Uniform Guidance. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: BDO recommends that the Organization establish a comprehensive system for retaining submission records, including timestamps and confirmation receipts, to ensure all future FFATA report submissions are verifiable. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Due to lack of submission date field in Sam.gov system, we agree that we will add an alternate process to document timely submission for subawards reports on Sam.gov. This will be done by downloading the PDF report and confirming through email from Senior compliance officer.
During our compliance testing of the procurement compliance requirement, with respect to ALN # 19.345, for one (1) sample of eleven samples selected for testing, the Organization amended the contract to extend the end date and adjust pricing before verifying and documenting that the vendor was not suspended or debarred. For ALN #19.501, for two (2) samples of the three samples tested, the Organization signed amendments in November 2023 and July 2024, before verifying and documenting that the vendor was not suspended or debarred. The last verification was performed in May 2022. Cause: The Organization did not perform proper suspension and debarment validations when the amendment to the agreement was signed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: None. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a random sampling method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2023- 003 in the 2023 Schedule of Findings and Questioned Costs. Recommendation: We recommend that management strengthen the procurement policy to align with the Procurement Procedures outlined in the Uniform Administrative Requirements. Additionally, we suggest providing all staff with additional training on this policy to ensure compliance in the future. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our compliance testing of the procurement compliance requirement, with respect to ALN # 19.345, for one (1) sample of eleven samples selected for testing, the Organization amended the contract to extend the end date and adjust pricing before verifying and documenting that the vendor was not suspended or debarred. For ALN #19.501, for two (2) samples of the three samples tested, the Organization signed amendments in November 2023 and July 2024, before verifying and documenting that the vendor was not suspended or debarred. The last verification was performed in May 2022. Cause: The Organization did not perform proper suspension and debarment validations when the amendment to the agreement was signed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: None. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a random sampling method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2023- 003 in the 2023 Schedule of Findings and Questioned Costs. Recommendation: We recommend that management strengthen the procurement policy to align with the Procurement Procedures outlined in the Uniform Administrative Requirements. Additionally, we suggest providing all staff with additional training on this policy to ensure compliance in the future. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
We have conducted trainings of our staff and rolled out Global procurement system during 2024 and it has resulted in higher compliance in procurement and specifically vendor screenings. Current instances are coming from the period before rolling out of Global procurement system. we will make sure we update vetting process for vendors coming from before rolling out of Global Procurement System.
2023-003
FAC accepted this audit on September 30, 2024 — management decision was due March 30, 2025.
We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-002 Internal Control over Compliance and Compliance with Cash Management Contact: Karishma Borgohain-Menta Title: Senior Manager, HQ Accounting Phone Number: (202) 777-2297 Estimated Completion Date: December 31, 2024 Corrective Action Plan: Majority of the projects with the US government where search is prime implementer, are on monthly drawdown based on field office projections. We typically spend these funds within a reasonable time. However, Projects where SFCG is not the prime recipient have quarterly advance arrangements with Prime recipients and therefore liquidation typically takes approximately the same time. Search have not kept that money in interest bearing account. Guidance identified by the auditors is well noted and we will convert our non-interest-bearing accounts into interest-bearing accounts. Any interest earned will be reported as program income in the respective award.
During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Contact: Wajid Ali Title: Senior Manager Internal Policies and Compliance Phone Number: (202) 777-2297 Estimated Completion Date: June 30, 2025 Corrective Action Plan: We Agree with the finding that background checks were done after the agreement date and before payment in few cases, during late 2023 and early 2024, we have rolled out a Global Procurement system (google sheet based internal workflow package) that is designed to mandate procurement steps in a systematic manner. This is already helping us streamline procurement in major countries. This system is planned to be fully rolled out by the Second Quarter of 2025 and is currently implemented in about half of the countries and 4 other countries will be included by end of 2024. This will enable us to complete the background checks before entering any commitment.
2022-004
FAC accepted this audit on September 25, 2023 — management decision was due March 25, 2024.
The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management?s preparation of the SEFA, BDO identified two awards whose assistance listing number was changed by the federal entity in award amendments issued prior to December 31, 2022. Management failed to update the assistance listing number for the awards within the SEFA to address the award modifications. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not fully operate as designed. The Organization did not adequately review award modifications for changes to existing awards. Effect: The SEFA initially provided to BDO resulted in incorrect major program selection as prescribed under the Unform Guidance. During the review of the award agreements, BDO identified the assistance listing numbers for the two awards had been modified. This issue resulted in a different major program selection once the SEFA was updated to reflect the correct assistance listing numbers. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management to continue to focus on training for both preparer and reviewers of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section ?200.510(b). This will ensure that the SEFA provides all relevant information as proscribed.
Show full finding ▾Hide full finding ▴2022-002 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Numbers: Direct Award Numbers Award Period SLMAQM20CA2264 September 28, 2020 through March 29, 2024 SLMAQM20GR2364 September 28, 2020 through September 30, 2024 Criteria: CFR Section ?200.510(b) states in part: ?The auditee must also 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 CFR Section ?200.502 Basis for determining Federal awards expended.? The schedule must provide total Federal awards expended for each individual Federal program. In accordance with ?200.302 Financial Management, a non-federal entity?s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management?s preparation of the SEFA, BDO identified two awards whose assistance listing number was changed by the federal entity in award amendments issued prior to December 31, 2022. Management failed to update the assistance listing number for the awards within the SEFA to address the award modifications. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not fully operate as designed. The Organization did not adequately review award modifications for changes to existing awards. Effect: The SEFA initially provided to BDO resulted in incorrect major program selection as prescribed under the Unform Guidance. During the review of the award agreements, BDO identified the assistance listing numbers for the two awards had been modified. This issue resulted in a different major program selection once the SEFA was updated to reflect the correct assistance listing numbers. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management to continue to focus on training for both preparer and reviewers of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section ?200.510(b). This will ensure that the SEFA provides all relevant information as proscribed.
We agree with the finding, This was due to the modification of assistance listing number for two awards. We will strengthen our controls for review of all grant documents before issuing the SEFA report.
The Organization has documented expenditure policies and procedures. However, as identified below, the review and approval process did not operate as designed. The Organization?s policies are designed to ensure expenses are reviewed and approved timely to ensure proper recording in the books and records. The following errors were identified during our testing of payroll and non-payroll expenditures: ? For AL# 19.345 we tested 40 non-payroll samples and identified one error. The expense was allocated between two projects based on preliminary estimates. The preliminary budgeted expense allocation was not corrected based on the actual allocation from the underlying documentation, representing $45 in questioned costs. ? For AL# 19.415 we tested 40 non-payroll samples and identified one error. The expense was related to depreciation which requires the Organization to maintain adequate property records and take a physical inventory at least once every two years to ensure that the assets exist and are usable, used, and needed. The documentation provided to support the charge to the award was not sufficient to meet the requirements above resulting in $3,046 in questioned costs. Questioned Costs: The items above represents questioned costs totaling $3,091. Context: This is a condition identified per review of the Organization?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: The Organization has documented expenditure policies and procedures regarding the timely processing and approval of expenditures. However, as identified above, the review and approval process did not operate as designed resulting in errors noted. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major programs. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: BDO recommends that the Organization adhere to its documented policies and procedures regarding authorization final invoices and recording of expenditures and not using preliminary budgeted expense allocations.
Show full finding ▾Hide full finding ▴2022-003 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Information on the Federal Program(s): United States Department of State Assistance Listing Number: 19.345 Assistance Listing Name: International Programs to Support Democracy, Human Rights and Labor Award Number: Direct Award Number Award Period SLMAQM20GR2250 September 8, 202 through June 30, 2023 United States Department of State Assistance Listing Number: 19.415 Assistance Listing Name: Professional and Cultural Exchange Programs ? Citizen Exchanges Pass-through Award: Pass-through Entity Pass through Award Number Award Period The Aspen Institute SI_SOL4_SubR-2021 April 1, 2021 through June 30, 2023 Criteria or Specific Requirement: In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Additionally, ?200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Organization has documented expenditure policies and procedures. However, as identified below, the review and approval process did not operate as designed. The Organization?s policies are designed to ensure expenses are reviewed and approved timely to ensure proper recording in the books and records. The following errors were identified during our testing of payroll and non-payroll expenditures: ? For AL# 19.345 we tested 40 non-payroll samples and identified one error. The expense was allocated between two projects based on preliminary estimates. The preliminary budgeted expense allocation was not corrected based on the actual allocation from the underlying documentation, representing $45 in questioned costs. ? For AL# 19.415 we tested 40 non-payroll samples and identified one error. The expense was related to depreciation which requires the Organization to maintain adequate property records and take a physical inventory at least once every two years to ensure that the assets exist and are usable, used, and needed. The documentation provided to support the charge to the award was not sufficient to meet the requirements above resulting in $3,046 in questioned costs. Questioned Costs: The items above represents questioned costs totaling $3,091. Context: This is a condition identified per review of the Organization?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: The Organization has documented expenditure policies and procedures regarding the timely processing and approval of expenditures. However, as identified above, the review and approval process did not operate as designed resulting in errors noted. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major programs. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: BDO recommends that the Organization adhere to its documented policies and procedures regarding authorization final invoices and recording of expenditures and not using preliminary budgeted expense allocations.
This lapse was a result of delay in submission and approval of time charged by a consultant (operated outside of our automated time sheet controls). We will ensure the allocation is done after the actual time charge is made. We will monitor more closely and train the finance staff in our subsidiary for charging depreciation to the projects.
During our testing of compliance, we identified the following matters: ? The Organization?s subsidiary Soliya did not have a written procurement policy that complied with the federal requirements presented above. ? For three procurement samples of a total of nine items teested for AL# 19.415, management did not provide adequate supporting documentation for the procurement transaction. BDO was only provided a copy of the authorized contract between the consultant and Soliya. No other information to support compliance with federal procurement requirements was provided. Questioned Costs: Total known questioned costs are $6,656. Context: This is a condition based on testing of Soliya?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: Soliya did not adopt a written procurement policy that was compliant with the Uniform Administrative Requirements. In addition Soliya was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: We recommend management of Soliya adopt Search for Common Ground?s procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff of Soliya are trained on this policy to help ensure compliance going forward.
Show full finding ▾Hide full finding ▴Information on the Federal Program: United States Department of State Assistance Listing Number: 19.415 Assistance Listing Name: Professional and Cultural Exchange Programs ? Citizen Exchanges Pass-through Awards: Pass-through Entity Pass through Award Number Award Period The Aspen Institute SI_SOL4_SubR-2021 April 1, 2021 through June 30, 2023 The Aspen Institute SI_SOL3_SubR-2020 April 1, 2021 through June 30, 2023 Criteria or Specific Requirement: In accordance with ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in a manner providing full and open competition consistent in accordance with ?200.319 and must be performed using the appropriate procurement method as outlined in ?200.320. In accordance with ?200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135.Condition: During our testing of compliance, we identified the following matters: ? The Organization?s subsidiary Soliya did not have a written procurement policy that complied with the federal requirements presented above. ? For three procurement samples of a total of nine items teested for AL# 19.415, management did not provide adequate supporting documentation for the procurement transaction. BDO was only provided a copy of the authorized contract between the consultant and Soliya. No other information to support compliance with federal procurement requirements was provided. Questioned Costs: Total known questioned costs are $6,656. Context: This is a condition based on testing of Soliya?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: Soliya did not adopt a written procurement policy that was compliant with the Uniform Administrative Requirements. In addition Soliya was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Repeat Finding: This finding is not a repeat finding from the prior year. Recommendation: We recommend management of Soliya adopt Search for Common Ground?s procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff of Soliya are trained on this policy to help ensure compliance going forward.
We will work with Soliya management to adapt SFCG?s procurement policy or to develop their own policy for procurement that is compliant with Uniform Administrative Requirements.
During our subrecipient testing for the major programs, we determined management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during BDO?s testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization did not comply with FFATA reporting requirements as there was not a control in place to ensure FFATA reporting was completed when required by 2 CFR Part 170. Effect: Failure to comply with the FFATA requirement may out the grant funding at risk due to noncompliance under the Uniform Guidance. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2021- 003 in the 2021 schedule of findings and questioned costs. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings in arrears are immediately filed.
Show full finding ▾Hide full finding ▴Information on the Federal Program(s): United States Department of the State Assistance Listing Number: 19.345 Assistance Listing Name: International Programs to Support Democracy, Human Rights and Labor Award Number:Direct Award Number Award Period SLMAQM21GR3097 July 15, 2021 through December 31, 2022 United States Department of the State Assistance Listing Number: 19.706 Assistance Listing Name: Partnership for Regional East Africa Counterterrorism Award Number: Direct Award Number Award Period SLMAQM20CA2264 September 28, 2020 through September 30, 2024 Criteria or Specific Requirement: The Federal Funding Accountability and Transparency Act, as codified in 2 CFR Part 170, requires prime awardees awarded a federal grant to file a Federal Funding Accountability and Transparency Act (FFATA) report when the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: During our subrecipient testing for the major programs, we determined management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during BDO?s testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization did not comply with FFATA reporting requirements as there was not a control in place to ensure FFATA reporting was completed when required by 2 CFR Part 170. Effect: Failure to comply with the FFATA requirement may out the grant funding at risk due to noncompliance under the Uniform Guidance. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2021- 003 in the 2021 schedule of findings and questioned costs. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings in arrears are immediately filed.
We will make sure all FFATA reports are filed and these submissions are internally reviewed for completeness.
2021-004
FAC accepted this audit on August 24, 2022 — management decision was due February 24, 2023.
During our testing of the reporting requirements for each of the major programs, BDO identified the following: ? For one financial reporting submission out of sixteen reporting submissions tested, BDO noted the report was filed late with no approval from the granting agency. This related to grant award SBUR-SGWIPF-17-002 for major program AL# 19.801. ? For one financial reporting submission out of thirty-six reporting submissions tested, BDO noted the report was filed late with no approval from the granting agency. This related to grant award YM-13910-001 for major program AL# 98.001. ? For two financial reporting submissions out of thirty-six reporting submissions tested, management was unable to provide supporting documentation as to the submission date of the submission to validate the report was filed timely. This related to grant award 7200AA21CA00005 for major program AL# 98.001. Questioned Costs: There are no questioned costs as the items outlined above are internal control related matters. Context: This is a condition identified during the testing of financial reports. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization has controls in place to ensure timely reporting in accordance with financial and performance reporting requirements, through the review of Project Finance Managers and Regional Controllers, which is the primary control. However, this is principally a manual process and the manual controls in place to file the reports as required within the period mandated per the underlying grant agreements did not operate as designed in these instances identified. Effect: Failure to comply with financial reporting requirements impacts the Federal agency from obtaining financial information required to assess award performance on a macro level. Such noncompliance also increases the risk of loss of future awards if compliance with award terms is not met. Recommendation: In order to facilitate timely reporting and compliance with the terms and conditions of federal awards, we recommend management to ensure all reporting requirements are maintained, updated, and available in a central location, which we believe should be an IT solution that contains both evidence of approvals as well as submission. Views of Responsible Officials: Organization management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the lapse in prescribed internal controls.
Show full finding ▾Hide full finding ▴2021-002 Internal Control over Compliance and Compliance ? Reporting Information on the Federal Program(s): United States Department of the State Assistance Listing Number: 19.801 Assistance Listing Name: Office of Global Women?s Issues Pass-through Award under the Uniform Guidance Requirements: Pass-through Entity Award Number The American Bar Association SBUR-SGWIPF-17-002 United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: Foreign Assistance for Programs Overseas Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number John Snow, Inc. YM-13910-001 CDA Collaborative Learning Projects, Inc. 7200AA21CA00005 Criteria or Specific Requirement: In accordance with ?200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. ?200.328, Financial Reporting, prescribes that the non-federal entity is responsible for oversight of the operations of the federal award supported activities. The non-federal entity must monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. Monitoring by the non-federal entity must cover each program, function or activity. The non-federal entity must submit reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Condition: During our testing of the reporting requirements for each of the major programs, BDO identified the following: ? For one financial reporting submission out of sixteen reporting submissions tested, BDO noted the report was filed late with no approval from the granting agency. This related to grant award SBUR-SGWIPF-17-002 for major program AL# 19.801. ? For one financial reporting submission out of thirty-six reporting submissions tested, BDO noted the report was filed late with no approval from the granting agency. This related to grant award YM-13910-001 for major program AL# 98.001. ? For two financial reporting submissions out of thirty-six reporting submissions tested, management was unable to provide supporting documentation as to the submission date of the submission to validate the report was filed timely. This related to grant award 7200AA21CA00005 for major program AL# 98.001. Questioned Costs: There are no questioned costs as the items outlined above are internal control related matters. Context: This is a condition identified during the testing of financial reports. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization has controls in place to ensure timely reporting in accordance with financial and performance reporting requirements, through the review of Project Finance Managers and Regional Controllers, which is the primary control. However, this is principally a manual process and the manual controls in place to file the reports as required within the period mandated per the underlying grant agreements did not operate as designed in these instances identified. Effect: Failure to comply with financial reporting requirements impacts the Federal agency from obtaining financial information required to assess award performance on a macro level. Such noncompliance also increases the risk of loss of future awards if compliance with award terms is not met. Recommendation: In order to facilitate timely reporting and compliance with the terms and conditions of federal awards, we recommend management to ensure all reporting requirements are maintained, updated, and available in a central location, which we believe should be an IT solution that contains both evidence of approvals as well as submission. Views of Responsible Officials: Organization management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the lapse in prescribed internal controls.
2021-002 Internal Control over Compliance and Compliance ? Reporting Contact: Wasim Khan Title: Vice President of Finance Phone Number: (202) 777-2297 Estimated Completion Date: December 31, 2022 Corrective Action Plan: Delays in submission of reports are stand-alone instances due to non-availability of responsible staff and lapse of handing over of responsibilities. During 2021, a new Project management system called GMS is rolled out to all country offices, GMS, among other utilities, helps document and summarize the reporting requirements for individual U.S. government projects. We will look for opportunities to systematically track and follow up on these requirements to be more effective. Management is committed to make conscious efforts and investments to strengthen our controls around U.S. government reporting. For U.S. government project (award ID:7200AA21CA00005), we were required to submit reports using an online link. This link does not provide any documentary proof of submission. However, from Q2 2022 and onwards, we have instructed our Implementation teams to capture screenshots during upload and obtain the confirmation message from the U.S. government to properly document the proof of submission.
2020-003
During our testing of the subrecipient for the major program, we concluded management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during BDO?s testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization did not comply with FFATA reporting requirements as there was incorrect conclusion it was not required for the sample tested. Effect: Failure to comply with the FFATA requirement may out the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings are immediately filed. Views of Responsible Officials: Organization management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the lapse in prescribed internal controls.
Show full finding ▾Hide full finding ▴2021-003 Internal Control over Compliance and Compliance ? Subrecipient Monitoring Information on Federal Program: United States Department of the State Assistance Listing Number: 19.016 Assistance Listing Name: Iraq Assistance Program Grant Award Number under the Uniform Guidance Requirements: Direct Award Number S-LMAQM-18-CA-2097 Criteria or Specific Requirement: The Federal Funding Accountability and Transparency Act, as codified in 2 CFR Part 170, requires prime awardees awarded a federal grant to file a Federal Funding Accountability and Transparency Act (FFATA) report when the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: During our testing of the subrecipient for the major program, we concluded management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during BDO?s testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization did not comply with FFATA reporting requirements as there was incorrect conclusion it was not required for the sample tested. Effect: Failure to comply with the FFATA requirement may out the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings are immediately filed. Views of Responsible Officials: Organization management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the lapse in prescribed internal controls.
2021-003 Internal Control over Compliance and Compliance ? Subrecipient Monitoring Contact: Wasim Khan Title: Vice President of Finance Phone Number: (202) 777-2297 Estimated Completion Date: December 31, 2022 Corrective Action Plan: We have developed a focused training plan for all Regional Controllers and Regional Program Managers covering FFATA reporting requirements. These trainings are planned to be completed by Q3 2022 and we will submit all missing FFATA reports, if any, on the FFATA Subaward Reporting System by Q4 2022.
The Organization has policies in place to file annual VAT reports which are required under certain grants of the major program. During our testing, BDO identified one sample where the VAT report was not filed by the country office as no VAT had been incurred for the period. However, per Federal regulations, an annual VAT report is required regardless of balances paid during the year. The Organization has since filed the report, as required. Cause: The Organization did not comply with its documented policies sufficient to evidence that the VAT reporting requirement was performed. Effect or Potential Effect: Failure to perform mandated grant reporting can result in the program not adequately complying with award terms. Such non-compliance also increases the risk of loss of future awards if compliance with award terms are not met. Questioned Costs: There are no questioned costs. Context: This is a condition identified during BDO?s testing of controls over compliance for performance reporting. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Repeat Finding: This is not a repeat finding. Recommendation: BDO recommends management implement a process by which approvals, submission considerations and supporting documentation for grant reporting are maintained in a centralized location. Views of Responsible Officials: Organization management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the lapse in prescribed internal controls.
Show full finding ▾Hide full finding ▴2021-004 Internal Control over Compliance and Compliance ? Special Tests Information on the Federal Program: United States Department of the State Assistance Listing Number: 19.016 Assistance Listing Name: Iraq Assistance Program Grant Award Number under the Uniform Guidance Requirements: Direct Award Number SLMAQM18CA2097 Criteria or Specific Requirement: In accordance with ?200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. ?200.470, Taxes (Including Value Added Tax). Value Added Tax (VAT) Foreign taxes charged for the purchase of goods or services that a non-Federal entity is legally required to pay in country is an allowable expense under Federal awards. Foreign tax refunds or applicable credits under Federal awards refer to receipts, or reduction of expenditures, which operate to offset or reduce expense items that are allocable to Federal awards as direct or indirect costs. To the extent that such credits accrued or received by the non-Federal entity relate to allowable cost, these costs must be credited to the Federal awarding agency either as costs or cash refunds. If the costs are credited back to the Federal award, the non-Federal entity may reduce the Federal share of costs by the amount of the foreign tax reimbursement, or where Federal award has not expired, use the foreign government tax refund for approved activities under the Federal award with prior approval of the Federal awarding agency. Condition: The Organization has policies in place to file annual VAT reports which are required under certain grants of the major program. During our testing, BDO identified one sample where the VAT report was not filed by the country office as no VAT had been incurred for the period. However, per Federal regulations, an annual VAT report is required regardless of balances paid during the year. The Organization has since filed the report, as required. Cause: The Organization did not comply with its documented policies sufficient to evidence that the VAT reporting requirement was performed. Effect or Potential Effect: Failure to perform mandated grant reporting can result in the program not adequately complying with award terms. Such non-compliance also increases the risk of loss of future awards if compliance with award terms are not met. Questioned Costs: There are no questioned costs. Context: This is a condition identified during BDO?s testing of controls over compliance for performance reporting. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Repeat Finding: This is not a repeat finding. Recommendation: BDO recommends management implement a process by which approvals, submission considerations and supporting documentation for grant reporting are maintained in a centralized location. Views of Responsible Officials: Organization management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the lapse in prescribed internal controls.
2021-004 Internal Control over Compliance and Compliance ? Special Tests Contact: Wasim Khan Title: Vice President of Finance Phone Number: (202) 777-2297 Estimated Completion Date: December 31, 2022 Corrective Action Plan: Management will provide a training to address the importance of complying with special tests and provisions as it relates to in-country VAT reporting requirements to assist in VAT reporting compliance prospectively. Relevant regional staff have already been provided with a refresher training session on VAT management and reporting and will be followed up quarterly.
FAC accepted this audit on September 9, 2021 — management decision was due March 9, 2022.
The Organization?s policies are designed to ensure expenses are reviewed to ensure proper and accurate recording of expenses, the policies also require retention of adequate transaction documentation to support the accuracy of the amounts charged to the Federal award. We noted the following four instances: - Our testing noted one instance of 240 samples selected where the grant was overcharged due to an error in the calculation used for the allocation of an employee?s hours incurred for the grant. The review and approval of the calculated allocation did not identify the error. The error resulted in known questioned costs of $7 charged to award S-LMAQM-18-CA-2006. - Our testing noted one instance of 240 samples selected where the voucher package supporting documentation allocated the underlying expenses among various awards. However, the voucher amount was charged to a single grant. The review and approval of the voucher package did not identify the error. This resulted in known questioned costs of $52 charged to award SLMAQM19GR2218. - Our testing noted two instances of 240 samples selected where the expenditures incurred were allocated to the grant, however the basis for the allocation was not correctly documented and supported. This resulted in likely questioned costs of $1,246 charged to award S-LMAQM-15-GR- 1162 and $72 charged to award SPRMCO19CA0097-SFCG. Questioned Costs: Known questioned costs totaled $59. Likely questioned costs associated with the expenses with improper or lack of supporting documentation for the costs totaled $1,318, assuming disallowance of the full amount of the samples selected. Context: This is a condition identified per review of the Organization?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: The Organization has documented expenditure policies and procedures, however, as identified above, the review and approval process, which is the primary control, did not operate as designed. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major programs. Recommendation: We recommend that the Organization adhere to its documented policies and procedures regarding authorization and approval of expenditures as well as document retention considerations.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirement: In accordance with ?200.302 Financial Management, a nonfederal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. These internal controls should be in compliance with the guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO); (b) comply with federal statutes, regulations, and the terms and conditions of the federal awards; (c) evaluate and monitor the non-federal entity?s compliance with statutes, regulations, and the terms and conditions of federal awards. Additionally, ?200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, ?200.4 Allocation is the process by which a non-federal entity assigns a cost or group of costs, to one or more cost objectives, in reasonable proportion to the benefit provided or other equitable relationship. The process may entail assigning a cost directly to a final cost objective orthrough one or more intermediate cost objectives. Condition: The Organization?s policies are designed to ensure expenses are reviewed to ensure proper and accurate recording of expenses, the policies also require retention of adequate transaction documentation to support the accuracy of the amounts charged to the Federal award. We noted the following four instances: - Our testing noted one instance of 240 samples selected where the grant was overcharged due to an error in the calculation used for the allocation of an employee?s hours incurred for the grant. The review and approval of the calculated allocation did not identify the error. The error resulted in known questioned costs of $7 charged to award S-LMAQM-18-CA-2006. - Our testing noted one instance of 240 samples selected where the voucher package supporting documentation allocated the underlying expenses among various awards. However, the voucher amount was charged to a single grant. The review and approval of the voucher package did not identify the error. This resulted in known questioned costs of $52 charged to award SLMAQM19GR2218. - Our testing noted two instances of 240 samples selected where the expenditures incurred were allocated to the grant, however the basis for the allocation was not correctly documented and supported. This resulted in likely questioned costs of $1,246 charged to award S-LMAQM-15-GR- 1162 and $72 charged to award SPRMCO19CA0097-SFCG. Questioned Costs: Known questioned costs totaled $59. Likely questioned costs associated with the expenses with improper or lack of supporting documentation for the costs totaled $1,318, assuming disallowance of the full amount of the samples selected. Context: This is a condition identified per review of the Organization?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: The Organization has documented expenditure policies and procedures, however, as identified above, the review and approval process, which is the primary control, did not operate as designed. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major programs. Recommendation: We recommend that the Organization adhere to its documented policies and procedures regarding authorization and approval of expenditures as well as document retention considerations.
Management Believes these are standalone events and are because of the individual errors from non-compliance with documented policies. We do have Regional Controller and Roving Controller positions to review field office expenses to identify weaknesses in additiona to the internal reviews performed by Country Finance managers and Country Directors. However, due to remote working conditions throughout 2020 due to COVID-19 restrictions, some errors went undetected. We have shared the instructions to further clarify and standardize the time allocation. We already have documented policies and procedures in place to allocate the common costs and have already debriefed the Regional teams and concerned local offices so that these errors should not occur again. We have made the adjustments in 2021 to correct the overcharged amounts. Finally, We have introduced another layer of Internal compliance review effective April 01, 2021 and this will help us identify undetected errors on timely basis.
During BDO?s testing of the reporting requirements, BDO noted internal controls around performance reporting were not formalized until August 2020, to ensure proper documentation exists to verify reports are reviewed by appropriate parties. Additionally, during our testing of the major programs, we noted five instances of the thirty reporting samples selected where the reports were not submitted timely. The instances noted related to two reports for award SPRMCO19CA0097-SFCG and one report for each of the following awards; SPRMCO20CA0076-SFCG, S-LMAQM-18-CA-2006 and S-LMAQM-19-CA-2197. Questioned Costs: There are no questioned costs as the items outlined above are internal control related matters. Context: This is a condition identified during BDO?s internal control walk-through procedures performed over the reporting requirements and through the testing of financial and performance reports. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization has controls in place to ensure timely reporting in accordance with financial and performance reporting requirements, through the review of Project Finance Managers and Regional Controllers, which is the primary control. However, this is principally a manual process and the manual controls in place to address delayed reporting did not operate as designed. Effect: Failure to properly track all performance reporting requirements impacts the Federal agency from obtaining performance information required to assess award performance on a macro level. Such non-compliance also increases the risk of loss of future awards if compliance with award terms are not met. Recommendation: In order to facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, BDO recommends management ensure all reporting requirements are maintained, updated, and available in a central location, which we believe should be an IT solution.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirement: In accordance with ?200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. ?200.328, Financial Reporting, prescribes that the non-federal entity is responsible for oversight of the operations of the federal award supported activities. The non-federal entity must monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. Monitoring by the non-federal entity must cover each program, function or activity. The non-federal entity must submit reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. ?200.329, Monitoring and reporting program performance, prescribes that the non-Federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity. The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Condition: During BDO?s testing of the reporting requirements, BDO noted internal controls around performance reporting were not formalized until August 2020, to ensure proper documentation exists to verify reports are reviewed by appropriate parties. Additionally, during our testing of the major programs, we noted five instances of the thirty reporting samples selected where the reports were not submitted timely. The instances noted related to two reports for award SPRMCO19CA0097-SFCG and one report for each of the following awards; SPRMCO20CA0076-SFCG, S-LMAQM-18-CA-2006 and S-LMAQM-19-CA-2197. Questioned Costs: There are no questioned costs as the items outlined above are internal control related matters. Context: This is a condition identified during BDO?s internal control walk-through procedures performed over the reporting requirements and through the testing of financial and performance reports. This internal control matter could result in noncompliance with certain federal awards. Our sample was selected through a non-statistical method. Cause: The Organization has controls in place to ensure timely reporting in accordance with financial and performance reporting requirements, through the review of Project Finance Managers and Regional Controllers, which is the primary control. However, this is principally a manual process and the manual controls in place to address delayed reporting did not operate as designed. Effect: Failure to properly track all performance reporting requirements impacts the Federal agency from obtaining performance information required to assess award performance on a macro level. Such non-compliance also increases the risk of loss of future awards if compliance with award terms are not met. Recommendation: In order to facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, BDO recommends management ensure all reporting requirements are maintained, updated, and available in a central location, which we believe should be an IT solution.
Delay in submitting Project reports is mainly linked to the Covid-19 pandemic, getting inputs from different people, and then compiling reports took longer time than usual given the remote working environment in the various countries. We have kept our donors informed for any major delays in sharing of reports. There was only one financial report that was delayed by one working day. we have added a new compliance position who will be responsible for checking internal compliance for external reporting and special tests. We have reemphasized globally the importance of compliance for financial and programmatic reporting and reinforced the controls surrounding external reporting.
FAC accepted this audit on September 27, 2018 — management decision was due March 27, 2019.
GSA_MIGRATION
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2016-003
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2016-004
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2016-005
FAC accepted this audit on September 25, 2017 — management decision was due March 25, 2018.
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2015-001
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2015-004
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2015-006
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2015-008
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