UNITED STATES TELECOMMUNICATIONS TRAINING INSTITUTENon-Profit

Finding 2023-003: Schedule of Expenditures of Federal Awards (Significant Deficiency) Information on the Federal Program: All programs in the 2023 SEFA. See Finding 2023-002.Criteria: In accordance with 2 CFR Section 200.508 (b), USTTI is required to prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). Condition: USTTI experienced difficulty in ensuring that all Federal expenditures were identified, categorized and included in the SEFA. Due to the amount of program codes in the accounting system, it was difficult to identify which subprogram codes related to the various Federal programs. In addition, indirect costs reported to the Federal granting agencies were not properly calculated. This condition impacted the entire SEFA and is considered to be a systematic problem. Cause: The high volume of subprogram codes was a contributing factor to the error as well as the improper calculation of the indirect costs on the grants. Effect: USTTI experienced difficulty in preparing an accurate SEFA. Context: USTTI does not have processes and procedures in place to prepare an accurate SEFA.Questioned Costs: None. Identification as a Repeat Finding: Yes. See Finding 2022-002.Recommendation: We recommend USTTI prepare its SEFA on a quarterly basis in accordance with the Uniform Guidance, and it should be reviewed and approved by an individual in a supervisory capacity with knowledge of the grant program. USTTI should ensure that the review process encompasses agreeing the amounts in the SEFA to expenses recorded in the general ledger. Additionally, USTTI should review the indirect rate calculation to ensure that is is accurate and that USTTI is not charging more indirect costs than allowed in accordance with the terms of its grant.

Finding 2023-004: Procurement (Significant Deficiency) Information on the Federal Program: ALN 19.663 Global Telecommunications and Emerging Technology Training Criteria: 2 CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: We noted procurement procedures are outsourced to a third party, but management is heavily involved in the ultimate decision. However, the procurement policy is not formalized and procurement actions are not documented and maintained in USTTI's vendor files. Cause: USTTI did not have a documented formal procurement policy in accordance with the Uniform Guidance. Effect: A lack of a formal procurement policy is insufficient to meet the requirements of the Uniform Guidance as noted in the Criteria section above. Questioned Costs: None. Context: Because USTTI does not have a formal procurement policy, it is not in compliance with the Uniform Guidance.Context (continued): Our audit work in this area consisted of a test of internal controls over a random sample of expenditures, as well as substantive tests of details over transactions above a defined threshold from select expense accounts that were charged to the Federal program. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Due to the timing of the audit for the year ended December 31, 2022, USTTI was not able to formalize a policy for the year ended December 31, 2023. We noted that USTTI has formalized a procurement policy during the year ended December 31, 2024. Identification as a Repeat Finding: Yes. See Finding 2022-03. Recommendation: We recommend USTTI formalize a procurement policy which is in compliance with the Uniform Guidance. We also recommend that USTTI management ensure the procurement policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with the policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files.

Finding 2023-005: Suspension and Debarment (Significant Deficiency) Information on the Federal Program: ALN 19.663 Global Telecommunications and Emerging Technology Training Criteria: Under 2 CFR §200.213, non-Federal entities are subject to the non-procurement debarment and suspension regulations included in Executive Orders 12549 and 12689 and 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over Suspension and Debarment, we determined that USTTI did not perform screenings on potential or current vendors, suppliers or contractors that were paid with Federal funds. Cause: USTTI does not have a formal internal policy with respect to screening vendors, suppliers, contractors and employees in order to adhere to compliance over suspension and debarment. Effect: Failure to screen potential and current vendors, suppliers, contractors and employees increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None. Context: We noted that none of the vendors, suppliers etc. selected for testing had a formally documented Suspension and Debarment check conducted prior to payment of their invoices.Context (Continued): Due to the timing of the audit for the year ended December 31, 2022, USTTI was not able to formalize a policy for the year ended December 31, 2023. We noted that USTTI has formalized a suspension and debarment policy during the year ended December 31, 2024. Identification as a Repeat Finding: Yes. See Finding 2022-04. Recommendation: We recommend that management develop and implement a formal policy on suspension and debarment. This policy should include a threshold for when vendors, suppliers, contractors and employees should be screened. All screenings should be conducted prior to signing a contract or issuing payment. We recommend that USTTI notify all employees of this policy and ensure that it is enforced during the upcoming fiscal year.

Finding 2023-006: Federal Financial Reporting (Significant Deficiency) Information on the Federal Program: ALN 19.663 Global Telecommunications and Emerging Technology Training Criteria: The U.S. Department of State requires that USTTI submit a quarterly Federal Financial Report (FFR), SF-425, in accordance with the quarterly schedule indicated in its grant agreement, within 30 days following the end of each calendar quarter. Condition: USTTI filed its FFR's for the fiscal year by the required due dates if there was activity. However, we noted that the expenditures reported in the quarterly FFR's were not consistent with the actual expenditures reported in the general ledger due to indirect costs which were incorrectly reported as direct expenses on the FFR's. We also noted that USTTI incorrectly reported on the accrual basis of accounting rather than on the cash basis of accounting on the quarterly FFR's. Cause: Management did not have effective internal controls in place to ensure that the FFR's were accurately filed and submitted. Effect: Without established controls over reporting and reimbursement requests, there is a reasonable possibility that USTTI would not detect noncompliance in the normal course of performing duties and be able to correct them in a timely manner. Questioned Costs: None. Context: Our audit procedures consisted of reviewing the FFR's that were filed and comparing them to the amounts reported in the general ledger. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding: Yes. See Finding 2022-05.Recommendation: We recommend USTTI prepare the FFR's based on actual expenditures for each quarter. Since it is likely indirect rate adjustments may occur after quarter-end, USTTI should make efforts to ensure these transactions are reflected in the general ledger before preparation of the FFR's, while still meeting the FFR submission deadlines.

Finding 2022-002: Tracking of Federal Expenses and Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Criteria: Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee's financial statements which must include the total Federal awards expended. Additionally, in accordance with CFR 200.303, the 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. These internal controls should be in compliance with 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). Condition: USTTI experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized and included in the SEFA. Due to the amount of program codes in the accounting system, it was difficult to identify which subprogram codes related to the various Federal programs. Additionally, we noted that indirect costs reported to the Federal granting agencies were not properly calculated. The condition impacted the entire SEFA which is considered to be a systematic problem. Cause: The high volume of subprogram codes were contributing factors to the error as well as improper calculation of the indirect rate on the grants. Effect: USTTI was unable to prepare the Schedule of Expenditures of Federal Awards. Questioned Costs: None. Context: USTTI was unable to complete its SEFA. As it has never prepared a SEFA in the past, the condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend USTTI prepare its SEFA on a quarterly basis and it should be reviewed and approved by an individual in a supervisory capacity. The SEFA should be prepared in accordance with the regulations under Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). USTTI should enhance the review process to ensure the amounts agree to its reported expenses. Additionally, USTTI should review its indirect rate calculation (i.e. ensuring components are correctly identified and the mathematical calculations are accurate) to verify it is not charging over its actual indirect rate.

Finding 2022-003: Procurement Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: We noted procurement procedures are outsourced to a third party and management is heavily involved in the ultimate decision. However, this policy is not formalized. Cause: USTTI did not have a documented formal procurement policy in place. Effect: A lack of a formal procurement policy is insufficient to meet the requirements noted in the Criteria section above. Questioned Costs: None. Context: USTTI does not have a formal procurement policy, and hence, not in compliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures, as well as substantive testwork over transactions above a defined threshold from select expense accounts that were charged to the Federal program. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend USTTI formalize a procurement policy to be in compliance with 2 CFR 200. We then recommend that USTTI management ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files.

Finding 2022-004: Suspension and Debarment Criteria: Under 2 CFR §200.213, Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over Suspension and Debarment, we determined that USTTI did not perform screenings on potential or current vendors, suppliers or contractors that were paid with Federal funds. Cause: USTTI does not have a formal internal policy with respect to screening vendors, suppliers, contractors and employees in order to adhere to compliance over suspension and debarment. Effect: Failure to screen potential and current vendors, suppliers, contractors and employees increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None. Context: We noted that vendors, suppliers etc. selected for testing did not have a formally documented Suspension and Debarment check conducted prior to engagement. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that management develop and implement a formal policy on suspension and debarment. This policy should include a threshold for when vendors, suppliers, contractors and employees should be screened. All screenings should be conducted prior to signing a contract or issuing payment. We recommend that USTTI notify all employees of this policy and ensure that it is enforced during the upcoming fiscal year.

Finding 2022-005: Federal Financial Reporting Criteria: The U.S. Department of Labor requires that the Organization submit a quarterly Federal Financial Report (FFR), SF-425, in accordance with the quarterly schedule indicated in its grant agreement, within 30 days following the end of each calendar quarter. Condition: USTTI filed its FFRs for the fiscal year by the required due dates if there was activity. We noted that the expenditures reported in the quarterly FFRs were not consistent with the actual expenditures reported in the general ledger due to indirect costs incorrectly reported as direct expenses on the FFRs. We also noted that USTTI incorrectly reported an accrual basis of accounting rather than cash basis on the quarterly FFRs. Cause: Management did not have effective internal controls in place to ensure that the FFRs were accurately filed and submitted. Effect: Without established controls over reporting and reimbursement requests, there is a reasonable possibility that USTTI would not detect noncompliance in the normal course of performing duties and correct them in a timely manner. Questioned Costs: None. Context: Our audit procedures consisted of testwork performed over cash receipts and draw down requests from the Federal Government. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend USTTI prepare its FFRs based on actual expenditures for each quarter. Since it is likely indirect rate adjustments may occur after quarter-end, for instance, USTTI should make efforts to ensure these transactions are reflected in the general ledger before preparation of the FFRs, while still meeting the FFR submission deadlines.