EIN: 521338892
UEI: GN36K2UPR245
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 14, 2022. 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 December 14, 2022, which was (1346 days ago).
What is a management decision? →NDI?s internal controls around performance reporting did not operate as designed for the review and approval of performance reports prior to submission to third parties. BDO noted there was no evidence that the four performance report samples of 25 total reports selected for testing were reviewed and approved prior to submission. Cause: NDI did not comply with its documented policies sufficient to evidence that the review and approval of the performance report was performed. Effect or Potential Effect: Failure to track and maintain documentation supporting performance 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 programmatic reports are maintained in a centralized location. Views of Responsible Officials: NDI management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴Information on the Federal Program: United States Agency for International Development Federal Assistance Listing Number: 98.001 Federal Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period 72038320LA00002 August 1, 2020 through July 31, 2025 DOBRE-16-06-NDI July 11, 2016 through December 31, 2021 72011419LA00001 April 1, 2019 through March 31, 2025 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, 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 nonfederal entity must monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. Monitoring by the nonfederal 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. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the federal award or could significantly affect program outcomes. Condition: NDI?s internal controls around performance reporting did not operate as designed for the review and approval of performance reports prior to submission to third parties. BDO noted there was no evidence that the four performance report samples of 25 total reports selected for testing were reviewed and approved prior to submission. Cause: NDI did not comply with its documented policies sufficient to evidence that the review and approval of the performance report was performed. Effect or Potential Effect: Failure to track and maintain documentation supporting performance 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 programmatic reports are maintained in a centralized location. Views of Responsible Officials: NDI management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the lapses in prescribed internal controls.
Finding 2021-001: Internal Control over Compliance and Compliance with Performance Reporting Contact: Sophia Toumbalakis, Program Coordination Director, 202-728-5500 Estimated Completion Date: July 2022 Corrective Action: NDI has established procedures for internally reviewing performance reports developed by NDI program teams and the subsequent submission of the reports to the appropriate donors. All performance reports are reviewed by both the program team and the administrative team responsible for oversight of donor compliance. In the four exceptions noted, the performance reports had been reviewed by both teams, but the written confirmations of the review were not retained due to an oversight. NDI will review its centralized performance report tracking system and make any improvements needed to better ensure that all review documentation is retained.
During fiscal year 2021, NDI identified an invalid/questioned cost incident incurred by a subrecipient through its internal reporting mechanisms that impacted it?s federally funded program. This fraud incident has been reported to the appropriate U.S. Office of the Inspector General by NDI. In Zimbabwe, an internal audit investigation identified that a subrecipient intentionally submitted invalid vendor invoices for car rental services and equipment rentals for vehicles and equipment owned by the subgrantee. These activities occurred on both the referenced direct awards (18-18105-ZIM.0-1565 incurring $23,143 in invalid/questioned costs and 20-20111-ZIM.0-1841 incurring $17,289 in invalid/questioned costs). Questioned Costs: There are no questioned costs as the amounts have been fully reimbursed to USAID. Context: These conditions were identified through NDI?s internal review and subrecipient monitoring processes and were reported to us during our internal control assessment for the year ended September 30, 2021.Cause: Individuals intentionally circumvented NDI?s established internal controls. Effect: These conditions resulted in unallowable expenses being charged to U.S. Government awards; controls in place later identified the conditions for reimbursement to occur. Repeat Finding: Not a repeat finding. Recommendation: Because of the international environment in which NDI operates, the potential for fraud is heightened. Given this, we recommend management continue to utilize its global internal audit team and fraud reporting hotline, as well as other policies and procedures around fraud identification to mitigate the fraud risk. Further, NDI should continue to monitor and assess the control environment and activities of its subrecipients. Views of Responsible Officials: NDI 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 ▴Information on the Federal Program: United States Agency for International Development Federal Assistance Listing Number: 98.001 Federal Assistance Listing Number: USAID Foreign Assistance for Programs Overseas Grant Award Numbers: Direct Award Number Award Period 18-18105-ZIM.0-1565 February 1, 2018 to October 15, 2019 20-20111-ZIM.0-1841 July 1, 2020 to December 31, 2021 Criteria: ?200.516 Audit findings (1)(6) requires known or suspected fraud be reported by the auditor. Condition: During fiscal year 2021, NDI identified an invalid/questioned cost incident incurred by a subrecipient through its internal reporting mechanisms that impacted it?s federally funded program. This fraud incident has been reported to the appropriate U.S. Office of the Inspector General by NDI. In Zimbabwe, an internal audit investigation identified that a subrecipient intentionally submitted invalid vendor invoices for car rental services and equipment rentals for vehicles and equipment owned by the subgrantee. These activities occurred on both the referenced direct awards (18-18105-ZIM.0-1565 incurring $23,143 in invalid/questioned costs and 20-20111-ZIM.0-1841 incurring $17,289 in invalid/questioned costs). Questioned Costs: There are no questioned costs as the amounts have been fully reimbursed to USAID. Context: These conditions were identified through NDI?s internal review and subrecipient monitoring processes and were reported to us during our internal control assessment for the year ended September 30, 2021.Cause: Individuals intentionally circumvented NDI?s established internal controls. Effect: These conditions resulted in unallowable expenses being charged to U.S. Government awards; controls in place later identified the conditions for reimbursement to occur. Repeat Finding: Not a repeat finding. Recommendation: Because of the international environment in which NDI operates, the potential for fraud is heightened. Given this, we recommend management continue to utilize its global internal audit team and fraud reporting hotline, as well as other policies and procedures around fraud identification to mitigate the fraud risk. Further, NDI should continue to monitor and assess the control environment and activities of its subrecipients. Views of Responsible Officials: NDI 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.
Contact: Jennifer Ganem, NDI Counsel, 202-728-5500 Estimated Completion Date: July 2022 Corrective Action: NDI takes its responsibilities as a steward of U.S. government funds seriously and has a robust system of internal controls and monitoring procedures in place to minimize the risk of loss. NDI notes that the fraud was identified through its monitoring procedures of the subrecipient. NDI has reviewed these controls in the wake of the fraud and believes its existing subrecipient monitoring procedures are strong, but will continue to assess their adequacy as risks evolve. NDI had extensive oversight steps in place for the subrecipient, including the submission of regular narrative and financial reports, along with receipts and bank records.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 27, 2021. 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 January 27, 2022, which was (1667 days ago).
What is a management decision? →During BDO?s compliance testing, the following conditions were noted: ? For two of 60 procurement transactions tested (see direct awards impacted above), the required suspension and debarment check was performed subsequent to entering into the contract with the vendor or consultant. In both instances, the required suspension and debarment checks were subsequently performed. NDI?s subsequent suspension and debarment analysis identified no vendors that were suspended or debarred. Cause: NDI personnel did not adhere to the federal requirements and NDI?s policies and procedures regarding procurement and suspension and debarment for the two items identified above. Effect or Potential Effect: Failure to verify that a vendor or consultant is not suspended or debarred could result in NDI inadvertently entering into a contract with an entity or individual that is barred from performing services for the Federal government. Questioned Costs: None. Context: This is a condition based on testing of NDI?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Repeat Finding: This is a repeat finding from last year. This was reported as finding 2019-002 in the 2019 schedule of findings and questioned costs. Recommendation: We recommend that NDI adhere to its documented policies and procedures to verify that vendors are not suspended or debarred prior to entering into contracts utilizing federal funding. Views of Responsible Officials: Management agrees with the finding and plans to perform additional institute-wide follow up trainings to reinforce these debarment check policies and procedures. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴Information on the Federal Program: U.S. Agency for International Development CFDA Number: 98.001 CFDA Name: USAID Foreign Assistance for Programs Overseas Direct Grant Award Number: AID-OAA-LA-16-00005 (One instance of non-compliance) 72027820LA00001 (One instance of non-compliance) Criteria or Specific Requirement: In accordance with ?200.213 of the Uniform Guidance and ?180.300 of OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), 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. Condition: During BDO?s compliance testing, the following conditions were noted: ? For two of 60 procurement transactions tested (see direct awards impacted above), the required suspension and debarment check was performed subsequent to entering into the contract with the vendor or consultant. In both instances, the required suspension and debarment checks were subsequently performed. NDI?s subsequent suspension and debarment analysis identified no vendors that were suspended or debarred. Cause: NDI personnel did not adhere to the federal requirements and NDI?s policies and procedures regarding procurement and suspension and debarment for the two items identified above. Effect or Potential Effect: Failure to verify that a vendor or consultant is not suspended or debarred could result in NDI inadvertently entering into a contract with an entity or individual that is barred from performing services for the Federal government. Questioned Costs: None. Context: This is a condition based on testing of NDI?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Repeat Finding: This is a repeat finding from last year. This was reported as finding 2019-002 in the 2019 schedule of findings and questioned costs. Recommendation: We recommend that NDI adhere to its documented policies and procedures to verify that vendors are not suspended or debarred prior to entering into contracts utilizing federal funding. Views of Responsible Officials: Management agrees with the finding and plans to perform additional institute-wide follow up trainings to reinforce these debarment check policies and procedures. See management?s corrective action plan.
Finding 2020-001: Procurement and Suspension and Debarment Contact: Sander Schultz, Chief Financial Officer, 202-728-5500 Estimated Completion Date: July 2021 Corrective Action: NDI takes its responsibilities as a steward of U.S. government funds seriously, and has designed it procurement policies and procedures to comply with the procurement standards in the Uniform Guidance. Training on NDI?s procurement policies and procedures regarding the required checks against the exclusions is part of NDI?s standard orientation for new employees. Periodic training is also provided to employees throughout the year on procurement standards. In order to strengthen its capabilities to perform the required checks on a timely basis, NDI implemented in December 2019 a software tool with enhanced functionality over the prior software. NDI trained staff from each department in the use of the new software. NDI reviews procurement transactions to monitor compliance with the requirement to perform exclusion checks prior to signing a contract. NDI will continue to perform Institute-wide follow up trainings to ensure that staff properly understand policies and procedures regarding debarment checks, including the use of the new software.
2019-002
During BDO?s testing of noted special provision reporting requirements, one instance in eight samples tested identified that the required Value Added Tax report was submitted 13 months after the due date. Questioned Costs: None. Context: This is a condition identified per review of NDI?s compliance with special tests and provisions outlined in the grant agreements underlying the major program. The prevalence of this finding is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: NDI has documented reporting policies to address compliance with the grant agreement reporting requirements. However, as identified above, the review and approval process did not operate as designed resulting in the delayed reporting outlined above. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with the provisions of grant agreements. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that NDI adhere to its documented policies and procedures regarding timely reporting to comply with the special tests and provisions to submit VAT reports. Views of Responsible Officials: Management agrees with the finding and intends to review its current reporting process to ensure the VAT submission process works as designed. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴Information on the Federal Program: U.S. Agency for International Development CFDA Number: 98.001 CFDA Name: Foreign Assistance for Programs Overseas Grant Award Number: Direct Award Number Award Period SA-288.10.01.16-NDI October 1, 2016 through September 30, 2020 Criteria or Specific Requirement: ?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 underlying federal award requirements. Condition: During BDO?s testing of noted special provision reporting requirements, one instance in eight samples tested identified that the required Value Added Tax report was submitted 13 months after the due date. Questioned Costs: None. Context: This is a condition identified per review of NDI?s compliance with special tests and provisions outlined in the grant agreements underlying the major program. The prevalence of this finding is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: NDI has documented reporting policies to address compliance with the grant agreement reporting requirements. However, as identified above, the review and approval process did not operate as designed resulting in the delayed reporting outlined above. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with the provisions of grant agreements. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that NDI adhere to its documented policies and procedures regarding timely reporting to comply with the special tests and provisions to submit VAT reports. Views of Responsible Officials: Management agrees with the finding and intends to review its current reporting process to ensure the VAT submission process works as designed. See management?s corrective action plan.
Finding 2020-002: Special Tests and Provisions Contact: Sander Schultz, Chief Financial Officer, 202-728-5500 Estimated Completion Date: July 2021 Corrective Action: NDI has established monitoring procedures for gathering the annual reports on Value Added Tax (VAT) from its field offices and subrecipients by country, and the subsequent submission of the reports to the appropriate grantors. Due to an oversight, the VAT report for the grant noted in the finding was not included in the original reporting process. NDI has now filed the VAT report for the fiscal year, reflecting $0 of VAT paid by NDI under the terms of the reporting requirement for the grant. NDI will review its reporting process to ensure all grants are appropriately included in the gathering and submission process.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 28, 2020. 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 January 28, 2021, which was (2031 days ago).
What is a management decision? →During the year ended September 30, 2019, NDI identified potential questioned costs under a federal award. NDI became aware of potential questioned costs incurred by a subrecipient. NDI notified the U.S. Agency for International Development upon identification of the potential questioned costs. NDI engaged an independent certified fraud examiner to investigate the allegation. The results of the findings were communicated to USAID on October 10, 2019. Cause: Certain employees at the subrecipient intentionally circumvented NDI?s established internal controls and policies and procedures over financial management, and compliance with U.S. government grant regulations. Effect or Potential Effect: Questioned costs of $27,996 were identified resulting from the investigation. As of the year ended September 30, 2019, the subrecipient has returned to NDI the full amount of questioned costs. Questioned Costs: $27,996. Context: This matter was identified through NDI?s ongoing monitoring of federal subgrants. This matter was reported to BDO during our internal control assessment for the year ended September 30, 2019. Recommendation: NDI should continue to monitor and assess the control environment and activities of its subrecipients. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴Information on Federal Program: U.S. Agency for International Development CFDA Number: 98.001 CFDA Name: Foreign Assistance for Programs Overseas Direct Grant Award Number: AID-520-LA-17-00001 (June 12, 2017 ? June 07, 2020) Criteria or Specific Requirement: 2 CFR 200 ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart E requires that for the cost to be allowable, the cost has to be necessary and reasonable for the performance of the federal award and conform to any limitation or exclusions set forth in the Uniform Guidance and the federal award. Condition: During the year ended September 30, 2019, NDI identified potential questioned costs under a federal award. NDI became aware of potential questioned costs incurred by a subrecipient. NDI notified the U.S. Agency for International Development upon identification of the potential questioned costs. NDI engaged an independent certified fraud examiner to investigate the allegation. The results of the findings were communicated to USAID on October 10, 2019. Cause: Certain employees at the subrecipient intentionally circumvented NDI?s established internal controls and policies and procedures over financial management, and compliance with U.S. government grant regulations. Effect or Potential Effect: Questioned costs of $27,996 were identified resulting from the investigation. As of the year ended September 30, 2019, the subrecipient has returned to NDI the full amount of questioned costs. Questioned Costs: $27,996. Context: This matter was identified through NDI?s ongoing monitoring of federal subgrants. This matter was reported to BDO during our internal control assessment for the year ended September 30, 2019. Recommendation: NDI should continue to monitor and assess the control environment and activities of its subrecipients. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Finding 2019?001: Activities Allowed or Unallowed; Allowable Costs/Costs Principles Contact: Jennifer Ganem, NDI Counsel, 202-728-5500 Estimated Completion Date: October 2019 Corrective Action: NDI takes its responsibilities as a steward of U.S. government funds seriously and has a robust system of internal controls and monitoring in place to minimize the risk of loss. NDI has reviewed these controls in the wake of the fraud and believes existing subgrant monitoring procedures are strong, but will continue to assess their adequacy as risks evolve. NDI had extensive oversight steps in place for the Subgrantee, including the submission of bi-monthly narrative and financial reports, along with receipts and bank records; regular program planning and coordination meetings between NDI and the Subgrantee.
During BDO?s compliance testing, the following conditions were noted: ? For four of 60 procurement transactions tested, the required suspension and debarment check was performed subsequent to entering into the contract with the vendor or consultant. In all four instances, the required suspension and debarment checks were subsequently performed. NDI?s subsequent suspension and debarment analysis identified no vendors that were suspended or debarred. o This finding relates to the following grant numbers: ? S-LMAQM-17-GR-1207 (one instance of noncompliance) ? S-LMAQM-17-GR-1172 (one instance of noncompliance) ? S-LMAQM-18-GR-2244 (one instance of noncompliance) ? 2018-0011 Bangladesh (one instance of noncompliance) Cause: NDI personnel did not adhere to the federal requirements and NDI?s policies and procedures regarding procurement and suspension and debarment for the four items identified above. Effect or Potential Effect: Failure to verify that a vendor or consultant is not suspended or debarred could result in NDI inadvertently entering into a contract with an entity or individual that is barred from performing services for the Federal government. Questioned Costs: None. Context: This is a condition based on testing of NDI?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Repeat Finding: This is a repeat finding from last year. This was reported as finding 2018-002 in the 2018 schedule of findings and questioned costs. Recommendation: We recommend that NDI adhere to its documented policies and procedures to verify that vendors are not suspended or debarred prior to entering into contracts utilizing federal funding. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴Information on Federal Program: Bureau of Democracy, Human Rights and Labor CFDA Number: 19.345 CFDA Name: International Programs to Support Democracy, Human Rights and Labor Direct Grant Award Number: S-LMAQM-17-GR-1207 (September 27, 2017 ? November 30, 2019) S-LMAQM-17-GR-1172 (September 8, 2017 ? June 30, 2019) S-LMAQM-18-GR-2244 (September 21, 2018 ? September 30, 2020) Pass-through Grant Award Number: 2018-0011 Bangladesh (February 1, 2018 ? December 31, 2020) Criteria or Specific Requirement: Effective October 1, 2016, NDI adopted the procurement standards contained in the Uniform Guidance. 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 of the Uniform Guidance and ?180.300 of OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), 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. 2 CFR 215.13, 2 CFR 215.40 through 215.48 notes that federal awarding agencies and recipients shall comply with relevant procurement standards including maintaining and abiding by a written procurement policy. 2 CFR 200.318(a) states that the non-Federal entity must use its own documented procurement procedures. Condition: During BDO?s compliance testing, the following conditions were noted: ? For four of 60 procurement transactions tested, the required suspension and debarment check was performed subsequent to entering into the contract with the vendor or consultant. In all four instances, the required suspension and debarment checks were subsequently performed. NDI?s subsequent suspension and debarment analysis identified no vendors that were suspended or debarred. o This finding relates to the following grant numbers: ? S-LMAQM-17-GR-1207 (one instance of noncompliance) ? S-LMAQM-17-GR-1172 (one instance of noncompliance) ? S-LMAQM-18-GR-2244 (one instance of noncompliance) ? 2018-0011 Bangladesh (one instance of noncompliance) Cause: NDI personnel did not adhere to the federal requirements and NDI?s policies and procedures regarding procurement and suspension and debarment for the four items identified above. Effect or Potential Effect: Failure to verify that a vendor or consultant is not suspended or debarred could result in NDI inadvertently entering into a contract with an entity or individual that is barred from performing services for the Federal government. Questioned Costs: None. Context: This is a condition based on testing of NDI?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Repeat Finding: This is a repeat finding from last year. This was reported as finding 2018-002 in the 2018 schedule of findings and questioned costs. Recommendation: We recommend that NDI adhere to its documented policies and procedures to verify that vendors are not suspended or debarred prior to entering into contracts utilizing federal funding. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Finding 2019-002: Procurement and Suspension and Debarment Contact: Sander Schultz, Chief Financial Officer, 202-728-5500 Estimated Completion Date: December 2019 Corrective Action: NDI takes its responsibilities as a steward of U.S. government funds seriously, and has designed it procurement policies and procedures to comply with the procurement standards in the Uniform Guidance. Training on NDl's procurement policies and procedures regarding the required checks against the exclusions is part of NDl's standard orientation for new employees. Periodic training is also provided to employees throughout the year on procurement standards. In order to strengthen its capabilities to perform the required checks on a timely basis, NDI purchased and implemented in December 2019 a software tool with enhanced functionality over the prior software. NDI trained staff from each department in the use of the new software. NDI reviews procurement transactions to monitor compliance with the requirement to perform exclusion checks prior to signing a contract. NDI regularly provides follow-up training related to issues identified in its monitoring procedures.
2018-002
During our testing of the period of performance compliance requirement, we selected 14 sample items specifically for grants that began or ended during 2019. In one instance, our testing identified an obligation incurred during the grant period that was liquidated in excess of 90 calendar days after the grant end date. Cause: NDI management works with a significant number of subgrantees in the performance of its global programs. In limited instances, NDI experiences delays in obtaining validating support from subgrantees. These delays, in limited circumstances, result in delayed submission of a request for reimbursement under the corresponding grant agreement. Effect or Potential Effect: While the known questioned costs that resulted from the conditions identified above were minimal, the lack of adherence to the established internal control procedures around the period of performance of the award as well as the accrual basis of expenditures can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in disallowed costs for the major program. Questioned Costs: $643. Context: This is a condition identified per review of NDI?s compliance with specified requirements. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴Information on Federal Program: Bureau of Democracy, Human Rights and Labor CFDA Number: 19.345 CFDA Name: International Programs to Support Democracy, Human Rights and Labor Direct Grant Award Number: S-LMAQM-16-GR-1051 (May 13, 2016 ? February 28, 2018) Criteria or Specific Requirement: In accordance with ?200.309 of the Uniform Guidance, a non- Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non- Federal entity must liquidate all obligations incurred under the Federal award not later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.343(b). When used in connection with a non- Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected 14 sample items specifically for grants that began or ended during 2019. In one instance, our testing identified an obligation incurred during the grant period that was liquidated in excess of 90 calendar days after the grant end date. Cause: NDI management works with a significant number of subgrantees in the performance of its global programs. In limited instances, NDI experiences delays in obtaining validating support from subgrantees. These delays, in limited circumstances, result in delayed submission of a request for reimbursement under the corresponding grant agreement. Effect or Potential Effect: While the known questioned costs that resulted from the conditions identified above were minimal, the lack of adherence to the established internal control procedures around the period of performance of the award as well as the accrual basis of expenditures can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in disallowed costs for the major program. Questioned Costs: $643. Context: This is a condition identified per review of NDI?s compliance with specified requirements. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Finding 2019-003: Period of Performance Contact: Sander Schultz, Chief Financial Officer Estimated Complet ion Date: July 2020 Corrective Act ion: NDI performs a close-out review of every award to ensure the accuracy and completeness of expenses recorded. NOi grants compliance staff members meet regularly with program teams in advance of the end of each award to help identify potential outstanding expenses that have not been recorded. The transaction that was recorded late was due to delays in reporting by the subgrantee. NDI will review its close-out procedures for potential improvements, and will remind all program staff of the importance of obtaining all outstanding invoices from vendors and subgrantees to ensure that all charges are recorded within the close-out period for the award.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 14, 2019. 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 September 14, 2019, which was (2533 days ago).
What is a management decision? →GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
2017-001
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 13, 2018. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by November 13, 2018, which was (2838 days ago).
What is a management decision? →GSA_MIGRATION
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GSA_MIGRATION
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 6, 2017. 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 September 6, 2017, which was (3271 days ago).
What is a management decision? →GSA_MIGRATION
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GSA_MIGRATION
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