EIN: 521344831
UEI: KH6TMX6EA148
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 8, 2024. 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 8, 2024 (714 days ago).
What is a management decision? →Finding 2023-001: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA).Agency and Award: U.S. Department of State, Assistance Listing Number 19.345.Criteria: Under the requirements of the FFATA (Pub. L. No. 109‑282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the Transparency Act that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the Federal Acquisition Regulation.Condition and context: The Endowment works with sub awardees and some of its awards require compliance with the FFATA requirement. Even though the Endowment is aware of the FFATA requirement, the Endowment does not report its subawards in the required system.Cause: The Endowment works with many grantees that work in high-risk countries and concluded that complying with the requirement, would put its grantees at risk.Questioned costs: None.Effect: The Endowment is in non-compliance with FFATA reporting requirements. No other reporting issues noted.Repeat finding: Yes, reported as Finding 2022-001.Recommendation: We recommend management continues to work with its grant officers to obtain a waiver and implement procedures to ensure grants are evaluated for reporting requirements under FFATA and the reporting is completed within the required timeframe.View of responsible officials and planned corrective actions: Management acknowledges the FFATA requirement and will continue working with the grant officers. See corrective action plan 2023.
Show full finding ▾Hide full finding ▴Finding 2023-001: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA).Agency and Award: U.S. Department of State, Assistance Listing Number 19.345.Criteria: Under the requirements of the FFATA (Pub. L. No. 109‑282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the Transparency Act that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the Federal Acquisition Regulation.Condition and context: The Endowment works with sub awardees and some of its awards require compliance with the FFATA requirement. Even though the Endowment is aware of the FFATA requirement, the Endowment does not report its subawards in the required system.Cause: The Endowment works with many grantees that work in high-risk countries and concluded that complying with the requirement, would put its grantees at risk.Questioned costs: None.Effect: The Endowment is in non-compliance with FFATA reporting requirements. No other reporting issues noted.Repeat finding: Yes, reported as Finding 2022-001.Recommendation: We recommend management continues to work with its grant officers to obtain a waiver and implement procedures to ensure grants are evaluated for reporting requirements under FFATA and the reporting is completed within the required timeframe.View of responsible officials and planned corrective actions: Management acknowledges the FFATA requirement and will continue working with the grant officers. See corrective action plan 2023.
NED management has been aware of the FFATA reporting requirements and takes a serious approach to FFATA regulations. NED's concerns regarding FFATA compliance are rooted in concern for personal and physical safety of our grantees working in the sphere of human rights and democracy, particularly those NED partners working in the world's most hostile authoritarian countries. As stated in our response to the FY2022 Audit, NED staff analysis of the potential reporting requirements recognized two significant risks to NED's partners and the success of its programs: 1) reporting all first-tier sub awardees would mean posting the identity of recipients and details of sensitive awards on a publicly accessible website, and 2) reporting NED partners as first-tier sub awardees of the Department of State (DOS) on a public website of federal funding accountability undermines the Congress' intentional decision to protect the independence of NED's programmatic decision-making when it crafted the NED Act. With the intention of balancing the legitimate concerns for our NED grantees with our desire to comply with the spirit of transparency and accountability rooted in FFATA, NED renewed discussions with Department of State officials to find a resolution to this issue. The leadership at NED and at State’s Bureau of Democracy, Human Rights, and Labor jointly assessed the issue to determine a long-term solution. Following the development of a Duty of Care policy outlining NED’s institutional obligations to “do no harm” with respect to the safety and security of our stakeholders, including NED grantees, NED management has since reached an agreement with our DOS Grants Officer to designate NED’s annual appropriation award as “sensitive” and therefore not subject to the annual FFATA reporting requirements. We have since received NED’s annual award for2024 with language matching several of our special funds DOS awards: “This award has been deemed sensitive and is not subject to the Federal Funding Accountability and Transparency Act (FFATA).” We expect the same terms to apply to our awards going forward which, ensuring a permanent resolution to this issue. Name of Responsible Official: Nancy Herzog, Title: VP, Grant Operations & Evaluation Date correction action executed: 11/29/2023.
2022-001
FAC accepted this audit on February 14, 2023 — management decision was due August 14, 2023.
Finding 2022-001: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA) Agency and Award: U.S. Department of State, Assistance Listing Number 19.345 Criteria: Under the requirements of the Federal Funding and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the Transparency Act that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the Federal Acquisition Regulation (FAR). Condition and context: The Endowment works with sub awardees and some of its awards require compliance with the FFATA requirement. Even though NED is aware of the FFATA requirement, NED does not report its subawards in the required system. Questioned costs: None Repeat finding: Yes Effect: The Endowment is in non-compliance with FFATA reporting requirements. No other reporting issues noted. Cause: The Endowment works with many grantees that work in high-risk countries and concluded that complying with the requirement, would put its grantees at risk. Recommendation: We recommend management continues to work with its grant officers to obtain a waiver and implement procedures to ensure grants are evaluated for reporting requirements under FFATA and if required, the reporting is completed within the required timeframe required. View of responsible officials and planned corrective actions: Management acknowledges the FFATA requirement and will continue working with the grant officers. See corrective action plan 2022.
Show full finding ▾Hide full finding ▴Finding 2022-001: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA) Agency and Award: U.S. Department of State, Assistance Listing Number 19.345 Criteria: Under the requirements of the Federal Funding and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the Transparency Act that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the Federal Acquisition Regulation (FAR). Condition and context: The Endowment works with sub awardees and some of its awards require compliance with the FFATA requirement. Even though NED is aware of the FFATA requirement, NED does not report its subawards in the required system. Questioned costs: None Repeat finding: Yes Effect: The Endowment is in non-compliance with FFATA reporting requirements. No other reporting issues noted. Cause: The Endowment works with many grantees that work in high-risk countries and concluded that complying with the requirement, would put its grantees at risk. Recommendation: We recommend management continues to work with its grant officers to obtain a waiver and implement procedures to ensure grants are evaluated for reporting requirements under FFATA and if required, the reporting is completed within the required timeframe required. View of responsible officials and planned corrective actions: Management acknowledges the FFATA requirement and will continue working with the grant officers. See corrective action plan 2022.
Management?s Response and Corrective Action Plan: As noted in the audit, NED management is and has been aware of the FFATA reporting requirements. For the record, NED management takes a serious approach to FFATA regulations. NED?s concerns regarding FFATA compliance are rooted in concern for our grantees working in the sphere of human rights and democracy, particularly those NED partners working in the world?s most hostile authoritarian countries. As stated in our response to the FY 21 Audit, NED staff analysis of the potential reporting requirements recognized two significant risks to NED?s partners and the success of its programs: 1) reporting all first-tier subawardees would mean posting the identity of recipients and details of sensitive awards on a publicly accessible website, and 2) reporting NED partners as first-tier subawardees of the Department of State on a public website of federal funding accountability undermines the Congress? intentional decision to protect the independence of NED?s programmatic decision-making when it crafted the NED Act. However, NED seeks to balance these legitimate concerns with our desire to comply with the spirit of transparency rooted in FFATA, recognizing the importance of transparency and accountability as foundational tenets of a democratic society. As NED management stated in response to the FY 21 audit, in 2015, DOS offered NED the option of case-by-case waivers of individual subgrantees, rather than a per-country or blanket waiver of subgrantees which would have allowed for a practicable solution to meet the reporting requirements. In response and with notice to DOS, NED proposed and implemented an alternate method of compliance by posting information about subrecipients and funded programs on a searchable online database with content controlled by NED, with anonymized records for sensitive programs. This flexibility is essential to NED?s sensitive grantmaking program, where we often must make quick adjustments to anonymize information when partners face new risks in their operating environment. In total, NED currently has more than 700 grants in 50 countries requiring special protection of grantee identities. Corrective Action Plan NED renewed discussions to find a resolution to this issue in 2022, with leadership at NED and at DOS serving as a catalyst for a fresh approach to the issue. In our correspondence and discussion with DOS officials, NED management and staff have continually cited the legitimate concern for the security of our grantees and that the disclosure of NED?s grantees on a federal website runs contrary to NED?s standing as an independent entity. In response, DOS once again stated that a blanket waiver was not possible. Further, DOS advised NED that it approached OMB on this issue and that OMB would not entertain granting a formal exemption to NED. Unfortunately, this response from DOS fails to address NED?s concerns or offer any solutions regarding risks that public disclosure poses to its grantees. We aim to prevent this from becoming a reoccurring issue on our audits, and NED management believes there are viable solutions beyond a blanket exemption. It is NED?s understanding that DOS conducts its own assessment of risks to grantees before any public disclosure, and issues waivers from disclosure for individual grants deemed sensitive. NED would like to learn more about the process DOS uses to make that risk determination and apply it to the disclosure requirements related to NED?s most sensitive grants. Further, NED would like to explore using NED?s public website portal to disclose all non-sensitive grants to maintain a level of transparency. This would allow NED the flexibility to respond to evolving threats to our grantees and allow for public disclosure without using a US government website. NED Management is continuing the discussion of FFATA compliance with the Department of State and is scheduled to meet with the Acting Assistant Secretary, Bureau of Democracy, Human Rights, and Labor and other senior DOS staff to find a path forward on this issue. As stated above, NED takes this issue seriously and management will work on a solution to this issue that is consistent with NED?s mission and one that prioritizes the security of NED?s most vulnerable partners around the world. Responsible person is: Maju Varghese, Chief Operating Officer Anticipated completion date: 09/30/2023
2021-001
FAC accepted this audit on June 15, 2022 — management decision was due December 15, 2022.
Finding 2021-001: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA) Award: All Criteria: Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the Federal Acquisition Regulation (FAR). Condition and context: NED works with sub awardees and is aware of the FFATA requirement. However, the sub awardees were not reported within the system. Questioned costs: None Repeat finding: No Effect: The Endowment is in non-compliance with FFATA reporting requirements. No other reporting issues noted. Cause: The Endowment works with many grantees that work in high-risk countries and concluded that complying with the requirement, would put its grantees at risk. Recommendation: We recommend management continues to work with its grant officers to obtain a waiver and implement procedures to ensure grants are evaluated for reporting requirements under FFATA and if required, the reporting is completed within the required timeframe required. View of responsible officials and planned corrective actions: Management acknowledges the FFATA requirement and will continue working with the grant officers. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-001: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA) Award: All Criteria: Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the Federal Acquisition Regulation (FAR). Condition and context: NED works with sub awardees and is aware of the FFATA requirement. However, the sub awardees were not reported within the system. Questioned costs: None Repeat finding: No Effect: The Endowment is in non-compliance with FFATA reporting requirements. No other reporting issues noted. Cause: The Endowment works with many grantees that work in high-risk countries and concluded that complying with the requirement, would put its grantees at risk. Recommendation: We recommend management continues to work with its grant officers to obtain a waiver and implement procedures to ensure grants are evaluated for reporting requirements under FFATA and if required, the reporting is completed within the required timeframe required. View of responsible officials and planned corrective actions: Management acknowledges the FFATA requirement and will continue working with the grant officers. See corrective action plan.
As noted, NED management is and has been aware of the FFATA reporting requirements since well before the Department of State began implementation of those requirements by incorporating them in their standard award terms and conditions in 2015. NED staff analysis of the potential reporting requirements recognized two significant risks to NED?s partners and the success of their programs: 1) reporting all first-tier subawardees would mean posting the identity of recipients and details of sensitive awards on a publicly accessible website, creating a risk to the work and individual safety of our many partners operating in hostile environments, and 2) reporting NED partners as first-tier subawardees of the Department of State on a public website of federal funding accountability undermines the Congress? intentional decision to protect the independence of NED?s programmatic decision-making when it crafted the NED Act (P.L. 98-164), and can negatively impact the work of partners around the world. These risks are not insignificant. In a rapidly growing number of countries, organizations are being invaded by security police, their files are being confiscated and various punitive fines are being levied in an effort to shut down their work. More concerning, laws are being imposed that allow for individuals to be prosecuted for their foreign relationships and imprisoned and tortured for short and exceptionally long terms. Finally, there are both state and non-state actors who physically attack and even kill journalists and other activists for their work and relationships with foreign organizations. After identifying these risks, NED management in 2011 sought guidance from officials at OMB, who confirmed that overseas programs were not considered when the requirements were established. NED requested a waiver from the requirements at that time with no response from OMB. In the interim, NED continued to study the requirements and prepared for eventual reporting. In 2015, DOS implemented the requirements and offered the option of case-by-case waivers of individual subgrantees, rather than a per-country or blanket waiver of subgrantees which would have allowed for a practicable solution. Without an option for remediation that would protect NED?s grantees and programs, NED proposed and implemented an alternate method of compliance by posting information about subrecipients and funded programs on a searchable online database with content controlled by NED, with anonymized records for sensitive programs. NED informed the Department of State?s Under-Secretary for Management, our Grants Officer, and our auditor of our approach, which allowed immediate edits when needed to mitigate risk to grantees in rapidly evolving high-risk circumstances. In the past year alone, NED moved listings of more than 100 grantees in 12 countries into an anonymized status on an urgent basis. In total, NED currently has more than 600 grants in 50 countries requiring special protection of grantee identities. NED Management has since renewed the discussion of FFATA compliance with the Department of State and on May 19, 2022, sent correspondence to the department to address NED?s concern with reporting first-tier subawards under our discretionary grants program. The response from DOS is pending. NED also intends to brief its Congressional contacts regarding its concerns with the impact of the FFATA reporting requirements on NED?s first-tier subawardees. Maju Varghese Chief Operating Officer
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