EIN: 521693387
UEI: CVD4R2ES1XZ1
Showing data from August 24, 2026 — the Federal Audit Clearinghouse is under high demand right now, so this couldn't be refreshed. This is the most recent data on record, not necessarily today's.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 19, 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 June 19, 2022 (1529 days ago).
What is a management decision? →WWF?s policies are designed to ensure expenses are reviewed and approved timely to ensure proper recording on the accrual basis of accounting. Our testing in various compliance areas identified one instance where the expense was not recorded in the correct financial reporting period in accordance with the accrual basis of accounting. For major program 19.017, we identified one instance of seven samples tested, where a prior year expense was recorded in the current fiscal year SEFA, resulting in an overstatement of fiscal year 2021 expenses of $6,666. This related to award number SLMAQM18CA2054. We were able to conclude that the expense occurred within the period of performance of the award and was an allowable award expenditure. Questioned Costs: None. Context: This is a condition identified per review of WWF?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. A nonstatistical sampling method was used. Cause: WWF has documented expenditure policies and procedures regarding the timely processing and approval of expenditures incurred. However, as identified above, the timely processing of the expenditure did not occur resulting in the error 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.
Show full finding ▾Hide full finding ▴2021-001 Internal Control Over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles See Schedule of Findings and Questioned Costs for chart/table Criteria or Specific Requirement: In accordance with ?200.303 Internal Controls 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. 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); (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. Condition: WWF?s policies are designed to ensure expenses are reviewed and approved timely to ensure proper recording on the accrual basis of accounting. Our testing in various compliance areas identified one instance where the expense was not recorded in the correct financial reporting period in accordance with the accrual basis of accounting. For major program 19.017, we identified one instance of seven samples tested, where a prior year expense was recorded in the current fiscal year SEFA, resulting in an overstatement of fiscal year 2021 expenses of $6,666. This related to award number SLMAQM18CA2054. We were able to conclude that the expense occurred within the period of performance of the award and was an allowable award expenditure. Questioned Costs: None. Context: This is a condition identified per review of WWF?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. A nonstatistical sampling method was used. Cause: WWF has documented expenditure policies and procedures regarding the timely processing and approval of expenditures incurred. However, as identified above, the timely processing of the expenditure did not occur resulting in the error 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.
2021-001 Internal Control Over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Contact: Leroy Wade Title: Controller Phone Number: 202-293-4800 Estimated Completion Date ? August 2022 Corrective Action ? WWF management will adhere to documented policies and procedures regarding the timely processing and recording of expenditures. WWF management will perform a more detailed review of invoices to ensure expenses are recorded timely.
During our testing of the cash management compliance requirements for major program 98.001, we identified four instances out of 18 samples selected for testing, where evidence supporting the control related to the approval of the cash draw down prior to submission was unable to be provided. Questioned Costs: None. Context: The condition was identified as part of testing performed on WWF?s compliance with the cash management provisions of the Uniform Guidance and WWF?s policy on cash drawdowns. We selected a sample of 18 expense reimbursement packages underlying the three cash drawdowns for CFDA Number 98.001 as part of our testing of internal controls over compliance related to the cash management compliance requirement. Of those 18 samples, four samples did not have evidence of the required approval, as documented in ?condition? above. Cause: WWF has established policies and procedures around cash management. However, WWF management did not adhere to its documented policies and procedures regarding authorization and approval of USAID drawdowns. 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.
Show full finding ▾Hide full finding ▴2021-002 Internal Control over Compliance and Compliance ? Cash Management See Schedule of Findings and Questioned Costs for chart/table Criteria or Specific Requirement: In accordance with ?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. 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); (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. In accordance with ?200.305(b), payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition: During our testing of the cash management compliance requirements for major program 98.001, we identified four instances out of 18 samples selected for testing, where evidence supporting the control related to the approval of the cash draw down prior to submission was unable to be provided. Questioned Costs: None. Context: The condition was identified as part of testing performed on WWF?s compliance with the cash management provisions of the Uniform Guidance and WWF?s policy on cash drawdowns. We selected a sample of 18 expense reimbursement packages underlying the three cash drawdowns for CFDA Number 98.001 as part of our testing of internal controls over compliance related to the cash management compliance requirement. Of those 18 samples, four samples did not have evidence of the required approval, as documented in ?condition? above. Cause: WWF has established policies and procedures around cash management. However, WWF management did not adhere to its documented policies and procedures regarding authorization and approval of USAID drawdowns. 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.
2021-002 Internal Control over Compliance and Compliance ? Cash Management Contact: Leroy Wade Title: Controller Phone Number: 202-293-4800 Estimated Completion Date ? March 2022 Corrective Action ? As part of the documented policies and procedures regarding the authorization and approval of USAID drawdowns, approval is evidenced by email. The four instances noted relate to one drawdown request. WWF Management did not retain the email with the explicit ?I approve? notation within the email exchanges for the drawdown. To mitigate future risk, management has updated the process to use electronic signatures for approvals rather than email. Electronic signature of approval will be obtained prior to submission and receipt of funding and will be retained with the drawdown request documentation.
FAC accepted this audit on March 3, 2021 — management decision was due September 3, 2021.
During our testing of internal control over compliance related to the cost sharing and matching compliance requirement we were able to examine the expense reports provided to WWF by the subrecipients. However, WWF was not able to provide adequate evidence of the required review and approval of the expenses contained within those reports. This deficiency in internal control over compliance is related to the following agreements: CFDA Number Award Number 19.017 SLMAQM18CA2090 15.651 F18AC00846 98.001 72044218CA00001 98.001 AID-367-A-16-00008 Additionally, during our testing of compliance with the cost-sharing and matching requirements for CFDA No. 98.001, Award Number 7200AA18LE00001, we identified two underlying expense transactions totaling $188 for which management was unable to provide adequate documentation to support the allowability of the transaction under the Uniform Guidance Subpart E ? Cost Principles. Questioned Costs: The $188 in costs identified above are considered to be likely questioned costs, as we were unable to examine adequate supporting documentation during the course of the audit to determine whether these costs were allowable or unallowable. Context: This is a condition identified based on the testing performed on WWF?s internal control over compliance and compliance with the cost sharing and matching provisions of the Uniform Guidance. For CFDA No. 19.017, of the two federal awards with cost sharing requirements in 2020, we tested one of the awards which resulted in the internal control matter included within the condition paragraph above. For CFDA No. 15.651, only one federal award had cost sharing requirements in 2020 which resulted in the internal control matter included within the condition paragraph above. For CFDA No. 98.001, of the seven federal awards with cost sharing requirements in 2020, we tested six of the awards which resulted the internal control matter identified for the two awards listed in the condition paragraph above. For Award Number 7200AA18LE00001 under CFDA No. 98.001, we tested 42 underlying expenses for compliance with the provisions of ?200.306(b)(4) which resulted in the compliance matters identified in the condition paragraph above. A nonstatistical sampling method was used. Cause: WWF has documented policies and procedures surrounding the determination of costs used as part of their cost sharing and matching requirements. However, management?s review and approval of the expenses incurred as part of the cost sharing and matching requirements did not allow management to detect the unallowable costs identified above. Additionally, management did not adequately document their review and approval of the subrecipient expenses used to satisfy the cost sharing requirements. Effect: While the likely questioned costs that resulted from the conditions identified above were not material, 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: During 2019, unallowable costs were identified as part of the testing of the cost sharing requirement and were reported as finding 2019-003 in the prior year report. While the type of unallowable cost reporting in the prior year finding is not the same as in the current year, and the internal control matter related to subrecipient expenses utilized for cost share was not reported in the prior year, that fact that there were deficiencies identified during the prior year audit require reporting as a repeat finding. Recommendation: To strengthen internal controls over compliance related to subrecipient expenses used to satisfy matching requirements, we recommend WWF develop a standardized set of procedures for all awards, instead of the various ad hoc procedures currently utilized, inclusive of a checklist to evidence management?s review of the underlying expenditures used by the subrecipient as cost sharing expenditures. The procedures enacted and related supporting checklist should include information evidencing the transactions reviewed, WWF management?s conclusions on that review, and a signature by the individuals responsible for monitoring the subrecipient?s cost sharing transactions. In addition, WWF should consider providing training to individuals who determine expenditures that are used to cost share, either through direct expenditures provided by WWF or through expenses provided by subrecipients to ensure only allowable costs are utilized as part of that cost sharing or matching arrangement. Views of Responsible Officials: WWF management agrees with the findings and recommendations. The planned corrective actions are presented in the corrective action plan attached as Appendix A to the Single Audit Report.
Show full finding ▾Hide full finding ▴2020-001 Internal Control Over Compliance and Compliance - Cost Sharing and Matching Requirements Information on the Federal Program: United States Agency for International Development CFDA Number: 98.001 CFDA Name: USAID Foreign Assistance for Programs Overseas Grant Award Numbers under the Uniform Guidance Requirements: Award Number Award Period 72044218CA00001 March 30, 2018 ? March 29, 2021 AID-367-A-16-00008 July 15, 2016 ? July 14, 2021 7200AA18LE00001 August 27, 2018 ? August 26, 2023 United States Department of State CFDA Number: 19.017 CFDA Name: Environmental and Scientific Partnerships and Programs Grant Award Numbers under the Uniform Guidance Requirements: Award Number Award Period SLMAQM18CA2090 September 24, 2018 ? September 30, 2021 United States Fish and Wildlife Service CFDA Number: 15.651 CFDA Name: Central Africa Regional Grant Award Numbers under the Uniform Guidance Requirements: Award Number Award Period F18AC00846 October 1, 2018 ? September 30, 2019 Criteria or Specific Requirement: In accordance with ?200.303 Internal Controls 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. 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); (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, In accordance with ?200.306(b)(4), Cost sharing or matching, for all Federal awards, any shared costs or matching funds and all contributions, including cash and third-party in-kind contributions, must be accepted as part of the non-Federal entities? cost sharing or matching when such contributions are allowable under Subpart E ? Cost Principles. Condition: During our testing of internal control over compliance related to the cost sharing and matching compliance requirement we were able to examine the expense reports provided to WWF by the subrecipients. However, WWF was not able to provide adequate evidence of the required review and approval of the expenses contained within those reports. This deficiency in internal control over compliance is related to the following agreements: CFDA Number Award Number 19.017 SLMAQM18CA2090 15.651 F18AC00846 98.001 72044218CA00001 98.001 AID-367-A-16-00008 Additionally, during our testing of compliance with the cost-sharing and matching requirements for CFDA No. 98.001, Award Number 7200AA18LE00001, we identified two underlying expense transactions totaling $188 for which management was unable to provide adequate documentation to support the allowability of the transaction under the Uniform Guidance Subpart E ? Cost Principles. Questioned Costs: The $188 in costs identified above are considered to be likely questioned costs, as we were unable to examine adequate supporting documentation during the course of the audit to determine whether these costs were allowable or unallowable. Context: This is a condition identified based on the testing performed on WWF?s internal control over compliance and compliance with the cost sharing and matching provisions of the Uniform Guidance. For CFDA No. 19.017, of the two federal awards with cost sharing requirements in 2020, we tested one of the awards which resulted in the internal control matter included within the condition paragraph above. For CFDA No. 15.651, only one federal award had cost sharing requirements in 2020 which resulted in the internal control matter included within the condition paragraph above. For CFDA No. 98.001, of the seven federal awards with cost sharing requirements in 2020, we tested six of the awards which resulted the internal control matter identified for the two awards listed in the condition paragraph above. For Award Number 7200AA18LE00001 under CFDA No. 98.001, we tested 42 underlying expenses for compliance with the provisions of ?200.306(b)(4) which resulted in the compliance matters identified in the condition paragraph above. A nonstatistical sampling method was used. Cause: WWF has documented policies and procedures surrounding the determination of costs used as part of their cost sharing and matching requirements. However, management?s review and approval of the expenses incurred as part of the cost sharing and matching requirements did not allow management to detect the unallowable costs identified above. Additionally, management did not adequately document their review and approval of the subrecipient expenses used to satisfy the cost sharing requirements. Effect: While the likely questioned costs that resulted from the conditions identified above were not material, 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: During 2019, unallowable costs were identified as part of the testing of the cost sharing requirement and were reported as finding 2019-003 in the prior year report. While the type of unallowable cost reporting in the prior year finding is not the same as in the current year, and the internal control matter related to subrecipient expenses utilized for cost share was not reported in the prior year, that fact that there were deficiencies identified during the prior year audit require reporting as a repeat finding. Recommendation: To strengthen internal controls over compliance related to subrecipient expenses used to satisfy matching requirements, we recommend WWF develop a standardized set of procedures for all awards, instead of the various ad hoc procedures currently utilized, inclusive of a checklist to evidence management?s review of the underlying expenditures used by the subrecipient as cost sharing expenditures. The procedures enacted and related supporting checklist should include information evidencing the transactions reviewed, WWF management?s conclusions on that review, and a signature by the individuals responsible for monitoring the subrecipient?s cost sharing transactions. In addition, WWF should consider providing training to individuals who determine expenditures that are used to cost share, either through direct expenditures provided by WWF or through expenses provided by subrecipients to ensure only allowable costs are utilized as part of that cost sharing or matching arrangement. Views of Responsible Officials: WWF management agrees with the findings and recommendations. The planned corrective actions are presented in the corrective action plan attached as Appendix A to the Single Audit Report.
2020-001 Internal Control Over Compliance and Compliance - Cost Sharing and Matching Requirements Contact: Leroy Wade Title: Controller Phone Number: 202-293-4800 Estimated Completion Date ? October 2021 Corrective Action ? WWF has a strong sub-recipient monitoring system in place. It starts with a detailed due diligence review and capacity assessment and continues with on-going programmatic and financial monitoring. Program Administrators provide oversight and ensure that financial reporting, including confirmation that cost-share requirements, meet and are in compliance with US Government rules and regulations. We note that the cost share review process is not documented on a consistent basis and in a uniform format. WWF will implement a standard sub-recipient monitoring template that will be reviewed on a consistent bases and is signed off by appropriate staff. In addition, WWF will require more detailed financial reporting from its sub-recipients. WWF will also continue to invest resources in training and capacity building of its subrecipients to ensure that only allowable costs that meet US Government regulations are used as cost share. WWF will ensure that any transaction without sufficient supporting documentation is not included as cost share.
2019-003
During our testing of the cash management compliance requirements, we identified two instances in which management requested funds based on inaccurate expenditure data, resulting in an overpayment from the Federal Agency. One overpayment for Award Number 72044218CA00001 totaling $108,814 and one overpayment for Award Number AID-367-A-16-00008 totaling $607,369. Management identified the error in expenditure data during the subsequent fiscal quarter and reduced the subsequent quarter?s payment request by the amount of the identified error. Management?s internal control procedures around cash management did not detect and prevent the inaccurate request for funds transfer prior to submission and receipt of the funding. Questioned Costs: Likely questioned costs consist of any interest earned on funds held by WWF related to the funds requested based on inaccurate expenditure data. Interest earned is considered to be deminimus and does not exceed the $25,000 questioned costs threshold. Context: The condition was identified as part of testing performed on WWF?s compliance with the cash management provisions of the Uniform Guidance. We selected a sample of 10 requests for reimbursement for CFDA Number 98.001 as part of our testing of internal controls over compliance related to the cash management compliance requirement. Of those 10 samples, two samples contained errors, as documented in ?condition? above. Cause: While WWF has established policies and procedures around cash management, WWF management?s review of the reimbursement requests and the underlying expenditure data supporting the amount of the reimbursement request was not adequate to identify the errors prior to submission. It is noted however, that management?s internal controls did detect the errors in the following quarter when the next payment request was generated. Effect: While there are no known questioned costs and likely questioned costs are considered to be deminimus related to incorrect funds requests, 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 or the requirement to remit any interest earned to the Federal agency for the incorrect request for reimbursement. Repeat Finding: This is not a repeat finding. Recommendation: We recommend WWF management revisit cash management policies and procedures to prevent incorrect funds requests. The cash management policies and internal control procedures should include a detailed review of any accruals or estimates of expenditures to ensure those are removed from the funds request. Views of Responsible Officials: WWF management agrees with the findings and recommendations. The planned corrective actions are presented in the corrective action plan attached as Appendix A to the Single Audit Report.
Show full finding ▾Hide full finding ▴2020-002 Internal Control over Compliance and Compliance ? Cash Management Information on Federal Programs: United States Agency for International Development CFDA Number: 98.001 CFDA Name: USAID Foreign Assistance for Programs Overseas Grant Award Numbers under the Uniform Guidance Requirements: Award Number Award Period AID-367-A-16-00008 July 15, 2016 ? July 14, 2021 72044218CA00001 March 30, 2018 ? March 29, 2021 Criteria or Specific Requirement: In accordance with ?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. 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); (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. In accordance with ?200.305(b), payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition: During our testing of the cash management compliance requirements, we identified two instances in which management requested funds based on inaccurate expenditure data, resulting in an overpayment from the Federal Agency. One overpayment for Award Number 72044218CA00001 totaling $108,814 and one overpayment for Award Number AID-367-A-16-00008 totaling $607,369. Management identified the error in expenditure data during the subsequent fiscal quarter and reduced the subsequent quarter?s payment request by the amount of the identified error. Management?s internal control procedures around cash management did not detect and prevent the inaccurate request for funds transfer prior to submission and receipt of the funding. Questioned Costs: Likely questioned costs consist of any interest earned on funds held by WWF related to the funds requested based on inaccurate expenditure data. Interest earned is considered to be deminimus and does not exceed the $25,000 questioned costs threshold. Context: The condition was identified as part of testing performed on WWF?s compliance with the cash management provisions of the Uniform Guidance. We selected a sample of 10 requests for reimbursement for CFDA Number 98.001 as part of our testing of internal controls over compliance related to the cash management compliance requirement. Of those 10 samples, two samples contained errors, as documented in ?condition? above. Cause: While WWF has established policies and procedures around cash management, WWF management?s review of the reimbursement requests and the underlying expenditure data supporting the amount of the reimbursement request was not adequate to identify the errors prior to submission. It is noted however, that management?s internal controls did detect the errors in the following quarter when the next payment request was generated. Effect: While there are no known questioned costs and likely questioned costs are considered to be deminimus related to incorrect funds requests, 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 or the requirement to remit any interest earned to the Federal agency for the incorrect request for reimbursement. Repeat Finding: This is not a repeat finding. Recommendation: We recommend WWF management revisit cash management policies and procedures to prevent incorrect funds requests. The cash management policies and internal control procedures should include a detailed review of any accruals or estimates of expenditures to ensure those are removed from the funds request. Views of Responsible Officials: WWF management agrees with the findings and recommendations. The planned corrective actions are presented in the corrective action plan attached as Appendix A to the Single Audit Report.
2020-002 Internal Control over Compliance and Compliance ? Cash Management Contact: Leroy Wade Title: Controller Phone Number: 202-293-4800 Estimated Completion Date ? March 2021 Corrective Action ? WWF acknowledges errors in the two fund requests which occurred as a result of an accounting error. As noted in the report, our internal controls detected and corrected both errors in a timely manner. The total requested funds for the fiscal year were based on accurate expenses. In the future, WWF will prevent this type of error by adding an additional accounting review and reconciliation for sub grant related expenses by both the Financial Reporting department and the Program Administrator prior to requesting funds. In addition, WWF has re-structured its Financial Reporting department and has brought additional resources with technical experience and expertise to strengthen existing preventative controls.
WWF management?s internal control procedures require a management-level review of financial reports prior to submission to the awarding agency. The management-level review did not identify the reporting errors identified below: CFDA No. 15.651 For Award Number F18AC00846, which is the only grant under the major program, there was only one financial report required for the major program during the fiscal year 2020. Therefore this report was selected for testing by BDO. The SF-425 report tested contained calculation errors related to indirect rates as well as the expenditures reported did not agree to WWF?s financial accounting system. Both discrepancies were corrected in a revised report submitted to the awarding agency. While not material discrepancies, management?s review did not identify these discrepancies prior to submission of these reports. CFDA No. 19.017 For this major program, we selected a non-statistical sample of six financial reports for testing. Of those six financial reports, two reports for award number S-LMAQM-18-CA-2054 contained errors. For one SF-425 report, the unliquidated obligations and the total federal expenditures did not agree to WWF?s financial accounting system. For the second SF-425 tested, the federal expenditures contained expenditures that were not included in WWF?s general ledger for the same period. The discrepancies identified above were corrected in the subsequent period SF-425 report. While not material discrepancies, management?s review did not identify these discrepancies prior to submission of the reports.. CFDA No. 98.001 For this major program, we selected a non-statistical sample of six financial reports. Of those six financial reports, four SF-425 reports contained errors in the reporting of indirect rates. The instructions for the SF-425 report require cumulative reporting; however, management reported the indirect costs only for the current reporting period. Management?s review did not identify the need to report on a cumulative basis. We did determine that the total federal expenditures reported within those four SF-425 reports were accurate and contained the cumulative direct and indirect expenditures for the financial report tested. Questioned Costs: There are no questioned costs as the items outlined above are internal control related matters and matters related to the accuracy of the information reported to the awarding agency in the financial reports. Context: This is a condition identified during BDO?s testing of the financial reporting requirements as outlined in the terms and conditions of the award documents. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Cause: The internal controls established for the oversight and approval of awarding agency financial reports did not operate as designed for instances noted above. Effect: Failure to perform adequate oversight and approval of financial reports could result in WWF providing information to the federal government that is incomplete or inaccurate which could lead to delayed funding. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements, and as set forth by the federal government, to ensure that the financial reports are accurate. Further, we recommend management implement a more comprehensive level of review of financial reports prior to issuance to address the reporting errors identified above. Views of Responsible Officials: WWF management agrees with the findings and recommendations. The planned corrective actions are presented in the corrective action plan attached as Appendix A to the Single Audit Report.
Show full finding ▾Hide full finding ▴2020-003 Internal Control over Compliance and Compliance ? Financial Reporting Information on Federal Programs: United States Agency for International Development CFDA Number: 98.001 CFDA Name: USAID Foreign Assistance for Programs Overseas Grant Award Numbers under the Uniform Guidance Requirements: Award Number Award Period 72044218CA00001 March 30, 2018 ? March 29, 2021 7200AA18LE00001 August 27, 2018 ? August 26, 2023 72052719CA00004 August 23, 2019 ? August 22, 2024 United States Department of State CFDA Number: 19.017 CFDA Name: Environmental and Scientific Partnerships and Programs Grant Award Numbers under the Uniform Guidance Requirements: Award Number Award Period SL-MAQM-18-CA-2054 September 17, 2018 ? August 31, 2021 United States Fish and Wildlife Service CFDA Number: 15.651 CFDA Name: Central Africa Regional Grant Award Numbers under the Uniform Guidance Requirements: Award Number Award Period F18AC00846 October 1, 2018 ? September 30, 2019 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. A federal awarding agency may solicit only the standard, Office of Management and Budget (OMB) approved government-wide data elements for collection of financial information, unless otherwise approved by the OMB in accordance with ?200.328, Financial Reporting. The information collected under this requirement must be collected with the frequency required by the terms and conditions of the federal award, but no less frequently than annually nor more frequently then quarterly except in unusual circumstances, for example where more frequent reporting if necessary for the effective monitoring of the federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The reports submitted to the federal awarding agency should be accurate. Condition: WWF management?s internal control procedures require a management-level review of financial reports prior to submission to the awarding agency. The management-level review did not identify the reporting errors identified below: CFDA No. 15.651 For Award Number F18AC00846, which is the only grant under the major program, there was only one financial report required for the major program during the fiscal year 2020. Therefore this report was selected for testing by BDO. The SF-425 report tested contained calculation errors related to indirect rates as well as the expenditures reported did not agree to WWF?s financial accounting system. Both discrepancies were corrected in a revised report submitted to the awarding agency. While not material discrepancies, management?s review did not identify these discrepancies prior to submission of these reports. CFDA No. 19.017 For this major program, we selected a non-statistical sample of six financial reports for testing. Of those six financial reports, two reports for award number S-LMAQM-18-CA-2054 contained errors. For one SF-425 report, the unliquidated obligations and the total federal expenditures did not agree to WWF?s financial accounting system. For the second SF-425 tested, the federal expenditures contained expenditures that were not included in WWF?s general ledger for the same period. The discrepancies identified above were corrected in the subsequent period SF-425 report. While not material discrepancies, management?s review did not identify these discrepancies prior to submission of the reports.. CFDA No. 98.001 For this major program, we selected a non-statistical sample of six financial reports. Of those six financial reports, four SF-425 reports contained errors in the reporting of indirect rates. The instructions for the SF-425 report require cumulative reporting; however, management reported the indirect costs only for the current reporting period. Management?s review did not identify the need to report on a cumulative basis. We did determine that the total federal expenditures reported within those four SF-425 reports were accurate and contained the cumulative direct and indirect expenditures for the financial report tested. Questioned Costs: There are no questioned costs as the items outlined above are internal control related matters and matters related to the accuracy of the information reported to the awarding agency in the financial reports. Context: This is a condition identified during BDO?s testing of the financial reporting requirements as outlined in the terms and conditions of the award documents. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Cause: The internal controls established for the oversight and approval of awarding agency financial reports did not operate as designed for instances noted above. Effect: Failure to perform adequate oversight and approval of financial reports could result in WWF providing information to the federal government that is incomplete or inaccurate which could lead to delayed funding. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management adhere to its documented policies and procedures and the documented instructions for reporting requirements contained within grant agreements, and as set forth by the federal government, to ensure that the financial reports are accurate. Further, we recommend management implement a more comprehensive level of review of financial reports prior to issuance to address the reporting errors identified above. Views of Responsible Officials: WWF management agrees with the findings and recommendations. The planned corrective actions are presented in the corrective action plan attached as Appendix A to the Single Audit Report.
2020-003 Internal Control over Compliance and Compliance ? Financial Reporting Contact: Leroy Wade Title: Controller Phone Number: 202-293-4800 Estimated Completion Date: March 2021 Corrective Action - Management recognizes the need to implement a more detailed review process for financial reports. This was in large part due to staff transition. Since then and as mentioned above, the Financial Reporting Department has been strengthened with experienced management-level staff who have financial reporting experience. We don?t expect this finding to be repeated.
During our testing of the subrecipient monitoring compliance requirement, we tested monitoring for 20 subrecipients under CFDA 98.001 and five subrecipients under CFDA 19.017. Of the subrecipients tested, we identified three instances, as noted under the information about Federal awards above, where WWF management did not perform the required risk assessment. Management?s internal processes and procedures did not identify the need to perform a risk assessment on these subrecipients due to the small value of the subrecipient grants. Questioned Costs: Not determinable. Context: This is a condition per review of WWF?s compliance with specified requirements for subrecipient monitoring. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Cause: WWF management?s internal policies and procedures around subrecipient monitoring were not designed to require risk assessment for certain subrecipients deemed to be ?low risk? in accordance with thresholds established by management. This policy does not adhere to the thresholds and requirements of the Uniform Guidance. Effect: Failure to comply with the subrecipient monitoring requirement of the Uniform Guidance could result in disallowed costs for certain subrecipients that are not adequately monitored. Repeat Finding: During 2019, improper accruals of subrecipient expenses were identified and unallowable costs were reported as part of the testing of the subrecipient monitoring compliance requirement. This was reported as finding 2019-004 in the prior year report. While the type of subrecipient monitoring compliance finding is not the same as 2019, the fact that there were deficiencies identified around subrecipient monitoring in both 2019 and 2020 require reporting as a repeat finding. Recommendation: We recommend management review the requirements outlined in ?200.331, ?200.332, and ?200.333 to ensure WWF?s policies comply with the requirements of the Uniform Guidance. More specifically, WWF must perform a risk assessment on all subrecipients or each new grant awarded. Finally, we recommend management develop standardized tools and templates to ensure compliance at a global level. Documentation of reviews and approvals related to subrecipient monitoring should be maintained as evidence that established internal controls are functioning as designed. Views of Responsible Officials: WWF management agrees with the findings and recommendations. The planned corrective actions are presented in the corrective action plan attached as Appendix A to the Single Audit Report.
Show full finding ▾Hide full finding ▴2020-004 Internal Control over Compliance and Compliance - Subrecipient Monitoring Information on Federal Programs: United States Agency for International Development CFDA Number: 98.001 CFDA Name: USAID Foreign Assistance for Programs Overseas Grant Award Numbers under the Uniform Guidance Requirements: Award Number Award Period 72067419CA00006 March 29, 2019 ? March 28, 2021 United States Department of State CFDA Number: 19.017 CFDA Name: Environmental and Scientific Partnerships and Programs Grant Award Numbers under the Uniform Guidance Requirements: Award Number Award Period S-LMAQM-16-CA-1267 September 19, 2016 ? March 31, 2020 S-LMAQM-18-CA-2054 September 17, 2018 ? August 31, 2021 Criteria or Specific Requirement: In accordance with ?200.332(b), ?200.331(d), and ?200.331(f), Requirements for Pass-Through Entities, WWF must evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: During our testing of the subrecipient monitoring compliance requirement, we tested monitoring for 20 subrecipients under CFDA 98.001 and five subrecipients under CFDA 19.017. Of the subrecipients tested, we identified three instances, as noted under the information about Federal awards above, where WWF management did not perform the required risk assessment. Management?s internal processes and procedures did not identify the need to perform a risk assessment on these subrecipients due to the small value of the subrecipient grants. Questioned Costs: Not determinable. Context: This is a condition per review of WWF?s compliance with specified requirements for subrecipient monitoring. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Cause: WWF management?s internal policies and procedures around subrecipient monitoring were not designed to require risk assessment for certain subrecipients deemed to be ?low risk? in accordance with thresholds established by management. This policy does not adhere to the thresholds and requirements of the Uniform Guidance. Effect: Failure to comply with the subrecipient monitoring requirement of the Uniform Guidance could result in disallowed costs for certain subrecipients that are not adequately monitored. Repeat Finding: During 2019, improper accruals of subrecipient expenses were identified and unallowable costs were reported as part of the testing of the subrecipient monitoring compliance requirement. This was reported as finding 2019-004 in the prior year report. While the type of subrecipient monitoring compliance finding is not the same as 2019, the fact that there were deficiencies identified around subrecipient monitoring in both 2019 and 2020 require reporting as a repeat finding. Recommendation: We recommend management review the requirements outlined in ?200.331, ?200.332, and ?200.333 to ensure WWF?s policies comply with the requirements of the Uniform Guidance. More specifically, WWF must perform a risk assessment on all subrecipients or each new grant awarded. Finally, we recommend management develop standardized tools and templates to ensure compliance at a global level. Documentation of reviews and approvals related to subrecipient monitoring should be maintained as evidence that established internal controls are functioning as designed. Views of Responsible Officials: WWF management agrees with the findings and recommendations. The planned corrective actions are presented in the corrective action plan attached as Appendix A to the Single Audit Report.
2020-004 Internal Control over Compliance and Compliance - Subrecipient Monitoring Contact: Leroy Wade Title: Controller Phone Number: 202-293-4800 Estimated Completion Date: March 2021 Corrective Action - WWF has strong due diligence and risk assessments processes in place. Due to the large volume of subrecipients, WWF has implemented a different review process for recipients with small value in funding. The risk review is conducted even for these recipients; however, we acknowledge it is not as robust as for recipients who receive greater amounts in funding. Management will revisit the existing policy and, in the future will require that all sub-recipients have documented risk assessments.
2019-004
FAC accepted this audit on February 5, 2020 — management decision was due August 5, 2020.
During our testing of cost allowability included in the WWF indirect cost pool, we selected 60 expenses for testing using a nonstatistical sampling approach. Of those 60 expenses, we identified one instance totaling $25,594 that was improperly recorded as WWF expenses instead of a transaction for which WWF would be reimbursed. Questioned Costs: The likely questioned costs across all program on the schedule of expenditures of federal awards is approximately $1,526. Context: This is a condition identified per review of WWF?s compliance with the allowability provisions of the Uniform Guidance. The prevalence of this finding is detailed in the condition section above. In order to determine the likely questioned costs associated with this finding, we recalculated the indirect cost rate excluding the unallowable expenditure noted above. By removing the $25,594 from the pool of costs, the indirect cost rate decreased by 0.013%. We applied this decrease to the total expenditures subject to the indirect cost rate for all programs on the schedule of expenditures of federal awards in order to estimate the questioned costs amount. The likely questioned costs apply to all programs in totality. Cause: WWF?s transactional review process did not properly detect the incorrect transaction that was recorded in the accounting records. Effect: While the known and likely questioned costs that resulted from the conditions identified above were not material to the SEFA, the lack of adherence to the established internal control policies and procedures with respect to review of transactions and account coding 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: During 2018, unallowable travel costs were identified as part of the testing of the pool of indirect expenses. These unallowable travel costs were reported as finding 2018-001 in the prior year report. While the type of unallowable cost reported in the prior year finding is not the same as in the current year, the fact that unallowable costs were identified in the indirect rate cost pool require the reporting as a repeat finding. Recommendation: We recommend that management ensure each transaction is reviewed in accordance with established procedures and the review is properly documented by an individual with the experience to do so. Views of Responsible Officials: Management agrees with the finding. The noted disallowed cost was the result of a misinterpretation of the nature of the transaction. WWF was reimbursed by third parties for the cost and the transaction should not have been recorded as an expense. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴2019-002 Internal Control Over Compliance and Compliance with Allowable Costs and Cost Principles for Indirect Costs Information on Federal Programs: All programs are affected by this finding. Criteria or Specific Requirement: In accordance with ?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. 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); (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. In addition, indirect costs are required to conform to the allowability cost provisions in 2 CFR 200, Subpart E. In accordance with the financial management requirements contained in ?200.302(b)(3), the financial management system of each non-Federal entity should require records that identify adequately the source of funds and those records should be supported by source documentation. Condition: During our testing of cost allowability included in the WWF indirect cost pool, we selected 60 expenses for testing using a nonstatistical sampling approach. Of those 60 expenses, we identified one instance totaling $25,594 that was improperly recorded as WWF expenses instead of a transaction for which WWF would be reimbursed. Questioned Costs: The likely questioned costs across all program on the schedule of expenditures of federal awards is approximately $1,526. Context: This is a condition identified per review of WWF?s compliance with the allowability provisions of the Uniform Guidance. The prevalence of this finding is detailed in the condition section above. In order to determine the likely questioned costs associated with this finding, we recalculated the indirect cost rate excluding the unallowable expenditure noted above. By removing the $25,594 from the pool of costs, the indirect cost rate decreased by 0.013%. We applied this decrease to the total expenditures subject to the indirect cost rate for all programs on the schedule of expenditures of federal awards in order to estimate the questioned costs amount. The likely questioned costs apply to all programs in totality. Cause: WWF?s transactional review process did not properly detect the incorrect transaction that was recorded in the accounting records. Effect: While the known and likely questioned costs that resulted from the conditions identified above were not material to the SEFA, the lack of adherence to the established internal control policies and procedures with respect to review of transactions and account coding 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: During 2018, unallowable travel costs were identified as part of the testing of the pool of indirect expenses. These unallowable travel costs were reported as finding 2018-001 in the prior year report. While the type of unallowable cost reported in the prior year finding is not the same as in the current year, the fact that unallowable costs were identified in the indirect rate cost pool require the reporting as a repeat finding. Recommendation: We recommend that management ensure each transaction is reviewed in accordance with established procedures and the review is properly documented by an individual with the experience to do so. Views of Responsible Officials: Management agrees with the finding. The noted disallowed cost was the result of a misinterpretation of the nature of the transaction. WWF was reimbursed by third parties for the cost and the transaction should not have been recorded as an expense. See management?s corrective action plan.
2019-002 Internal Control Over Compliance and Compliance with Allowable Costs and Cost Principles for Indirect Costs Contact: Leroy Wade Title: Controller Phone Number: 202-293-4800 Estimated Completion Date ? January 2020 Corrective Action ? WWF will retrain and remind its staff about specific areas that need to be reviewed to ensure all costs are allocable and allowable. A special emphasis will be made on the review and approval process of the journal entries.
2018-001
During our testing of the federal award identified above, we selected a total of six expenses that were used as cost-sharing or matching expenses. For three of six samples tested, alcoholic beverages were included in the amounts reported as cost share. In accordance with Subpart E ? Cost Principles, specifically ?200.423, alcoholic beverages are unallowable. Questioned Costs: Known questioned costs totaled $45. Context: This is a condition identified based on the testing performed on WWF?s compliance with the cost sharing and matching provisions of the Uniform Guidance. There were eight federal awards with cost sharing requirements in 2019. BDO tested 22 underlying expense transactions for compliance with the provisions of ?200.306(b)(4). A nonstatistical sampling method was used. Cause: WWF has documented policies and procedures surrounding the determination of costs used as part of their cost sharing and matching requirements. However, management?s review and approval of the expenses incurred as part of the cost sharing and matching requirements did not allow management to detect the unallowable costs identified above. Effect: While the known questioned costs that resulted from the conditions identified above were not material, 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 is not a repeat finding. Recommendation: We recommend that WWF provide training to individuals who determine expenditures that are used to cost share and ensure there is a review process in place when reporting cost share to donors to ensure only allowable costs are utilized as part of that cost sharing or matching arrangement. Views of Responsible Officials: Management agrees with the finding. The noted costs were segregated to an unallowable ledger account within WWF accounting records. However, an oversight of these cost occurred during the cost sharing review. Systems and processes are in place to ensure that this type of expense is isolated and not charged to the donor. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴2019-003 Internal Control Over Compliance and Compliance with Cost Sharing and Matching Requirements Information on the Federal Program: United States Agency for International Development CFDA Number: 98.001 CFDA Name: USAID Foreign Assistance for Programs Overseas Grant Award Numbers under the Uniform Guidance Requirements: Award Number: 7200AA18LE00001 Award Period: September 27, 2018 through August 26, 2023 Criteria or Specific Requirement: In accordance with ?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. 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); (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, In accordance ?200.306(b)(4), Cost sharing or matching, for all Federal awards, any shared costs or matching funds and all contributions, including cash and third-party in-kind contributions, must be accepted as part of the non-Federal entities? cost sharing or matching when such contributions are allowable under Subpart E ? Cost Principles. Condition: During our testing of the federal award identified above, we selected a total of six expenses that were used as cost-sharing or matching expenses. For three of six samples tested, alcoholic beverages were included in the amounts reported as cost share. In accordance with Subpart E ? Cost Principles, specifically ?200.423, alcoholic beverages are unallowable. Questioned Costs: Known questioned costs totaled $45. Context: This is a condition identified based on the testing performed on WWF?s compliance with the cost sharing and matching provisions of the Uniform Guidance. There were eight federal awards with cost sharing requirements in 2019. BDO tested 22 underlying expense transactions for compliance with the provisions of ?200.306(b)(4). A nonstatistical sampling method was used. Cause: WWF has documented policies and procedures surrounding the determination of costs used as part of their cost sharing and matching requirements. However, management?s review and approval of the expenses incurred as part of the cost sharing and matching requirements did not allow management to detect the unallowable costs identified above. Effect: While the known questioned costs that resulted from the conditions identified above were not material, 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 is not a repeat finding. Recommendation: We recommend that WWF provide training to individuals who determine expenditures that are used to cost share and ensure there is a review process in place when reporting cost share to donors to ensure only allowable costs are utilized as part of that cost sharing or matching arrangement. Views of Responsible Officials: Management agrees with the finding. The noted costs were segregated to an unallowable ledger account within WWF accounting records. However, an oversight of these cost occurred during the cost sharing review. Systems and processes are in place to ensure that this type of expense is isolated and not charged to the donor. See management?s corrective action plan.
2019-003 Internal Control Over Compliance and Compliance with Cost Sharing and Matching Requirements Contact: Leroy Wade Title: Controller Phone Number: 202-293-4800 Estimated Completion Date: January 30, 2020 Corrective Action - WWF will retrain and remind its staff to identify disallowable cost whether directly charged to the grant or for cost sharing and matching. A global training is planned for the month of January where this topic will be addressed. The organization will also include an additional process review step, to ensure that small disallowable amounts are not used for cost sharing or matching. WWF will continue to review its policies and procedures to identify additional tools that can be used to manage small dollar transactions.
During our testing of subrecipient expenditures, we selected 40 transactions for testing using a nonstatistical sample. For one sample, we noted management recorded an accrual for expenditures that was not representative of the actual grant expenditures incurred during 2019. This resulted in an overstatement of subrecipient expenditures on the schedule of expenditures of federal awards of $185,444. Questioned Costs: The known questioned costs are $185,444. Context: This is a condition identified as part of our testing of subrecipient expenses. Because the expenses should not have been charged to the grant during 2019, the costs deemed unallowable. The prevalence of this finding is detailed in the condition section above. The error is material to the major program as the expenditures are overstated by $185,444. Cause: WWF?s subrecipient monitoring and management procedures failed to identify the error in expenditures charged to the grant on a timely basis. Effect: Because the subrecipient monitoring and management procedures did not detect the expenses that were improperly charged to the grant, the major program expenditures are improperly overstated. This results in questioned costs, noncompliance, and a material weakness in internal control over compliance with the subrecipient monitoring and allowable costs compliance requirements. The lack of adherence to the established internal control policies and procedures could lead to further noncompliance with federal statutes, regulations, and the provisions of grant agreements. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management perform a year-end review of the subrecipient expenditures included within the accounting records, as well as on the schedule of expenditures of federal awards to ensure the amounts reported represent actual costs incurred as of the end of the fiscal year. We also recommend that management take a proactive monitoring approach with their subrecipients to ensure the subrecipients are reporting actual costs incurred, and not providing estimates. Views of Responsible Officials: Management agrees with the finding. Activities planned by WWF?s key partner in Zambia were not implemented as planned. Sub-grantee implementing the project experienced a number of unforeseen and unexpected delays. The work in the region is done through an inter-governmental organization that brings together eight countries. Obtaining approvals for the project from different governments took longer than expected. This is what led to under-spending. The activities have subsequently been approved and program activities increased in the fall. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴2019-004 Internal Control Over Compliance and Compliance with Subrecipient Monitoring and Allowable Costs and Cost Principles Requirements Information on the Federal Program: United States Department of State CFDA Number: 19.017 CFDA Name: Environmental and Scientific Partnerships and Programs Grant Award Numbers under the Uniform Guidance Requirements: Award Number: SLMAQM18CA2090 Award Period: September 26, 2018 through September 30, 2021 Criteria or Specific Requirement: In accordance with ?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. 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); (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. In addition, direct costs charged to Federal programs are required to conform to the allowability cost provisions in 2 CFR 200, Subpart E. Organizations must monitor the activities of subrecipients to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward, and must review financial and performance reports of the pass-through entity in accordance with ?200.331(d), Requirements for pass-through entities. Condition: During our testing of subrecipient expenditures, we selected 40 transactions for testing using a nonstatistical sample. For one sample, we noted management recorded an accrual for expenditures that was not representative of the actual grant expenditures incurred during 2019. This resulted in an overstatement of subrecipient expenditures on the schedule of expenditures of federal awards of $185,444. Questioned Costs: The known questioned costs are $185,444. Context: This is a condition identified as part of our testing of subrecipient expenses. Because the expenses should not have been charged to the grant during 2019, the costs deemed unallowable. The prevalence of this finding is detailed in the condition section above. The error is material to the major program as the expenditures are overstated by $185,444. Cause: WWF?s subrecipient monitoring and management procedures failed to identify the error in expenditures charged to the grant on a timely basis. Effect: Because the subrecipient monitoring and management procedures did not detect the expenses that were improperly charged to the grant, the major program expenditures are improperly overstated. This results in questioned costs, noncompliance, and a material weakness in internal control over compliance with the subrecipient monitoring and allowable costs compliance requirements. The lack of adherence to the established internal control policies and procedures could lead to further noncompliance with federal statutes, regulations, and the provisions of grant agreements. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management perform a year-end review of the subrecipient expenditures included within the accounting records, as well as on the schedule of expenditures of federal awards to ensure the amounts reported represent actual costs incurred as of the end of the fiscal year. We also recommend that management take a proactive monitoring approach with their subrecipients to ensure the subrecipients are reporting actual costs incurred, and not providing estimates. Views of Responsible Officials: Management agrees with the finding. Activities planned by WWF?s key partner in Zambia were not implemented as planned. Sub-grantee implementing the project experienced a number of unforeseen and unexpected delays. The work in the region is done through an inter-governmental organization that brings together eight countries. Obtaining approvals for the project from different governments took longer than expected. This is what led to under-spending. The activities have subsequently been approved and program activities increased in the fall. See management?s corrective action plan.
2019-004 Internal Control Over Compliance and Compliance with Subrecipient Monitoring and Allowable Costs and Cost Principles Requirements Contact: Leroy Wade Title: Controller Phone Number: 202-293-4800 Corrective Action - For new accruals in the future, WWF will ensure all approvals are in place and activities can realistically be implemented within the planned timeframe.
FAC accepted this audit on December 22, 2018 — management decision was due June 22, 2019.
GSA_MIGRATION
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GSA_MIGRATION
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