EIN: 536001427
UEI: UC5GL3MF93Y5
Audited by: CliftonLarsonAllen LLP
Oversight agency: 66 [Environmental Protection Agency]
View federal awards & risk assessment →
Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 18, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by November 18, 2026 (72 days from today).
What is a management decision? →Federal Agency: Environmental Protection Agency Federal Program Name: Water Pollution Control Assistance Listing Numbers: 66.419 Federal Award Identification Number: 98339418 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: 10/1/2023 - 12/30/2025 Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or specific requirement: Compliance: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §200.318 through §200.327. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR §200.320(b)). Control: Per 2 CFR §200.303(a), 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. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: For two of five procurements selected for testing, the Commission was unable to provide documentation (completed requisition form) to demonstrate compliance with their procurement policy. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that the Commission’s procurement policies were followed for procurements entered into where expenses were charged to the federal program. Effect: The Commission was unable to provide documentation to support compliance with Federal requirements. Repeat Finding: No. Recommendation: We recommend that the Commission ensure that it follows its procurement policies for all goods and services charged to the program and that documentation be readily available for audit. Views of responsible officials: To prevent future noncompliance the Commission will 1)clarify vendor coverage on existing agreements, 2) strengthen controls over procurement threshold, 3) monitor cumulative spending by vendor, and 4) reinforce training and communication.
Show full finding ▾Hide full finding ▴Federal Agency: Environmental Protection Agency Federal Program Name: Water Pollution Control Assistance Listing Numbers: 66.419 Federal Award Identification Number: 98339418 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: 10/1/2023 - 12/30/2025 Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or specific requirement: Compliance: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §200.318 through §200.327. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR §200.320(b)). Control: Per 2 CFR §200.303(a), 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. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: For two of five procurements selected for testing, the Commission was unable to provide documentation (completed requisition form) to demonstrate compliance with their procurement policy. Questioned costs: Undetermined. Cause: Controls were not operating effectively to ensure that the Commission’s procurement policies were followed for procurements entered into where expenses were charged to the federal program. Effect: The Commission was unable to provide documentation to support compliance with Federal requirements. Repeat Finding: No. Recommendation: We recommend that the Commission ensure that it follows its procurement policies for all goods and services charged to the program and that documentation be readily available for audit. Views of responsible officials: To prevent future noncompliance the Commission will 1)clarify vendor coverage on existing agreements, 2) strengthen controls over procurement threshold, 3) monitor cumulative spending by vendor, and 4) reinforce training and communication.
Subject: Corrective Action Plan for FY2025 Audit Action Taken in Response to the Finding The Commission reviewed the two transactions cited in the audit—Adobe Lightroom ($127.07) and Hover ($103.02)—and determined that these small-dollar purchases resulted from unintentional administrative oversights rather than systemic issues. To prevent similar issues going forward, the following actions have been taken or are in progress: 1. Clarifying vendor coverage under existing agreements ICPRB maintains a blanket procurement agreement for Adobe products. A detailed review of that agreement confirmed that Adobe Lightroom is not currently covered. Going forward, any Adobe products not explicitly included in an approved blanket agreement will require a separate procurement requisition before purchase. 2. Strengthening controls over procurement thresholds Procedures have been reinforced to ensure that any purchase exceeding the $100 threshold is properly documented before the purchase is made. As part of this effort, a Director of Finance and Administration—who is a CPA—joined the organization effective April 6, 2026, with direct responsibility for overseeing procurement activities and ensuring compliance with applicable policies. 3. Monitoring cumulative spending by vendor In the case of Hover, ICPRB initially incurred a small annual charge of $16.17 for website hosting. Over time, additional sites were added, which caused total spending with the vendor to exceed the $100 threshold by $3.02. New procedures are now in place to monitor cumulative spending with each vendor throughout the year so that procurement requirements are triggered promptly when thresholds are reached. 4. Reinforcing training and communication Finance and administrative staff involved in purchasing and procurement were reminded of key requirements, including: The importance of obtaining proper procurement documentation for applicable purchases. • The need to track cumulative vendor spending to identify when thresholds are exceeded. • The limitations of blanket procurement agreements 5. Conducting periodic compliance reviews The Finance Department will perform regular reviews of vendor expenditures to identify any vendors approaching or exceeding procurement thresholds and will take appropriate action as needed to maintain compliance. Name(s) of the contact person(s) responsible for corrective action: P. Ernest Parker, Jr., Director of Finance and Administration eparker@icprb.org, 301.450.2413 Wendy Wang, Senior Accountant wwang@icprb.org, 301.274.8129 Planned completion date for corrective action plan: June 30, 2026.
FAC accepted this audit on June 24, 2025 — management decision was due December 24, 2025.
FAC accepted this audit on June 27, 2024 — management decision was due December 27, 2024.
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
The Commission did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses applied to the federal program. Context: Forty payroll transactions were selected for testing and one of the transactions charged to the grant was not supported by a timesheet. The timesheet was also not approved by a supervisory or independent individual. Questioned costs: The amount charged to the grant for this transaction was $582. Cause: Controls were not operating effectively to ensure that payroll reporting was performed in a timely and accurate manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Commission should reevaluate its current process and update internal controls related to time and effort reporting. Views of responsible officials: One of our employee?s timesheets was supposed to charge Account #500, but the incorrect formula was used and summed to Account #802 in December. This resulted in $582 difference between the two projects identified as a questioned cost above. By the end of 2022 fiscal year, however, we didn't overcharge project #802. ICPRB expended nearly $80,000 more on this project than was charged to the federal government so this oversight had no effect. This minor error resulted from the termination of our former Admin Director and the resignation of his temporary replacement. Our new Office Manager (hired on February 15, 2023) has assumed the responsibility of reviewing the timesheets so this will not be repeated. In addition, we have decided to block employees from adding accounts directly into their monthly timesheets without first including the account into the YTD portion of the timesheet software.
Show full finding ▾Hide full finding ▴Reference Number: 2022-001 Federal Agency: U.S. Environmental Protection Agency Federal Program: Water Pollution Control Assistance Listing Number: 66.419 Award Number and Year: I-98339417 (10/1/2021 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), 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. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Commission did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses applied to the federal program. Context: Forty payroll transactions were selected for testing and one of the transactions charged to the grant was not supported by a timesheet. The timesheet was also not approved by a supervisory or independent individual. Questioned costs: The amount charged to the grant for this transaction was $582. Cause: Controls were not operating effectively to ensure that payroll reporting was performed in a timely and accurate manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: The Commission should reevaluate its current process and update internal controls related to time and effort reporting. Views of responsible officials: One of our employee?s timesheets was supposed to charge Account #500, but the incorrect formula was used and summed to Account #802 in December. This resulted in $582 difference between the two projects identified as a questioned cost above. By the end of 2022 fiscal year, however, we didn't overcharge project #802. ICPRB expended nearly $80,000 more on this project than was charged to the federal government so this oversight had no effect. This minor error resulted from the termination of our former Admin Director and the resignation of his temporary replacement. Our new Office Manager (hired on February 15, 2023) has assumed the responsibility of reviewing the timesheets so this will not be repeated. In addition, we have decided to block employees from adding accounts directly into their monthly timesheets without first including the account into the YTD portion of the timesheet software.
Reference Number: 2022-001 Prior Year Finding: No Federal Agency: U.S. Environmental Protection Agency Federal Program: Water Pollution Control Assistance Listing Number: 66.419 Award Number and Year: I-98339417 (10/1/2021 ? 9/30/2022) Compliance Requirement: Allowable Cost/Cost Principles ? Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Noncompliance Recommendation: The Commission should reevaluate its current process and update internal controls related to time and effort reporting. The Commission should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding that $582 was improperly charged to EPA 106 Account #802 on one timesheet and not caught because of a change in personnel. ICPRB notes that EPA 106 Account #802 was not overcharged because ICPRB spent $80,000 more on this project than was charged to the federal government. Action taken in response to finding: Hiring of Office Manager to review the formulas used in timesheet entries [Completed February 2023]; Blocking of employees from adding accounts directly into their monthly timesheets without first including the account into the YTD portion of the timesheet software [Underway]. Name(s) of the contact person(s) responsible for corrective action: Michael Nardolilli, Executive Director Planned completion date for corrective action plan: March 2023 If the U.S. Environmental Protection Agency has questions regarding this plan, please call Michael Nardolilli, Executive Director at 301-274-8105.
FAC accepted this audit on March 22, 2022 — management decision was due September 22, 2022.
FAC accepted this audit on March 7, 2021 — management decision was due September 7, 2021.
FAC accepted this audit on March 17, 2020 — management decision was due September 17, 2020.
FAC accepted this audit on March 21, 2019 — management decision was due September 21, 2019.
FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.
FAC accepted this audit on April 17, 2017 — management decision was due October 17, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Browse other Single Audit organizations in Maryland →
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Add it to a monitored group and get alerted when a new audit, finding, repeat finding, or management-decision deadline shows up — instead of checking back.
Checking several at once? Portfolio view →
© 2026 Single Audit Intelligence. All data is public domain.
