AMERICAN BATTLEFIELD TRUST AND AFFILIATESNon-Profit

Finding No. 2022-002-Significant Deficiency-Delay in Submission of the OMB Reporting Package. The Uniform Guidance requires that entities that expense $750,000 or more in a year in Federal awards must submit their audited annual financial reports and data collection form to the Federal Audit Clearinghouse within thirty (30) days after receipts of the auditor's report, or nine (9) months of the close of the auditee's fiscal year. The Trust did not file the OMB reporting package within nine months of the fiscal year end as required per Uniform Guidance. Turnover in a key accounting position close to the year-end caused a delay in start of the annual audit. The fiscal year 2022 audit work did not commence until March 2023 and was not completed until June 2023. We recommend the Trust complete all reports required under the Federal award document and submit the reports in a timely manner. The Trust should improve financial close-out procedures and obtain the audit required under the Uniform Guidance within nine months of the fiscal year end.

2020-002 - Schedule of Expenditures of Federal Awards Reporting Information on Federal Program U.S. Department of the Interior CFDA No. 15.928 Grant Number: Various Program: Battlefield Land Acquisition Grants Pass-through Entity: North Carolina Department of Natural and Cultural Resources Criteria? The auditee shall prepare a schedule of expenditures of Federal awards (?SEFA? or ?the Schedule?) for the period covered by the auditee?s financial statements. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. For example, when a Federal program has multiple award years, the auditee may list the amount of Federal awards expended for each award year separately. At a minimum, the Schedule shall: 1. List individual Federal programs by Federal agency. For Federal programs included in a cluster of programs, list individual Federal programs within a cluster of programs. For R&D, total Federal awards expended shall be shown either by individual award or by Federal agency and major subdivision with the Federal agency. 2. For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity shall be included. 3. Provide total Federal awards expended for each individual Federal program and the Catalog of Federal Domestic Programs (CFDA) number or other identifying number when the CFDA information is not available. 4. Include notes that describe the significant accounting policies used in preparing the schedule. 5. To the extent practical, pass-through entities should identify in the schedule the total amount provided to subrecipients from each Federal program. 6. Include, in either the schedule or a note to the Schedule, the value of Federal awards expended in the form of noncash assistance, the amount of insurance in effect during the year, and loans or loan guarantees outstanding at year-end. While not required, it is preferable to present this information in the Schedule. Condition ? During our testing of the management prepared SEFA, we identified the following exceptions during our testing: ? Expenditures for grant number P19AP00003 totaling $72,481 were incorrectly included in the fiscal year ended March 31, 2020 SEFA. ? Expenditures for grant number P19AP00004 totaling of $45,735 were incorrectly included in the fiscal year ended March 31, 2020 SEFA. Cause - The U.S. Department of the Interior (DOI) issued two federal awards to the North Carolina Department of Natural and Cultural Resources (DNCR). The DNCR utilized the Trust as a subgrantee to purchase battlefields. However, due to delays in execution of the underlying Agreement of Purchase and Sale of Real Property contracts, the Trust did not complete the property acquisitions prior to March 31, 2020 and therefore the expenditures did not occur within the fiscal year. The DOI funds for both awards were provided to the Trust from the DNCR during the fiscal year ended March 2020. Effect or Potential Effect - The management prepared SEFA prepared required adjustments as described in the condition above. Questioned Costs - There are no questioned costs related to the items described above. Context ? The SEFA prepared by the auditee required revision due to incorrect reporting to the auditors. The SEFA included in this report has been corrected by management for the error identified. This is a condition based on our review of the completeness and accuracy of the SEFA in performing Uniform Guidance audit procedures. Recommendation ? Although the auditee ensures that the SEFA is prepared and reviewed by appropriate personnel, BDO recommends a reconciliation is performed between the executed and completed property transactions from "grants and awards revenue" recorded as part of the year-end revenue close process. This reconciliation will address the Federal compliance requirements that property transactions are complete prior to recognition of related grant funds within the SEFA. Views of Responsible Officials - The Trust management agrees with the finding and recommendation set forth within and has developed a corrective action plan to address the instances of noncompliance identified.