EIN: 760279876
UEI: WQMNK4LCT9N6
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 30, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by December 30, 2025 (236 days ago).
What is a management decision? →Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable programs: Federal Awards, U. S. Environmental Protection Agency, Assistance Listing #66.456, National Estuary program, Passed through Texas Commission on Environmental Quality: Contract period: 09/01/23 – 08/31/25, Contract number: 582-24-50165, Contract period: 07/19/18 – 08/31/24, Contract number: 582-18-80344, Contract period: 09/01/23 – 05/31/26, Contract number: 582-24-50138, Contract period: 09/01/24 – 08/31/26, Contract number: 582-25-00053, Contract period: 09/01/24 – 08/31/26, Contract number: 582-25-00064, Passed through Houston Advanced Research Center: Contract period: 09/01/22 – 03/31/25, Contract number: GBFO322, Passed through Lee College: Contract period: 05/30/23 – 05/31/25, Contract number: 582-23-40258. State Awards, Texas General Land Office, Coastal Erosion Planning and Response Act, Contract period: 07/09/20 – 08/31/25, Grantor number: 20-132-008-C191, Contract period: 07/07/20 – 08/31/25, Grantor number: 20-132-007-C190, Contract period: 07/07/20 – 08/31/25, Grantor number: 20-132-011-C293, Contract period: 11/10/22 – 08/31/27, Grantor number: 22-133-008-D367, Contract period: 11/29/22 – 08/31/27, Grantor number: 22-113-006-D365. Criteria: Procurement – Nonprofit organizations are required to conduct procurement transactions consistent with standards prescribed in Uniform Guidance, Procurement Standards, Texas Grant Management Standards (TxGMS), and conform to federal and state laws and regulations and other contractual requirements. This includes specific procurement, suspension and debarment evaluation requirements. Condition and context: We reviewed the procurement documentation for 3 vendors with expenditures greater than $10,000 requiring procurement, and identified that suspension and debarment procedures were not documented and retained. Effect: Failure to follow the Foundation’s procurement policy, Uniform Guidance, and TxGMS could result in the selection of ineligible vendors. Recommendation: Management should provide additional training to staff with purchasing authority on the procurement policy. View of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable programs: Federal Awards, U. S. Environmental Protection Agency, Assistance Listing #66.456, National Estuary program, Passed through Texas Commission on Environmental Quality: Contract period: 09/01/23 – 08/31/25, Contract number: 582-24-50165, Contract period: 07/19/18 – 08/31/24, Contract number: 582-18-80344, Contract period: 09/01/23 – 05/31/26, Contract number: 582-24-50138, Contract period: 09/01/24 – 08/31/26, Contract number: 582-25-00053, Contract period: 09/01/24 – 08/31/26, Contract number: 582-25-00064, Passed through Houston Advanced Research Center: Contract period: 09/01/22 – 03/31/25, Contract number: GBFO322, Passed through Lee College: Contract period: 05/30/23 – 05/31/25, Contract number: 582-23-40258. State Awards, Texas General Land Office, Coastal Erosion Planning and Response Act, Contract period: 07/09/20 – 08/31/25, Grantor number: 20-132-008-C191, Contract period: 07/07/20 – 08/31/25, Grantor number: 20-132-007-C190, Contract period: 07/07/20 – 08/31/25, Grantor number: 20-132-011-C293, Contract period: 11/10/22 – 08/31/27, Grantor number: 22-133-008-D367, Contract period: 11/29/22 – 08/31/27, Grantor number: 22-113-006-D365. Criteria: Procurement – Nonprofit organizations are required to conduct procurement transactions consistent with standards prescribed in Uniform Guidance, Procurement Standards, Texas Grant Management Standards (TxGMS), and conform to federal and state laws and regulations and other contractual requirements. This includes specific procurement, suspension and debarment evaluation requirements. Condition and context: We reviewed the procurement documentation for 3 vendors with expenditures greater than $10,000 requiring procurement, and identified that suspension and debarment procedures were not documented and retained. Effect: Failure to follow the Foundation’s procurement policy, Uniform Guidance, and TxGMS could result in the selection of ineligible vendors. Recommendation: Management should provide additional training to staff with purchasing authority on the procurement policy. View of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.
Finding #2024-001 – Significant Deficiency and Other Noncompliance. Applicable programs: Federal Awards, U. S. Environmental Protection Agency, Assistance Listing #66.456, National Estuary program, Passed through Texas Commission on Environmental Quality: Contract period: 09/01/23 – 08/31/25, Contract number: 582-24-50165, Contract period: 07/19/18 – 08/31/24, Contract number: 582-18-80344, Contract period: 09/01/23 – 05/31/26, Contract number: 582-24-50138, Contract period: 09/01/24 – 08/31/26, Contract number: 582-25-00053, Contract period: 09/01/24 – 08/31/26, Contract number: 582-25-00064, Passed through Houston Advanced Research Center: Contract period: 09/01/22 – 03/31/25, Contract number: GBFO322, Passed through Lee College: Contract period: 05/30/23 – 05/31/25, Contract number: 582-23-40258. State Awards, Texas General Land Office, Coastal Erosion Planning and Response Act, Contract period: 07/09/20 – 08/31/25, Grantor number: 20-132-008-C191, Contract period: 07/07/20 – 08/31/25, Grantor number: 20-132-007-C190, Contract period: 07/07/20 – 08/31/25, Grantor number: 20-132-011-C293, Contract period: 11/10/22 – 08/31/27, Grantor number: 22-133-008-D367, Contract period: 11/29/22 – 08/31/27, Grantor number: 22-113-006-D365. Condition and context: We reviewed the procurement documentation for 3 vendors with expenditures greater than $10,000 requiring procurement, and identified that suspension and debarment procedures were not documented and retained. Recommendation: Management should provide additional training to staff with purchasing authority on the procurement policy. Planned corrective action: The Foundation recognizes the importance of verifying and retaining documentation regarding vendor eligibility. To prevent recurrence, the Foundation will update the procurement policy to include documentation of verifications in procurement files for each applicable vendor. Responsible officer: Dawn Asbury, Controller. Estimated completion date: July 31, 2025.
Finding #2024-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Environmental Protection Agency, Assistance Listing #66.456, National Estuary program, Passed through Texas Commission on Environmental Quality: Contract period: 09/01/23 – 08/31/25, Contract number: 582-24-50165. Criteria: In accordance with Uniform Guidance OMB 2 CFR §200.331(a), pass through entities must provide subrecipients with specific information at the time of the subaward, including the assistance listing number, federal award identification number (FAIN), name of the federal awarding agency, pass through entity and contact information for awarding official, federal award date of award to the recipient by the Federal agency, access to subrecipient’s records and retention period, and a statement regarding the close-out terms and conditions. Condition and context: We reviewed one of the two subrecipient awards for the required information described in the criteria above and noted such provisions were not included in the subrecipient agreement. Effect: Failure to communicate required information may result in subrecipients not properly complying with federal requirements, increasing the risk of noncompliance. Recommendation: Policies and procedures should be implemented to ensure all required information is included in the subrecipient agreement before issuance. View of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2024-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Environmental Protection Agency, Assistance Listing #66.456, National Estuary program, Passed through Texas Commission on Environmental Quality: Contract period: 09/01/23 – 08/31/25, Contract number: 582-24-50165. Criteria: In accordance with Uniform Guidance OMB 2 CFR §200.331(a), pass through entities must provide subrecipients with specific information at the time of the subaward, including the assistance listing number, federal award identification number (FAIN), name of the federal awarding agency, pass through entity and contact information for awarding official, federal award date of award to the recipient by the Federal agency, access to subrecipient’s records and retention period, and a statement regarding the close-out terms and conditions. Condition and context: We reviewed one of the two subrecipient awards for the required information described in the criteria above and noted such provisions were not included in the subrecipient agreement. Effect: Failure to communicate required information may result in subrecipients not properly complying with federal requirements, increasing the risk of noncompliance. Recommendation: Policies and procedures should be implemented to ensure all required information is included in the subrecipient agreement before issuance. View of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.
Finding #2024-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Environmental Protection Agency, Assistance Listing #66.456, National Estuary program, Passed through Texas Commission on Environmental Quality: Contract period: 09/01/23 – 08/31/25, Contract number: 582-24-50165. Condition and context: We reviewed one of the two subrecipient awards for the required information described in the criteria above and noted such provisions were not included in the subrecipient agreement. Recommendation: Policies and procedures should be implemented to ensure all required information is included in the subrecipient agreement before issuance. Planned corrective action: Management agrees with the finding and would like to provide additional context to this situation. This agreement occurred during the early implementation phase of a multi-year grant in 2023, when the Foundation was still establishing internal processes for managing subawards under federal funding requirements. At the time of this transaction: The federal award had not yet been formally executed, though the federal agency provided authorization to begin incurring expenses. The subrecipient, a partner organization, drafted and issued the agreement using their standard contract template. Since that time, the Foundation has updated its procedures for subsequent subrecipient agreements to include the required Uniform Guidance information as outlined in 2 CFR §200.331(a). This was an isolated incident during a transitional period, and management is confident that current processes address this issue. To prevent recurrence, the Foundation will: Continue to follow updated subrecipient agreement templates, which include all required award and federal compliance language. Provide refresher training to staff involved in grant and contract administration on subrecipient vs. vendor classifications and associated federal requirements. Perform an annual compliance review of all subrecipient agreements to ensure ongoing adherence. Responsible officer: Dawn Asbury, Controller. Estimated completion date: July 31, 2025.
FAC accepted this audit on June 28, 2023 — management decision was due December 28, 2023.
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of the Interior North American Wetlands Conservation Fund ALN #15.623 Contract #: F21AP01040 Contract year: 04/01/21 ? 04/01/24 Criteria: Reporting ? Nonprofit organizations are required submit reports to grantors on a schedule set forth in the federal contract. Condition and context: Interim reports were not submitted on time to the grantor agency during the 2022 fiscal year. Cause: Management did not have controls in place to ensure interim reporting was submitted timely. Effect: Failure to establish and maintain internal control procedures over the procurement process may result in the Foundation violating or failing to meet the grant contract requirements. Recommendation: Develop policies and procedures to meet the contract reporting requirements. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of the Interior North American Wetlands Conservation Fund ALN #15.623 Contract #: F21AP01040 Contract year: 04/01/21 ? 04/01/24 Criteria: Reporting ? Nonprofit organizations are required submit reports to grantors on a schedule set forth in the federal contract. Condition and context: Interim reports were not submitted on time to the grantor agency during the 2022 fiscal year. Cause: Management did not have controls in place to ensure interim reporting was submitted timely. Effect: Failure to establish and maintain internal control procedures over the procurement process may result in the Foundation violating or failing to meet the grant contract requirements. Recommendation: Develop policies and procedures to meet the contract reporting requirements. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.
Finding #2022-002 ? Significant Deficiency and Other Noncompliance Recommendation: Develop policies and procedures to meet the contract reporting requirements. Planned corrective action: In 2023, Galveston Bay Foundation created a new Director of Program Operations position. This person will be responsible for the oversight of grant reporting in addition to the oversight of program operations. The Director of Program Operations will maintain a spreadsheet of all grant reporting requirements with applicable due dates. Although each grant program manager is responsible for submission of program and financial reporting related to their grant, the Director of Program Operations will work closely with each grant program manager to ensure reports due were submitted timely as required by the individual grant contract. Responsible officer: Robert Stokes, President and CEO Estimated completion date: Immediately
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