EIN: 830219852
UEI: KEE1TFECGG58
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 29, 2022. 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 March 29, 2023 (1246 days ago).
What is a management decision? →2021-001: Subrecipient Monitoring (Significant Deficiency) Assistance Listing Number and Title: 45.129 Promotion of the Humanities - Federal/State Partnership Federal Agency Name: National Endowment for the Humanities Pass-Through Entity Name (if applicable): Not Applicable Award Number: ZSO-283168-21 Award Year(s): June 15, 2021 through April 30, 2023 Criteria: Per 31 USC 7502(f)(2)(B) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)); 2 CFR Section 200.332; program legislation; and Federal awarding agency regulations and terms and conditions of the award, all pass-through entities must ensure that every sub-award is clearly identified to the subrecipient as a sub-award, includes the following information at the time of the sub-award and, if any of these data elements change, includes the changes in subsequent sub-award modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and sub-award. Required information includes: ? Federal award identification ? Subrecipient name ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date ? Sub-award period of performance start and end date ? Amount of Federal funds obligated by this action by the pass-through entity to the subrecipient ? Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current obligation ? Total amount of the Federal award committed to the subrecipient by the pass-through entity ? Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act ? Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity ? Assistance Listing number and name; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listing number at the time of disbursement ? Identification of whether the award is research and development ? Indirect cost rate for the Federal award Condition/context: There are various components of subrecipient monitoring, which includes award identification (providing complete and accurate information to the subrecipient). The Council did not provide all required award identification information to its subrecipients. Specifically, the following elements were not communicated: Federal award identification, subrecipient?s unique identifier, Federal award identification number, identification of whether or not the award was research and development, and the indirect cost rate. Questioned costs: $0 Cause: The Council used various FAQ documents provided by the National Endowment for the Humanities when it provided programmatic information to potential applicants for its regrants as well as information provided after the awarding phase. However, in its haste to get the funds deployed, the program did not verify that it had provided all information required by 2 CFR 200.332. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: No. Recommendation: We recommend that the Council provide a more formal award letter/email to all subrecipients that contains all required award information. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
Show full finding ▾Hide full finding ▴2021-001: Subrecipient Monitoring (Significant Deficiency) Assistance Listing Number and Title: 45.129 Promotion of the Humanities - Federal/State Partnership Federal Agency Name: National Endowment for the Humanities Pass-Through Entity Name (if applicable): Not Applicable Award Number: ZSO-283168-21 Award Year(s): June 15, 2021 through April 30, 2023 Criteria: Per 31 USC 7502(f)(2)(B) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)); 2 CFR Section 200.332; program legislation; and Federal awarding agency regulations and terms and conditions of the award, all pass-through entities must ensure that every sub-award is clearly identified to the subrecipient as a sub-award, includes the following information at the time of the sub-award and, if any of these data elements change, includes the changes in subsequent sub-award modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and sub-award. Required information includes: ? Federal award identification ? Subrecipient name ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date ? Sub-award period of performance start and end date ? Amount of Federal funds obligated by this action by the pass-through entity to the subrecipient ? Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current obligation ? Total amount of the Federal award committed to the subrecipient by the pass-through entity ? Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act ? Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity ? Assistance Listing number and name; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listing number at the time of disbursement ? Identification of whether the award is research and development ? Indirect cost rate for the Federal award Condition/context: There are various components of subrecipient monitoring, which includes award identification (providing complete and accurate information to the subrecipient). The Council did not provide all required award identification information to its subrecipients. Specifically, the following elements were not communicated: Federal award identification, subrecipient?s unique identifier, Federal award identification number, identification of whether or not the award was research and development, and the indirect cost rate. Questioned costs: $0 Cause: The Council used various FAQ documents provided by the National Endowment for the Humanities when it provided programmatic information to potential applicants for its regrants as well as information provided after the awarding phase. However, in its haste to get the funds deployed, the program did not verify that it had provided all information required by 2 CFR 200.332. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: No. Recommendation: We recommend that the Council provide a more formal award letter/email to all subrecipients that contains all required award information. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.
2021-001? Subrecipient Monitoring (Significant Deficiency) Condition/Context ? There are various components of sub-recipient monitoring, which includes Award Identification (providing complete and accurate information to the sub-recipient). The Wyoming Humanities Council did not provide all required Award Identification information to their sub-recipients. Specifically, the following elements were not communicated: Federal Award Identification, Sub-recipient?s unique identifier, Federal Award Identification Number, identification of whether or not the award was R&D, and the indirect cost rate. Recommendation ? We recommend that the Wyoming Humanities Council implement a more formal award letter/email that would be provided to all sub-recipient?s that contains all required award information. Corrective Action Plan ? For all sub-recipients that receive grants with federal funds, Wyoming Humanities will update their award letter that is sent to all sub-recipients. This award letter will include addendums that require the sub-awardee initials and date. The addendums to the award letter will include ? Federal Award Identification ? Sub-recipient name ? Sub-recipient's unique entity identifier ? Federal Award Identification Number ? Federal Award Date ? Sub-award Period of Performance Start and End Date ? Amount of Federal Funds Obligated by this action by the pass-through entity to the sub-recipient ? Total Amount of Federal Funds Obligated to the sub-recipient by the pass-through entity including the current obligation ? Total Amount of the Federal Award committed to the sub-recipient by the pass-through entity ? Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act, ? Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity ? Assistance Listing Number and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listing number at time of disbursement ? Identification of whether the award is R&D ? Indirect cost rate for the Federal award Wyoming Humanities will also retroactively apply these addendums to any current American Rescue Plan recipients as an attachment to their final report. This will cover any sub-recipient that was awarded in FY21 and early FY22. Contact Person ? Michele Carter, Director of Operations Anticipated Date of Completion ? Implemented and ongoing
FAC accepted this audit on August 10, 2021 — management decision was due February 10, 2022.
Criteria ? Per 2 Code of Federal Regulations (CFR) 200.213, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, sub-awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR 200.212, non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Covered transactions include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., sub-awards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215. Condition/Context ? The Council had one contractor with expenditures greater than $25,000, which was subjected to testing against the suspension and debarment compliance requirement. Results of the work audit performed indicated that the contractor was not suspended or debarred; however, the Council failed to verify this prior to the expenditure of funds. Questioned Costs ? $0.00 Effect ? Per 2 CFR 200.338, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.207 specific conditions. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Cause ? The Council did not have a control system in place to monitor suspension and debarment requirements and ensure that a contractor was not suspended or debarred at the time the contract was executed. Identifications as a Repeat Finding ? No. Recommendation ? We recommend the Council review and revise its current control system to ensure that suspension and debarment status is verified on all contracts funded with federal funds. Views of Responsible Officials and Planned Corrective Action ? Management concurs with this finding. See Exhibit I.
Show full finding ▾Hide full finding ▴Criteria ? Per 2 Code of Federal Regulations (CFR) 200.213, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. These regulations restrict awards, sub-awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR 200.212, non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Covered transactions include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., sub-awards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215. Condition/Context ? The Council had one contractor with expenditures greater than $25,000, which was subjected to testing against the suspension and debarment compliance requirement. Results of the work audit performed indicated that the contractor was not suspended or debarred; however, the Council failed to verify this prior to the expenditure of funds. Questioned Costs ? $0.00 Effect ? Per 2 CFR 200.338, if a non-Federal entity fails to comply with Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.207 specific conditions. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Cause ? The Council did not have a control system in place to monitor suspension and debarment requirements and ensure that a contractor was not suspended or debarred at the time the contract was executed. Identifications as a Repeat Finding ? No. Recommendation ? We recommend the Council review and revise its current control system to ensure that suspension and debarment status is verified on all contracts funded with federal funds. Views of Responsible Officials and Planned Corrective Action ? Management concurs with this finding. See Exhibit I.
2020-001: Suspension and Debarment (Significant Deficiency) Catalog of Federal Assistance (CFDA) Number and Title: CFDA #45.129 Promotion of the Humanities ? Federal/State Partnership Federal Agency Name: National Endowment for the Humanities Pass-Through Entity Name (if applicable): N/A Award Number/Name: SO-236449-19 Award Year(s): November 1, 2018 ? October 31, 2023 Condition/Context ? The Council had one contractor with expenditures greater than $25,000, which was subjected to testing against the suspension and debarment compliance requirement. Results of the work audit performed indicated that the contractor was not suspended or debarred; however, the Council failed to verify this prior to the expenditure of funds. Recommendation ? We recommend the Council review and revise its current control system to ensure that suspension and debarment status is verified on all contracts funded with federal funds. Corrective Action Plan ? For all contracts or written agreements over $25,000, made with a contractor, vendor, or grantee, Wyoming Humanities will require all awardees verify suspension and debarment by including a statement within the contract and/or agreement prior to submitting the contract for approval. For all other transactions over $25,000, the Director of Operations will verify the suspension and debarment criteria of all awardees through Sam.gov. A snapshot of the search will be saved for verification at the time the search is conducted through Sam.gov. The Director of Operations will be responsible for collecting all documentation supporting the suspension and debarment criteria prior to the awardee being approved. Contact Person ? Michele Carter, Director of Operations Anticipated Date of Completion ? implemented and ongoing
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