NORTH PACIFIC FISHERY MANAGEMENT COUNCILNon-Profit

Finding # 2024-001 Type: Immaterial noncompliance Federal Agency: U.S. Department of Commerce, National Oceanic and Atmospheric Administration Assistance Listing: 11.441 Criteria/Requirement: The Organization’s procurement policies should incorporate the provisions of the procurement standards set out at 2 CFR sections 200.318 through 200.327. Cause: The Organization’s fiscal policies and procedures do not meet the required federal standards for procurement. Effect: Executed contracts using federal funds may be in violation of federal guidelines. Recommendation: The Organization's procurement policy must have documented procurement procedures, consistent with state, local, and tribal laws and regulations for the acquisition of property or services required under a federal award or subaward. The Organization should maintain records sufficient to detail the history of procurement. Management Response: Management will work on revising the Organization’s procurement policies to incorporate the necessary provisions.

Finding # 2024-002 Type: Immaterial noncompliance Federal Agency: U.S. Department of Commerce, National Oceanic and Atmospheric Administration Assistance Listing: 11.441 Criteria/Requirement: Per Uniform Grant Guidance 200.430, charges to federal awards for salaries and wages must be based on actual work performed, supported by internal controls, and part of the official records of the organization. Using estimated amounts do not qualify as support for charges to federal awards. Cause: Payroll costs charged to grants are based on estimated allocations not actual hours. Effect: While charges appear allowable to federal programs tested, the potential exists for hours to be inaccurately recorded or charged to programs. Recommendation: All timesheets should include allocated hours by grant before certification by the employee and review by a supervisor. Management Response: Time sheet tracking will be modified to track hours by grant so that time and effort reporting will support amount charged to the grant.

Finding # 2024-003 Type: Immaterial noncompliance Federal Agency: U.S. Department of Commerce, National Oceanic and Atmospheric Administration Assistance Listing: 11.441 Criteria/Requirement: In accordance with 2 CFR 200.305, organizations that receive more than $250,000 of federal funding per year should maintain those funds in an interest-bearing account. Interest earned in excess of $500 should be remitted back to the federal government. Cause: Funds are not maintained in an interest-bearing account. Effect: There are potential lost earnings and the Organization is not following federal guidelines. Recommendation: The Organization should change their primary operating account to an interest-bearing account. Management Response: Funds on hand will be moved to an interest-bearing account.