Pacific States Marine Fisheries CommissionLocal Government

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, §200.318 General procurement standards indicates “the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: A selection of procurements did not maintain sufficient documentation that detailed the history of the procurement and justification for using non-competitive practices. Questioned costs: Known questioned costs of $23,890. (NA21NMF4370552 = $4,650, NA22NMF4370355 = $12,440, NA22NMF4360330 = $6,800) Context: In a statistically valid sample, three of forty procurement selections tested, did not have sufficient documentation to justify their acquisition method. One item related to purchase decisions dictated by a subrecipient; however the payment was made directly by the Commission and no justification showing an adequate procurement process was provided by the subrecipient. Two selections related to procurements with a long-standing vendor which was used as the justification for selection, however no documentation was provided for the justification to continue using this vendor. Cause: Insufficient understanding and application of procurement policies when unusual situations arise. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat finding: Yes – see finding 2022-001 from the prior year. Recommendation: We recommend increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified, and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. Specifically, per CFR 200.329(c)(1), “the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcome and productivity…. Reports submitted quarterly or semiannual must be due no later than 30 calendar days after the reporting period.” In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted some reports tested were not submitted within 30 days after the end of the quarterly reporting period. Questioned costs: None. Context: Two of eight reports tested under ALN 11.437 and two of five reports tested under ALN 11.022 were submitted 1 day after the due date. The ALN 11.437 reports related to the program quarter ended 2/28/2023 and the ALN 11.022 reports related to the program quarter ended 4/30/23. Cause: Reports were likely sent to the Grants Manager on the due date, and therefore were missed or there was not time to adequately review prior to submission by end of day. Effect: The Commission was not in compliance with submitting reports timely. Repeat finding: No Recommendation: We recommend the Commission implement stronger internal monitoring to ensure reports are completed by program managers and submitted to the Grants Manager timely to ensure ample time for internal review and upload to the Federal Agency. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Energy, Bonneville Power Administration Federal Program Name: Columbia Basin Pit Tag Assistance Listing Number: 81.999 Federal Award Identification Number and Year: 00078040 REL 35 ? 2021-2022 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement. Specifically, per ?200.320(c), noncompetitive procurements can only be used if one of five specific circumstances are met. Documentation for that assessment must be kept. The Commission should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Commission did not have adequate internal controls designed to ensure noncompetitive procurements were appropriately identified as sole source procurements. Questioned costs: $134,084 Context: In a statistically valid sample, two of seven procurement selections tested, representing 50% of the noncompetitive procurements tested, did not have sufficient documentation to appropriately determine that the procurements qualified as sole source acquisitions. Upon further review of the procurements in question, they did appear to merit the use of sole source procurement, however incomplete documentation was kept to identify the procurements as such. Cause: The selections in questions were for renewals of software agreements. Sole source justification may have been completed on the initial contracts and purchases, however these documents were either not retained or were inaccessible during the audit. Effect: Noncompliance could lead the Commission to enter into contracts with vendors that are not the most suitable for the goods and/or services being procured. Repeat Finding: No Recommendation: We recommend the Commission design controls to ensure adequate documentation is maintained to support sole source justifications. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Energy, Bonneville Power Administration Federal Program Name: Columbia Survival Study (CSS), Streamnet, Smolt Monitoring by Non-Federal Entities Assistance Listing Number: 81.999 Federal Award Identification Number and Year: 00078040 REL 17 ? 2019-2021; 00078040 REL 33 ? 2020-2021; 00078040 REL 37 ? 2021-2022 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of subrecipient monitoring. Specifically, per ?200.332(f), all pass-through entities must verify that every subrecipient is audited as required. The Commission should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Commission did not keep adequate documentation to verify the Commission had acquired and reviewed its subrecipients? most recent audit reports. Questioned costs: None. Context: In a statistically valid sample, all five of the subrecipient selections tested lacked sufficient documentation to verify the Commission had received, reviewed, and followed up on its subrecipients? most recent audit reports. Although review of a subrecipient?s audit is a required requirement under the Uniform Guidance, compensating procedures ensured that the Commission only made subrecipient agreements with entities that are eligible and valid. Additional documentation was provided to verify the Commission performs other ongoing monitoring procedures of its subrecipients. Cause: Internal controls and procedures were missed due to a turnover in the Fiscal Manger role. Effect: The Commission was not in compliance with Uniform Guidance monitoring of subrecipient requirements. Repeat Finding: No Recommendation: We recommend the Commission follow its internal controls and procedures over subrecipient monitoring to ensure subrecipient audits are received, reviewed, and followed up on and that documentation of those procedures is maintained. Views of responsible officials: There is no disagreement with the audit finding.