THE JANE GOODALL INSTITUTE FOR WILDLIFE RESEARCH EDUCATION & CONSERVATION

Finding # 2023-001 Timely Program Reporting Submission (Significant Deficiency) Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement: §200.329 Monitoring and reporting program performance (c)(1) states that “The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency”. Condition: As part of our compliance audit over the Institute’s programmatic reporting requirements under the major program, we noted multiple instances in which programmatic reports were not submitted to the federal agency by the deadline stated in the grant agreement. In some cases, reports were submitted after extended deadlines. Ultimately, all reports were completed and accepted by the donor. Cause: The final submission dates observed in this review were necessary because of a temporary overlapping period on programs (LCWT and TKV). The need for this extra time was communicated with the funder, however, such communication was not properly documented as amended submission times. Lack of formalized communication rather than a delayed submission. Effect or Potential Effect: Late program report submissions result in delays of program monitoring and evaluation. Questioned Costs: N/A Context: As a federal award recipient, the Institute is responsible for oversight of the operations of the Federal award supported activities. The Institute must monitor its activities under Federal awards to assure compliance with applicable federal requirements and that performance expectations are being achieved. Federal awards require varying programmatic reports to be submitted according to the timeframe stated in the grant agreement. Identification as a Repeat Finding: N/A Recommendation: We recommend that the Institute review its policies and procedures and strengthen internal controls to ensure that all programmatic reports are submitted to the donor by the deadlines stipulated in the terms of the agreement.

Finding # 2023-002 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that 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. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that 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, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. The nonfederal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted contractual relationships under the federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation (prepared at the time the contracts were executed) detailing the history and rationale of the procurements. Cause: The Institute's processes in place during 2023 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200 and related guidance provided by USAID. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Institute may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Institute could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: Our audit sample consisted of transactions incurred by both JGI USA and JGI Tanzania. The finding relates to a transaction incurred by both entities. Both entities have defined procurement policies. Identification as a Repeat Finding: N/A Recommendation: We recommend that the Institute ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. Such documentation should include, but is not limited to; (1) Bids (2) Bid Analysis with documentation of vendor selection and rationale (3) Minutes of meetings of procurement committee (4) for sole source procurements, documentation of which of the allowable sole source criteria the procurement was done under. Additionally, we recommend that the procurement policies are enhanced to include compliance with §200.320 (f) Methods of procurement to be followed and, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.

Finding # 2023-003 Subrecipient Monitoring (Significant Deficiency) Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement: § 200.332, Requirements for pass-through entities, requires pass-through entities to evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. The statute also requires pass-through entities to include certain federal award identifying information within the subaward agreement. Condition: The Institute maintains subaward selection and monitoring policies. However, the policies do not include pre-prescribed monitoring procedures based on an assessed level of risk assigned in the subaward selection stage. Additionally, as part of our audit, we selected a sample of subawards charged to the major federal programs. We noted that a subaward agreement did not contain certain federal award identifying information, specifically the relevant Federal Assistance Listing Number (ALN). Cause: The Institute maintains subaward selection and monitoring policies that do not include preprescribed monitoring procedures based on an assessed level of risk. Additionally, Federal Assistance Listing Number were omitted from the subaward agreements based on an oversight during the subaward writing process. Effect or Potential Effect: The Institute may have inadvertently failed to perform monitoring procedures appropriate for a subrecipient’s assessed level of risk. Not including Federal Assistance Listing Numbers in the subaward agreement could lead to the subrecipient omitting the subaward from its Schedule of Expenditures of Federal Awards. Questioned Costs: N/A Context: The Institute executes subaward agreements under US Federal grants. Therefore, the Institute is subject to § 200.332 Requirements for pass-through entities. Our audit procedures consisted of testwork completed on subawards charged to the federal awards. The report in which samples were selected was generated directly from the Institute’s general ledger (accounting system). We consider our sample to be representative of the population. Identification as a Repeat Finding: N/A Recommendation: We recommend that the Institute revise its subaward selection and monitoring policies to include pre-prescribed monitoring procedures based on an assessed level of risk assigned in the subaward selection stage. The assessed level of risk should be documented in a pre-award risk assessment. Additionally, we recommend that the Institute ensure that all subaward agreements include all elements required by §200.332.

Finding # 2023-004 Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting (Significant Deficiency) Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward report by the end of the month following the month in which the prime recipient awards any subaward with a value greater than or equal to $30,000. Condition: We noted one instance in which the Institute did not report a subaward in the Federal Subaward Reporting System as required by 2 CFR Part 170. Cause: The Institute was unaware of the FFATA report filing requirement. Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result in withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: N/A Context: There were three subawards under the major program. We selected one subaward for which to test the FFATA reporting requirements. The sample is considered to be representative of the population. Identification as a Repeat Finding: N/A Recommendation: We recommend the Institute take steps to raise awareness of the FFATA reporting requirements and associated deadlines to those staff responsible for compliance with FFATA reporting requirements. The Institute should ensure reports are filed for all existing and future first tier subawards in excess of $30,000. Requirements for FFATA reporting should be included in the Institutes subaward selection and monitoring policies.

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