EIN: 943370994
UEI: CKZPMBTVTPL6
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 18, 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 March 18, 2026 (158 days ago).
What is a management decision? →During our audit of the SEFA for the year ended December 31, 2024, we noted that the initial SEFA provided by management contained material inaccuracies. Specifically, we noted that amounts passed through to subrecipients were not properly reported and certain programs had expenditures that were inaccurately reported. Cause: The inaccuracies in the SEFA were primarily due to a lack of formalized procedures and oversight in the SEFA preparation process. Effect or Potential Effect: An incomplete or inaccurate SEFA may result in inadequate audit coverage, potential noncompliance with Federal reporting requirements, and increased risk of questioned costs or funding disallowances. Questioned Costs: None. Context: The initial SEFA provided for audit included approximately $310,000 passed through to subrecipients. During the performance of our audit procedures, we identified approximately $5.2 million in amounts passed through to subrecipients that were omitted. Additionally, other expenses were omitted from the SEFA as well. The SEFA was subsequently revised and corrected by management. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management implement formal procedures for compiling the SEFA, including a reconciliation of expenditures to the general ledger, review of all grant agreements for required disclosures, and a documented supervisory review prior to finalization. Staff involved in Federal grant reporting should also receive training on SEFA requirements under Uniform Guidance.
Show full finding ▾Hide full finding ▴Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Commerce. Federal Programs: Ocean Exploration, Coastal Zone Management Administration Awards, Marine Sanctuary Program, Unallied Management Projects, Habitat Conservation, Building Resilience through Community Stewardship of Coral Reefs, Marine Debris Program. Assistance Listing Numbers: 11.011, 11.419, 11.429, 11.454, 11.463, 11.473, 11.999. Compliance Requirement: Reporting. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance. Criteria: Per 2 CFR §200.510(b), the auditee must prepare a SEFA that includes total Federal expenditures, the name of the Federal agency, the Assistance Listing Number, and other identifying information. The SEFA must be accurate, complete, and prepared in accordance with the Uniform Guidance to facilitate the Single Audit. Condition: During our audit of the SEFA for the year ended December 31, 2024, we noted that the initial SEFA provided by management contained material inaccuracies. Specifically, we noted that amounts passed through to subrecipients were not properly reported and certain programs had expenditures that were inaccurately reported. Cause: The inaccuracies in the SEFA were primarily due to a lack of formalized procedures and oversight in the SEFA preparation process. Effect or Potential Effect: An incomplete or inaccurate SEFA may result in inadequate audit coverage, potential noncompliance with Federal reporting requirements, and increased risk of questioned costs or funding disallowances. Questioned Costs: None. Context: The initial SEFA provided for audit included approximately $310,000 passed through to subrecipients. During the performance of our audit procedures, we identified approximately $5.2 million in amounts passed through to subrecipients that were omitted. Additionally, other expenses were omitted from the SEFA as well. The SEFA was subsequently revised and corrected by management. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management implement formal procedures for compiling the SEFA, including a reconciliation of expenditures to the general ledger, review of all grant agreements for required disclosures, and a documented supervisory review prior to finalization. Staff involved in Federal grant reporting should also receive training on SEFA requirements under Uniform Guidance.
Views of Responsible Officials: Management concurs with the auditor’s findings related to Federal award compliance and questioned costs. Several internal transitions contributed to the control gaps and compliance lapses identified during the audit period, including: The implementation of a new chart of accounts and a new instance of the Sage Intacct accounting system, which impacted reporting structures and account mapping for Federal programs. A transition in finance leadership, which affected oversight of Federal grant compliance and reporting. The lack of timely replacement for a key vacant finance position, which limited staff capacity during critical reporting periods. These factors collectively contributed to the challenges experienced in adhering to certain requirements under the Uniform Guidance, including the accurate preparation of the Schedule of Expenditures of Federal Awards (SEFA) and the documentation of allowable costs. To address the findings and prevent recurrence, management has taken or is taking the following steps: Staff training on SEFA preparation and Uniform Guidance requirements will be conducted to ensure a full understanding of Federal compliance obligations. Will ask GRF what recommendations they have for trainings by August 2025. Verify chart of accounts mapping for Federal grants has been finalized and validated within the new Intacct system to support more accurate tracking of expenditures. – Complete by September 2025. The utilization of the C-STAAR system will support a more structured and consistent internal grant management process. Finance will also evaluate the grants management module within the accounting system to determine feasibility for integration and ease of syncing with SEFA reporting requirements. A calendar of Federal reporting deadlines will be developed to strengthen compliance monitoring and accountability. – By October 2025. Management is committed to improving its internal controls and ensuring compliance with all applicable Federal requirements moving forward.
FAC accepted this audit on September 10, 2020 — management decision was due March 10, 2021.
During the current year under audit, the Foundation changed the way that it was recording its direct federal program and program management revenue. As a result, during the preparation of the Schedule of Expenditures of Federal Awards, the program management expenses associated with the program management revenue, which is apportioned to the federal funds was initially unintentionally excluded from the Schedule. This situation is due to the Schedule being provided to the auditors prior to review to ensure that all federal sources of funds are properly identified and included in the Schedule. Cause: The Foundation reported the program management revenue and expense separately in order to be more transparent in its financial accounting Effect: The Schedule of Expenditures of Federal Award that the Foundation first provided to the auditors did not include the program management expenses associated with the program management revenue for the federal awards shown on the Schedule in its single audit for the year ended 2019. Questioned Costs: None identified. Context: Due to the change in accounting recordation for all federal sources of revenue, the program management expenses associated with the program management revenue was excluded from the Schedule of Expenditures of Federal Awards presented. Upon identification of the issue, management immediately provided a corrected version that included all expenses. This issue appears to be an isolated incident and not systematic in nature. Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend that the Schedule of Expenditures of Federal Awards be prepared and reviewed and approved prior to submission of the Schedule to the auditors for the annual audit and compliance examination to ensure the schedule is complete and accurate.
Show full finding ▾Hide full finding ▴Finding 2019-001: Preparation of the Schedule of Expenditures of Federal Awards Federal Programs: All Federal Awards Criteria: The National Marine Sanctuary Foundation is required under 2 CFR ? 200.302 to be able to "identify, in its accounts, all federal awards received and expended and the federal programs under which they were received". It is also required to "maintain internal control over federal programs that provide reasonable assurance that the Foundation is managing federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its federal programs". Additionally, 2 CFR ? 200.302 requires "accurate, current, and complete disclosure of the financial results of each Federal award or program". These requirements are imperative to ensure that all federal programs are properly reported on the Foundation's Schedule of Expenditures of Federal Awards. Condition: During the current year under audit, the Foundation changed the way that it was recording its direct federal program and program management revenue. As a result, during the preparation of the Schedule of Expenditures of Federal Awards, the program management expenses associated with the program management revenue, which is apportioned to the federal funds was initially unintentionally excluded from the Schedule. This situation is due to the Schedule being provided to the auditors prior to review to ensure that all federal sources of funds are properly identified and included in the Schedule. Cause: The Foundation reported the program management revenue and expense separately in order to be more transparent in its financial accounting Effect: The Schedule of Expenditures of Federal Award that the Foundation first provided to the auditors did not include the program management expenses associated with the program management revenue for the federal awards shown on the Schedule in its single audit for the year ended 2019. Questioned Costs: None identified. Context: Due to the change in accounting recordation for all federal sources of revenue, the program management expenses associated with the program management revenue was excluded from the Schedule of Expenditures of Federal Awards presented. Upon identification of the issue, management immediately provided a corrected version that included all expenses. This issue appears to be an isolated incident and not systematic in nature. Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend that the Schedule of Expenditures of Federal Awards be prepared and reviewed and approved prior to submission of the Schedule to the auditors for the annual audit and compliance examination to ensure the schedule is complete and accurate.
View of Responsible Official: Prior to the audit, there was a turnover in the Director of Finance at the Foundation and the first submission of the Schedule of Expenditures of Federal Awards mistakenly excluded program management revenue. The program management revenue was appropriately included in other documentation. The Foundation corrected this mistake and provided an updated Schedule. The Foundation hired a Chief Financial Officer in August who will be responsible for reviewing and approving the Schedule prior to submission.
FAC accepted this audit on October 26, 2016 — management decision was due April 26, 2017.
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