oversight

SIGAR 21-35-FA

Published by the Office of the Special Inspector General for Afghanistan Reconstruction on 2021-06-04.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

  SIGAR                                                    Special Inspector General for
                                                           Afghanistan Reconstruction




                                                                              SIGAR 21-35 Financial Audit




    USAID's Conflict Mitigation Assistance for Civilians
    Program in Afghan istan: Audit of Costs Incurred by
    Blumont Global Development Inc.



                In accordance with legal requirements, SIGAR has redacted certain information deemed
                                  proprietary or otherwise sensitive from this report.




                                                                                                       JUNE

                                                                                               2021

SIGAR 21-35-FA/USAID's COMAC Program
                                                         June 2021

                                                         USAID's Conflict Mitigation Assistance for Civilians Program in Afghanistan:


SIGAR                                                    Audit of Costs Incurred by Blumont Global Development Inc.

                                                         SIGAR 21-35-FA

Special Inspector General for                            WHAT SIGAR FOUND
Afghanistan Reconstruction                               Crowe ident ified f ive material weaknesses and one significant deficiency
                                                          in Blumont's internal cont rols, as well as t wo instances of
WHAT THE AUDIT REVIEWED                                   noncompliance wit h the terms of t he agreement . For example, t he
                                                         auditors f ound t hat Blumont recorded $265,8 56 in costs incurred in the
On March 12, 2018, the U.S. Agency for
                                                         incorrect accounting period t hat resulted in a material misstatement in
International Development (USAID) awarded a
                                                         t he SPFS. The auditors concluded t hat t his was a reporting error and was
cooperative agreement to Blumont Global
                                                         not considered an ineligible amount or a quest ioned cost .
Development Inc. (Blumont) to support t he
Conflict Mitigation Assistance for Civilians              In another instance, the auditors performed analysis of Blumont's
program in Afghanistan. The program provides              property records and found t hat Blumont did not include acquisition
assistance to support Afghan families suffering          costs fo r 613 items in its invent ory. The auditors did not report this as
from military operations, to conduct advocacy            quest ioned costs because t he missing items were t ransferred from a
and outreach. and for other related activit ies.         previous project and were not purchased wit h t he award f unds. In
The initial obligated amount was $8.5 million,           addition, t he audit ors found that Blumont's procurement policy did not
but after four modifications. the total obligation       specify a met hOd t o ensure t hat micro-purcl1ases are equitably
increased to $26,375,000. The periOd of                  distributed and did not exceed t he t hresholds.
performance for t he award was unchanged by
                                                         Crowe did not identify any quest ioned costs, which would have consisted
the modifications; it is ongoing and spans from
                                                         of ineligible costs-costs prohibited by the agreement , applicable laws, or
March 12, 2018, t hrough March 11. 2023.
                                                         regulat ions-and unsupported costs-costs not s upported wit h adequat e
SIGAR's financial audit, performed by Crowe LLP          documentat ion or that did not have required prior approval.
(Crowe) reviewed $9,120,738 in costs charged
                                                         Crowe identified eight prior audit reports that were relevant to Blumont's
to the agreement f rom January 1, 2019,
                                                         agreement. The reports did not have any findings t hat could have a
through December 31, 2019 . The objectives of
                                                         material effect on the SPFS or ot her fina ncial data are significant to t11is
the audit were to (1) identify and repQrt on
                                                         audit's objectives. Crowe concluded t hat no follow up was required.
material weaknesses or significant def iciencies
in Blumont's internal controls related to the            Crowe issued an unmodified opinion on Blumonrs SPFS, not ing that it
agreement; (2) ident ify and rePort on instances         presents f airly, in all material respects, revenues received, and costs
of material noncompliance with the t erms of the          incurred for period indicated.
agreement and applicable laws and regulations,
including any Potential fraud or abuse; (3)
determine and repQrt on whether Blumont has
taken correct ive action on prior findings and
recommendat ions; and (4) express an Opinion
on the fa ir present ation of Blumonrs Special
PurpQse Financial Statement (SPFS). See                 WHAT SIGAR RECOMMENDS
Crowe·s report for the precise audit Objectives.
                                                        Based on the results of the audit, SIGAR recommends that the respQnsible
In contracting with an independent audit firm           agreement officer at USAID:
and drawing from the results of the audit,
                                                            1.   Advise Blumont to address the rePort's six internal contrOI findings.
auditing standards require SIGAR to review the
work performed. Accordingly, SIGAR oversaw
                                                            2.   Advise Blumont to address the rePort's two noncompliance findings.
the audit and reviewed its results. Our review
disclosed no instances wherein Crowe did not
comply, in all material respects, with U.S.
generally accepted government audit ing
standards.




      For more information, contact SIGAR Public Affairs at (703) 545-5974 or sigar.pentagon.ccr.mbx.public-affairs@mail.mil.
June 4, 2021



The Honorable Samantha Power
Administrator, U.S. Agency for International Development

Dr. Tina Dooley-Jones
USAID Mission Director for Afghanistan


SIGAR contracted with Crowe LLP (Crowe) to audit the costs incurred by to Blumont Global Development Inc.
(Blumont) under a cooperative agreement from the U.S. Agency for International Development (USAID) to support
the Conflict Mitigation Assistance for Civilians program in Afghanistan.1 The program provides assistance to
support Afghan families suffering from military operations, to conduct advocacy and outreach, and for other
related activities. Crowe reviewed $9,120,738 in costs charged to the agreement from January 1, 2019, through
December 31, 2019. Our contract with Crowe required that the audit be performed in accordance with generally
accepted government auditing standards issued by the Comptroller General of the United States.
Based on the results of the audit, SIGAR recommends that the responsible agreement officer at USAID:
          1. Advise Blumont to address the report’s six internal control findings.
          2. Advise Blumont to address the report’s two noncompliance findings.
Crowe discusses the results of the audit in detail in the attached report. We reviewed Crowe’s report and related
documentation. Our review, as differentiated from an audit in accordance with U.S. generally accepted
government auditing standards was not intended to enable us to express, and we do not express, an opinion on
Blumont’s Special Purpose Financial Statement. We also express no opinion on the effectiveness of Blumont’s
internal control or compliance with the agreement, laws, and regulations. Crowe is responsible for the attached
auditor’s report and the conclusions expressed in it. However, our review disclosed no instances in which Crowe
did not comply, in all material respects, with generally accepted government auditing standards issued by the
Comptroller General of the United States.
Please provide documentation related to corrective actions taken and/or target dates for planned completion for
the recommendations to sigar.pentagon.audits.mbx.recommendation-followup@mail.mil, within 60 days from the
issue date of this report.




John F. Sopko
Special Inspector General
   for Afghanistan Reconstruction




(F-187)




1   The agreement number is 72030618CA00005.
           Blumont Global Development, Inc.

         Financial Audit of Costs Incurred Under

     Cooperative Agreement No. 72030618CA00005

          Special Purpose Financial Statement

For the Period January 1, 2019 through December 31, 2019

      (With Independent Auditor’s Report Thereon)
SIGAR                                                          Blumont Global Development, Inc.




Table of Contents
        TRANSMITTAL LETTER ...................................................................................................................... 1

        SUMMARY ........................................................................................................................................... 2

        INDEPENDENT AUDITOR’S REPORT ON THE SPECIAL PURPOSE FINANCIAL STATEMENT... 7

        SPECIAL PURPOSE FINANCIAL STATEMENT ................................................................................. 9

        NOTES TO THE SPECIAL PURPOSE FINANCIAL STATEMENT ................................................... 10

        INDEPENDENT AUDITOR’S REPORT ON INTERNAL CONTROL ................................................. 12

        INDEPENDENT AUDITOR’S REPORT ON COMPLIANCE .............................................................. 14

        SECTION I SCHEDULE OF FINDINGS AND QUESTIONED COSTS ............................................. 16

        SECTION II SUMMARY SCHEDULE OF PRIOR AUDIT, REVIEW, AND ASSESSMENT FINDINGS
        ............................................................................................................................................................ 27

        APPENDIX A VIEWS OF RESPONSIBLE OFFICIALS ..................................................................... 28

        APPENDIX B AUDITOR’S REBUTTAL.............................................................................................. 33




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TRANSMITTAL LETTER
March 15, 2021


To the Board of Directors of Blumont Global Development, Inc.
1777 North Kent Street Suite 300
Arlington, Virginia 22209

To the Office of the Special Inspector General for Afghanistan Reconstruction 2530 Crystal Drive
Arlington, Virginia 22202


We appreciate the opportunity to provide to you our report regarding the procedures that we have
completed during our audit of Blumont Global Development, Inc. (“Blumont”) special purpose financial
statement applicable under the U.S. Agency for International Development (“USAID”) Cooperative
Agreement No. 72030618CA00005 to support the Conflict Mitigation Assistance for Civilians (“COMAC”)
program for the period January 1, 2019 through December 31, 2019.

Within the pages that follow we have provided a brief summary of the work performed. Following the
summary, we have incorporated our report on the Special Purpose Financial Statement, our report on
internal control, and our report on compliance. We do not express an opinion on the summary or any
information preceding our reports.

When preparing our report, we considered comments, feedback, and interpretations of Blumont, the U.S.
Agency for International Development (“USAID”), and the Office of the Special Inspector General for
Afghanistan Reconstruction (“SIGAR”), provided both in writing and orally throughout the audit planning
and fieldwork phases. Management’s final written responses will be incorporated as an appendix to this
report.

Thank you for providing us the opportunity to work with you and to conduct the financial audit of Blumont’s
cooperative agreement.

Sincerely,



Bert Nuehring, CPA, Partner
Crowe LLP




                                                                                                                    1
SIGAR                                Blumont Global Development, Inc.



SUMMARY
Background
On March 12, 2018, the U.S. Agency for International Development (“USAID”) awarded a $39,999,873
cooperative agreement to Blumont to support the Conflict Mitigation Assistance for Civilians” (“COMAC”)
program. The total initial obligated amount was for $8,500,000. As of January 9, 2020, the total obligated
amount is $26,375,000.

COMAC provides comprehensive victims’ assistance to Afghan families suffering from military operations
by delivering direct and indirect assistance, building the capacity of the Government of Afghanistan, and
conducting advocacy and outreach. The program’s victim assistance initiatives focus on Afghan civilians
and dependents who have suffered loss of life, physical injury, or lack of economic livelihood. The program
is a five-year Afghanistan-wide program based in Kabul with regional offices in Herat, Kandahar, Jalalabad,
and Mazar-i-Sharif that will support delivery of victims’ assistance (“VA”) to at least 50,000 Afghan families.
The period of performance for the award is still ongoing and covers the period of March 12, 2018 through
March 11, 2023.

Our audit period encompassed activities in parts of Years 1 and 2 of the award. During this time, Blumont
led programmatic efforts, with support from Ministry of Labor, Social Affairs, Martyrs and Disabled
(“MoLSAMD”) staff, to (a) provide direct assistance and referrals to eligible victims; (b) build the institutional
and technical capacity of MoLSAMD and other relevant Government of the Islamic Republic of Afghanistan
(“GIRoA”) entities; (c) provide referral services to eligible victims; and, (d) carry out advocacy and outreach
about victims’ rights, needs, services, and the role of MoLSAMD, specifically the Martyrs and Disabled
Division (“MDD”). Key implementation requirements and activities include the following:
1. In Coordination and Collaboration with GIRoA, Appropriate Assistance Provided to Victims of the
    Conflict by Effectively Using All Available Resources.
  o Mapping of VA Service Providers.
  o Beneficiary Data Collection and Management.
  o Delivery of Immediate Assistance to Victims in a Timely and Responsive Manner.
  o Provision of Tailored Assistance Programs with Long-Term Linkages.
  o Strengthening Referral Protocols for Victims.
2. GIRoA’s Capacity to Respond to Victims’ Needs Improved.
  o Needs Assessment of MoLSAMD, Ministry of Public Health, and Their Provincial Directorates and
       Local Offices.
  o Design and Delivery of Customized Capacity-Building Support to GIRoA.
3. Increased Awareness of Victims’ Assistance Services.
  o Design of Communication Strategy and Development of an Action Plan for MDD.
  o Implementation of Advocacy and Outreach Activities.

After four modifications to the agreement, the total funding was increased to $26,375,000 and the period of
performance remained unchanged through March 11, 2023.

Crowe’s audit encompasses the period January 1, 2019 through December 31, 2019. Within the period
under audit, Blumont reported $9,120,738 in costs.

Work Performed
The Office of the Special Inspector General for Afghanistan Reconstruction (“SIGAR”) engaged Crowe LLP
(“Crowe” or “we” or “our”) to conduct a financial audit of cooperative agreement number 72030618CA00005
awarded to Blumont Global Development, Inc. (“Blumont”).




                                                  (Continued)

                                                                                                                2
SIGAR                               Blumont Global Development, Inc.



Objectives Defined by SIGAR
The following audit objectives were defined within the Performance Work Statement for Financial Audits of
Costs Incurred by Organizations Contracted by the U.S. Government for Reconstruction Activities in
Afghanistan:

Audit Objective 1 – Special Purpose Financial Statement
Express an opinion on whether Blumont’s Special Purpose Financial Statement (“SPFS”) for the
cooperative agreement presents fairly, in all material respects, revenues earned, costs incurred, and
balance for the period audited in conformity with the terms of the cooperative agreement and generally
accepted accounting principles or other comprehensive basis of accounting.

Audit Objective 2 – Internal Controls
Evaluate and obtain a sufficient understanding of Blumont’s internal control related to the cooperative
agreement; assess control risk; and identify and report on significant deficiencies including material internal
control weaknesses.

Audit Objective 3 – Compliance
Perform tests to determine whether Blumont complied, in all material respects, with the cooperative
agreement and applicable laws and regulations; and identify and report on instances of material
noncompliance with terms of the cooperative agreement and applicable laws and regulations, including
potential fraud or abuse that may have occurred.

Audit Objective 4 – Corrective Action on Prior Findings and Recommendations
Determine and report on whether Blumont has taken adequate corrective action to address findings and
recommendations from previous engagements that could have a material effect on the special purpose
financial statement or other financial data significant to the audit objectives.

Scope
The scope of the audit included $9,120,738 in costs for the period January 1, 2019 to December 31, 2019.
The audit was limited to those matters and procedures pertinent to the cooperative agreement that have a
direct and material effect on the SPFS. The audit also included an evaluation of the presentation, content,
and underlying records of the SPFS. Further, the audit included testing the financial records that support the
SPFS to determine if there were material misstatements and if the SPFS was presented in the format
required by SIGAR. In addition, the following areas were determined to be direct and material and, as a
result, were included within the final audit program for detailed evaluation:

•        Allowable Costs and Activities;
•        Cash Management;
•        Eligibility;
•        Equipment and Real Property;
•        Procurement;
•        Reporting; and
•        Subrecipient Monitoring.




                                                 (Continued)

                                                                                                             3
SIGAR                              Blumont Global Development, Inc.



Methodology
To meet the aforementioned objectives, Crowe completed a series of tests and procedures to audit the
SPFS, tested compliance and considered the auditee's internal controls over compliance and financial
reporting and determined if adequate corrective action w as taken in response to prior audit, assessment,
and review comments, as applicable .

For purposes of meeting Audit Objective 1 pertaining to the SPFS, transactions were selected from the
financial records underlying the SPFS and were tested to determine if the transactions were recorded
accurately and were consistent with the terms and conditions of the aw ard; were incurred within the period
covered by the SPFS and in alignment with specified cutoff dates; were appropriately allocated to the
cooperative agreement, as applicable ; and were adequately supported.

Regarding Audit Objective 2 pertaining to internal control, Crow e requested, and the auditee provided
copies of policies and procedures to provide Crowe with an understanding of the system of internal control
established by Blumont during the period of performance. To the extent documented policies and
procedures were unavailable, Crowe conducted interviews with management to obtain an understanding
of the processes that were in place during the period of performance. The system of internal control is
intended to provide reasonable assurance of achieving reliable financial reporting and compliance with
applicable laws and regulations. Crowe corroborated internal controls identified by the auditee and
conducted testing of select key controls to understand if they w ere implemented as designed.

Audit Objective 3 required that tests be performed to obtain an understanding of the auditee's compliance
with requirements applicable to the cooperative agreement. Crowe identified - through review and
evaluation of the cooperative agreement from USAID to Blumont - the criteria against which to test the
SPFS and supporting financial records and documentation. Using various sampling techniques, including,
but not limited to, audit sampling guidance for compliance audits provided by the American Institute of
Certified Public Accountants, Crowe selected transactions, draws on the line of credit, equipment and real
property, financial and programmatic reports, beneficiaries and applicants, organizations identified as
subrecipients by Blumont, and procurements for testing. Supporting documentation w as provided by the
auditee and subsequently evaluated to assess Blumont's compliance. Testing of indirect costs w as limited
to determining whether indirect costs w ere calculated and charged to the U.S. Government in accordance
with Blumont's Negotiated Indirect Cost Rate Agreement submitted by Blumont. We also performed
procedures to determine if adjustments to the draws that were based on preliminary or provisional rates were
made, as required and applicable.

Regarding Audit Objective 4 , Crowe inquired of Blumont, SIGAR, and USAID personnel participating in the
audit entrance conference to understand whether there were prior audits, reviews, or assessments that
were pertinent to the audit scope. Crow e also conducted an inde endent search of ublicl available
information to identi audit and review re orts.
                                                                                                       e aso
revIewe      e au I e inancIa s a emen s or umon           o a eve opmen nc. or e years 2018 and
2019 as well as the Blumont, Inc. and Affiliates audited combined financial statements and supplementary
information for the years ended December 31 , 2017-2018 and December 31 , 2018-2019. One finding was
noted in the Blumont, Inc. and Affiliates December 31, 2017-2018 report. Crowe reviewed the prior audit
report to ascertain whether the finding may be direct and material to the SPFS or significant to the audit
objectives. Crowe determined that all review ed prior audit reports were not direct or material to the award
under audit.




                                                (Continued)

                                                                                                          4
SIGAR                                Blumont Global Development, Inc.



Su mmary of Resu lts
Upon completion of Crowe's procedures, Crowe identified six (6) findings that met one or more of the
following criteria: (1 ) significant deficiencies in internal control; (2) material weaknesses in internal control;
(3) noncompliance with rules, laws, regulations, or the terms and conditions of the cooperative agreement;
and/or (4) questioned costs resulting from identified instances of noncompliance.

Crowe issued an unmodified opinion on the SPFS.

Crowe also reported on both Blumont's internal controls over financial reporting and compliance with the
applicable laws, rules, regulations, and the terms and conditions of the cooperative agreement. Five (5)
material weaknesses and one (1 ) significant deficiency in internal control were reported . Additionally, we
reported two (2) instances of noncompliance. In situations in which control and compliance findings
pertained to the same matter, the findings were consolidated within a single finding.

In performing our testing, we considered whether the information obtained during our testing resulted in
either detected or suspected material fraud, waste, or abuse, which would be subject to reporting under
Government Auditing Standards. Evidence of such items was not identified by our testing .

Crowe also requested copies of prior audits, reviews, and evaluations pertinent to Blumont's financial
performance under this cooperative agreement. Based on Crowe's communications with Blumont, SIGAR,
and USAID, Crowe reviewed eight audit reports in total issued to Blumont and its prior entity, International
Relief and Development (IRD). The three reports issued to IRD (all prior to 2015) contained twenty-nine
(29) internal control findings and twenty-eight (28) instances of noncompliance. Crowe determined that
findings included in prior audit reports were not direct or material to the Special Purpose Financial
Statement or other financial information significant to the audit objectives. Therefore, we concluded that
follow-up on the findings was not required.

                               schedule 01f jndjngs and auestjoned costs
 Finding No. Finding Name                                        Classification                 Questioned
                                                                                                Costs (USO)
   2019-01      Misstatements Identified in the Special          Material Weakness in           $0
                Purpose Financial Statement and Note             Internal Control
                Disclosures
   2019-02      Incomplete Property Records                      Material Weakness in           $0
                                                                 Internal Control and
                                                                 Noncom~liance
   2019-03      Eligibility Procedures Not Implemented as        Material Weakness in           $0
                Designed                                         Internal Control
   2019-04      Inadequate Micro-Purchase Procurement            Material Weakness in           $0
                Procedures                                       Internal Control
   2019-05      Incorrect Subrecipient-Contractor         Material Weakness in                  $0
                Determination and Inaccurate Reporting of Internal Control and
                Subawards                                 Noncom~liance
   2019-06      Inadequate Monitoring Process Over        Significant Deficiency in             $0
                Subrecipient Audit Requirements           Internal Control
Total Questioned Costs:                                                                         $0




                                                   (Continued)

                                                                                                                 5
SIGAR                              Blumont Global Development, Inc.



Summary of Management Comments
Management provided responses to the draft audit findings. A summary of management’s comments
follows:
     • Management disagreed with finding 2019-01 due to the finding being specific to the inconsistent
         presentation of the SIGAR audits and stated that “the Special Purpose Financial Statement (SPFS)
         was prepared consistent with the instructions provided during the 2018 SIGAR audit of the same
         project.”
     • Management disagreed with finding 2019-02 due to the property items having been donated to
         COMAC from other implementing partners without values and there was “no information regarding
         acquisition costs in existence.”
     • Management disagreed with finding 2019-03 and its classification and stated that they provided the
         audit team expense vouchers that show the linkage to program disbursement.
     • Management disagreed with finding 2019-04, stating that the micro-purchase procedures in place
         are sufficient.
     • Management disagreed with finding 2019-05 stating that they made their determination based off
         the scope of work and that the USAID Agreement officer was aware of the determination made.
     • Management disagreed with finding 2019-06 and stated that they provided evidence of monitoring
         on an expired RSI sub-award, as was Blumont’s Form A, which tracks sub-recipients federal
         spending if exceeding $750,000 per year.

Crowe has responded to each management response with a rebuttal in Appendix B. Crowe did not make
any changes to the findings as a result of management’s stated disagreement with each of the findings.
Crowe found that Blumont did not provide any additional information to change the condition of each finding.

Reference to Appendix
The auditor’s reports are supplemented by two appendices: Appendix A, which contains management’s
responses to the audit findings and Appendix B, which contains Crowe’s rebuttal.




                                                                                                          6
                                                                                      Crowe LLP
                                                                                      Independent Member Crowe Global




    INDEPENDENT AUDITOR’S REPORT ON THE SPECIAL PURPOSE FINANCIAL STATEMENT




To the Board of Directors of Blumont Global Development, Inc.
1777 North Kent Street Suite 300
Arlington, Virginia 22209

To the Office of the Special Inspector General for Afghanistan Reconstruction
2530 Crystal Drive
Arlington, Virginia 22202


Report on the Special Purpose Financial Statement

We have audited the Special Purpose Financial Statement (the “Statement”) of Blumont Global
Development, Inc. (“Blumont”), and related notes to the Statement, with respect to the United States Agency
for International Development’s Cooperative Agreement No. 72030618CA00005 awarded to Blumont
Global Development, Inc. (“Blumont”) for the Conflict Mitigation Assistance for Civilians (“COMAC”)
program for the period January 1, 2019 through December 31, 2019.

Management’s Responsibility for the Special Purpose Financial Statement

Management is responsible for the preparation and fair presentation of the Statement in accordance with
the requirements specified by the Office of the Special Inspector General for Afghanistan Reconstruction
(“SIGAR”) and the terms and conditions of Cooperative Agreement No. 72030618CA00005. Management
is also responsible for the design, implementation, and maintenance of internal control relevant to the
preparation and fair presentation of a Statement that is free from material misstatement, whether due to
fraud or error.

Auditor’s Responsibility

Our responsibility is to express an opinion on the Statement based on our audit. We conducted our audit in
accordance with auditing standards generally accepted in the United States of America and Government
Auditing Standards issued by the Comptroller General of the United States. Those standards require that
we plan and perform the audit to obtain reasonable assurance about whether the Statement is free from
material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the
Statement. The procedures selected depend on the auditor’s judgment, including the assessment of the
risks of material misstatement of the Statement, whether due to fraud or error. In making those risk
assessments, the auditor considers internal control relevant to the entity’s preparation and fair presentation
of the Statement in order to design audit procedures that are appropriate in the circumstances, but not for
the purpose of expressing an opinion on the effectiveness of the entity’s internal control. Accordingly, we
express no such opinion. An audit also includes evaluating the appropriateness of accounting policies used
and the reasonableness of significant accounting estimates made by management, as well as evaluating
the overall presentation of the Statement.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our
audit opinion.


                                                (Continued)

                                                                                                                    7
Opinion

In our opinion, the Special Purpose Financial Statement referred to above pertaining to Cooperative
Agreement No. 72030618CA00005 presents fairly the revenues earned, costs incurred, and balance for
the indicated period in accordance with the basis of presentation and accounting described in Notes 1, 2,
4, 5, and 6.

Basis of Presentation and Accounting

We draw attention to Notes 1, 2, 4, 5, and 6 to the Statement, which describe the basis of presentation and
accounting. The Statement is prepared in a format required by SIGAR and presents those amounts as
permitted under the terms and conditions of Cooperative Agreement No. 72030618CA00005, which is a
basis of accounting other than accounting principles generally accepted in the United States of America, to
comply with the financial reporting provisions of the cooperative agreement referred to above. Our opinion
is not modified with respect to this matter.

Restriction on Use

This report is intended for the information of Blumont, the United States Agency for International
Development (“USAID”), and the Office of the Special Inspector General for Afghanistan Reconstruction
(“SIGAR”). Financial information in this report may be privileged. The restrictions of 18 U.S.C. 1905 should
be considered before any information is released to the public.

Report on Other Legal and Regulatory Requirements

In accordance with Government Auditing Standards, we have also issued our reports dated March 4, 2021,
on our consideration of Blumont’s internal controls over financial reporting and on our tests of its compliance
with certain provisions of laws, regulations, cooperative agreement, and other matters. The purpose of that
report is to describe the scope of our testing of internal control over financial reporting and compliance and
the results of that testing, and not to provide an opinion on internal control over financial reporting or on
compliance. That report is an integral part of an audit performed in accordance with Government Auditing
Standards in considering Blumont’s internal control over financial reporting and compliance.




                                                           Crowe LLP

March 4, 2021
Washington, D.C.




                                                                                                             8
                                                    Blumont Global Development, Inc .
                                                   Special Purpose Financial Statement
                                           For the Period January 1, 2019 to December 31, 2019.




                                                                                                               Questioned Costs

                                                          Budget                Actual            Ineligible       Unsueeorted    Notes
     Revenues
     Cooperative Agreement Number 300-72030618CA00005 $      3919991873   $         9 120 738                                       4
     Total Reve nue                                  $       39,9991873   $         9 120 738


     Costs Incurred                                                                                                                 5
       PERSONNEL                                     $                    $
       FRINGE BENEFITS
       TRAVEL, TRANSPORTATION, AND PER DIEM
       ALLOWANCES
       EQUIPMENT
       SUB-GRANTEES / CONTRACTORS
       CONSULTANTS
       OTHER DIRECT COSTS
       SECURITY
       INDIRECT COSTS
     TotaJ Costs Incurred                            $       39,999 873   $         9,120 738

     Balance                                                              $                                                         6




Note: The award budget as presented within the cooperative agreement includes a $1 difference between the sum of the budgeted amounts
by account and the total award budget of $39,999,873.




                                                                                                                                          9
                                 Blumont Global Development, Inc.
                         Notes to the Special Purpose Financial Statement
                        For the Period January 1, 2019 to December 31, 2019.



Note 1. Basis of Presentation

The accompanying Special Purpose Financial Statement (the "Statement") includes costs incurred under
U.S. Agency for International Development (“USAID”) Cooperative Agreement Number 72030618CA00005
for the Conflict Mitigation Assistance for Civilians (“COMAC”) for the period January 1, 2019, through
December 31, 2019. Because the Statement presents only a selected portion of the operations of Blumont
Global Development (“Blumont”), it is not intended to and does not present the financial position, changes
in net assets, or cash flows of Blumont. The information in this Statement is presented in accordance with
the requirements specified by the Office of the Special Inspector General for Afghanistan Reconstruction
("SIGAR") and is specific to the aforementioned Federal award. Therefore, some amounts presented in
this Statement may differ from amounts presented in, or used in the preparation of, the basic financial
statements.

Note 2. Basis of Accounting

Revenues and expenditures reported on the Statement are reported on the Accrual Basis. Expenditures
are recognized following the cost principles contained in Cost Principles contained in 2 CFR 200, wherein
certain types of expenditures are not allowable or are limited as to reimbursement.

Note 3. Foreign Currency Translation Method

For purposes of preparing the Statement, translations from local currency to United States dollars were
required.

Note 4. Revenues

Revenues on the Statement represent the amount of funds to which Blumont is entitled to receive from the
USAID for allowable, eligible costs incurred under the cooperative agreement during the period of
performance.

Note 5. Costs Incurred by Budget Category

The budget categories presented, and associated amounts reflect the budget line items presented within
the final, approved award budget adopted as a component of the original budget to the cooperative
agreement started March 12, 2018 until March 11, 2023.

Note 6. Balance

The balance presented on the Statement represents the difference between revenues earned and costs
incurred such that an amount greater than $0 would reflect that revenues have been earned that exceed
the costs incurred or charged to the contract and an amount less than $0 would indicate that costs have
been incurred, but are pending additional evaluation before a final determination of allowability and amount
of revenue earned may be made.

Note 7. Currency

All amounts presented are shown in U.S. dollars.

Note 8. Subrecipients

                           received total payments of $624,122 during 2019.




                                               (Continued)

                                                                                                         10
                                Blumont Global Development, Inc.
                        Notes to the Special Purpose Financial Statement
                       For the Period January 1, 2019 to December 31, 2019.


Note 9. Program Status

The COMAC remains active. The period of performance for the award is scheduled to conclude on March
11, 2023 as noted in modification number 3 dated April 15, 2019.

Note 10. Subsequent Events

Management has performed an analysis of the activities and transactions subsequent to January 1, 2019
through December 31, 2019, the period covered by the Statement. Management has performed their
analysis through March 4, 2021.




                                                                                                  11
                                                                                        Crowe LLP
                                                                                        Independent Member Crowe Global




                    INDEPENDENT AUDITOR’S REPORT ON INTERNAL CONTROL


To the Board of Directors of Blumont Global Development, Inc.
1777 North Kent Street Suite 300
Arlington, Virginia 22209

To the Office of the Special Inspector General for Afghanistan Reconstruction
2530 Crystal Drive
Arlington, Virginia 22202

We have audited, in accordance with the auditing standards generally accepted in the United States of
America and the standards applicable to financial audits contained in Government Auditing Standards
issued by the Comptroller General of the United States, the Special Purpose Financial Statement (the
“Statement”) of Blumont Global Development, Inc. (“Blumont”), and related notes to the Statement, with
respect to the United States Agency for International Development’s Cooperative Agreement No.
72030618CA00005 for the period January 1, 2019 through December 31, 2019. We have issued our report
thereon dated March 4, 2021.

Internal Control over Financial Reporting

Blumont’s management is responsible for establishing and maintaining effective internal control. In fulfilling
this responsibility, estimates and judgments by management are required to assess the expected benefits
and related costs of internal control policies and procedures. The objectives of internal control are to provide
management with reasonable, but not absolute, assurance that the assets are safeguarded against loss
from unauthorized use or disposition; transactions are executed in accordance with management’s
authorization and in accordance with the terms of the cooperative agreement; and transactions are
recorded properly to permit the preparation of the Statement in conformity with the basis of accounting and
presentation described in Notes 1, 2, 4, 5, and 6 to the Statement. Because of inherent limitations in internal
control, errors or fraud may nevertheless occur and not be detected. Also, projection of any evaluation of the
structure to future periods is subject to the risk that procedures may become inadequate because of changes
in conditions or that the effectiveness of the design and operation of policies and procedures may
deteriorate.

In planning and performing our audit of the Statement for the period January 1, 2019, through December 31,
2019, we considered Blumont’s internal controls to determine the audit procedures that are appropriate in
the circumstances for the purpose of expressing our opinion on the Statement, but not for the purpose of
expressing an opinion on the effectiveness of Blumont’s internal control. Accordingly, we do not express an
opinion on the effectiveness of Blumont’s internal control.

Our consideration of internal control was for the limited purpose described in the second paragraph of this
section and was not designed to identify all deficiencies in internal control that might be material
weaknesses or significant deficiencies and therefore, material weaknesses or significant deficiencies may
exist that were not identified. However, as described in the accompanying Schedule of Findings and
Questioned Costs, we identified certain deficiencies in internal control that we consider to be material
weaknesses and significant deficiencies.




                                                 (Continued)

                                                                                                                    12
A deficiency in internal control exists when the design or operation of a control does not allow management
or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct,
misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in
internal control such that there is a reasonable possibility that a material misstatement of the entity’s
financial statements will not be prevented or detected and corrected on a timely basis. We consider the
deficiencies described in the accompanying Schedule of Findings and Questioned Costs as Findings 2019-
01, 2019-02, 2019-03, 2019-04, and 2019-05 to be material weaknesses.

A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe
than a material weakness, yet important enough to merit attention by those charged with governance. We
consider the deficiency described in the accompanying Schedule of Findings and Questioned Costs as
Finding 2019-06 to be a significant deficiency.

We noted certain matters that we communicated to Blumont’s management in a separate letter dated March
4, 2021.

Blumont Global Development’s Response to the Findings

Blumont’s response to the findings identified in our report are described in Appendix A to our report.
Blumont’s response to the findings were not subjected to the auditing procedures applied in the audit of the
Statement and, accordingly, we express no opinion on it.

Purpose of this Report

The purpose of this report is solely to describe the scope of our testing of internal control and the results of
that testing, and not to provide an opinion on the effectiveness of the entity’s internal control. This report is
an integral part of an audit performed in accordance with Government Auditing Standards in considering
the entity’s internal control. Accordingly, this communication is not suitable for any other purpose.

Restriction on Use

This report is intended for the information of Blumont, the United States Agency for International
Development (“USAID”), and the Special Inspector General for Afghanistan Reconstruction (“SIGAR”).
Financial information in this report may be privileged. The restrictions of 18 U.S.C. 1905 should be
considered before any information is released to the public.




                                                             Crowe LLP

March 4, 2021
Washington, D.C.




                                                                                                                13
                                                                                     Crowe LLP
                                                                                     Independent Member Crowe Global




                        INDEPENDENT AUDITOR’S REPORT ON COMPLIANCE




To the Board of Directors of Blumont Global Development, Inc.
1777 North Kent Street Suite 300
Arlington, Virginia 22209

To the Office of the Special Inspector General for Afghanistan Reconstruction
2530 Crystal Drive
Arlington, Virginia 22202


We have audited, in accordance with the auditing standards generally accepted in the United States of
America and the standards applicable to financial audits contained in Government Auditing Standards
issued by the Comptroller General of the United States, the Special Purpose Financial Statement (the
“Statement”) of Blumont Global Development, Inc. (“Blumont”), and related notes to the Statement, with
respect to the United States Agency for International Development’s Cooperative Agreement No.
72030618CA00005 for the period January 1, 2019 through December 31, 2019. We have issued our report
thereon dated March 4, 2021.

Management’s Responsibility for Compliance

Compliance with Federal rules, laws, regulations, and the terms and conditions applicable to the cooperative
agreement is the responsibility of the management of Blumont.

Compliance and Other Matters

As part of obtaining reasonable assurance about whether the Statement is free from material misstatement,
we performed tests of compliance with certain provisions of laws, regulations, and cooperative agreement,
noncompliance with which could have a direct and material effect on the determination of Statement
amounts. However, providing an opinion on compliance with those provisions was not an objective of our
audit, and, accordingly, we do not express such an opinion. The results of our tests disclosed instances of
noncompliance or other matters that are required to be reported under Government Auditing Standards and
which are described in the accompanying Schedule of Findings and Questioned Costs as Findings 2019-
02 and 2019-05.

Blumont Global Development’s Response to the Findings

Blumont’s response to the findings identified in our audit are described in Appendix A of this report.
Blumont’s response was not subjected to the auditing procedures applied in the audit of the Statement and,
accordingly, we express no opinion on it.




                                               (Continued)

                                                                                                                 14
Purpose of this Report

The purpose of this report is solely to describe the scope of our testing of compliance and the results of that
testing, and not to provide an opinion on compliance. This report is an integral part of an audit performed
in accordance with Government Auditing Standards in considering the entity’s compliance. Accordingly,
this communication is not suitable for any other purpose.

Restriction on Use

This report is intended for the information of Blumont, the United States Agency for International
Development (“USAID”), and the Special Inspector General for Afghanistan Reconstruction (“SIGAR”).
Financial information in this report may be privileged. The restrictions of 18 U.S.C. 1905 should be
considered before any information is released to the public.




                                                           Crowe LLP

March 4, 2021
Washington, D.C.




                                                                                                            15
                                  Blumont Global Development, Inc .
                        Section I Schedule of Findings and Questioned Costs
                         For the Period January 1, 2019 to December 31,201 9



FINDING 2019-01 : Misstatements Identified in the Special Purpose Financial Statement and Note
Disclosures

Material Weakness in Internal Control

Condition: Blumont stated within Note 2 to the Special Purpose Financial Statement ("SPFS"), that the
SPFS was prepared on the accrual basis of accounting. During testing of the financial records that support
the SPFS, we identified the following transactions that were recorded in the incorrect accounting period :

•   113 transactions out of 5,701 for a total of $240, 120 reflecting direct costs from 2018 that should not
    be included in the SPFS for the period January 1, 2019 through December 31, 2019;
•   Indirect Costs related to the above transactions in the total of $23,115;
•   $2,621 in government property received in 2018 was recorded and booked to 2019 due to the timing
    of payments; and
•   Revenue was misstated by a total of $265,856 due to management's having included revenue earned
    in prior period within the current SPFS.

As a result, a material total of $265,856 costs incurred was improperly included on the SPFS. Following
identification of the material misstatements, management conducted an analysis of the population and
produced a revised SPFS to exclude certain costs incurred in 2018 from the 2019 SPFS and to include
omitted 2019 costs recorded to the 2020 accounting period . Blumont corrected material errors but did not
correct $54,668 in costs recorded to the incorrect accounting period.

In addition , we noted that Blumont did not include a note disclosure regarding costs incurred by all
subrecipients. Blumont provided a listing of subrecipients to Crowe for audit that included the following
entities and corresponding award amounts, which are material to the SPFS:




I
Subsequent to our initial review and identification of the errors and omissions, management provided
revised Notes to the SPFS. Blumont did not fully correct the subrecipient disclosure, however. See Finding
2019-05.

Criteria: Note 1, "Basis of Presentation", to Blumont's SPFS states: "The accompanying Special Purpose
Financial Statement (the "Statement") includes costs incurred under Cooperative Agreement
72030618CA00005for the COMAC for the period 1/1/2019 to 12/31/2019."

Note 2, "Basis of Accounting", to the SPFS states: "Revenues and expenditures reported on the Statement
are reported on the Accrual Basis."




Effect: The government may not be receiving accurate financial information related to the program under
audit. The amounts recorded on the SPFS are misstated.




                                                (Continued)

                                                                                                         16
                                  Blumont Global Development, Inc.
                        Section I Schedule of Findings and Questioned Costs
                         For the Period January 1, 2019 to December 31,2019


Cause: Blumont did not implement an adequate financial reporting process to ensure that revenue and
expenditures were appropriately recognized and the SPFS was accurately presented. In addition, staff
were not sufficiently trained to properly prepare the SPFS.

Questioned Costs: We did not determine the costs to be ineligible, just reported incorrectly. Thus, the
amount identified is a misstatement and not a questioned cost.

Recommendation: We recommend that Blumont:
   1. Correct the remaining misstatement of $54,669 in costs incurred and reported revenue;
   2. Revise the financial reporting process to incorporate an appropriate review of financial records
   3. supporting reports and note disclosures for alignment with applicable requirement; and
   4. Provide training on the revised procedures to the appropriate personnel.




                                              (Continued)

                                                                                                         17
                                   Blumont Global Development, Inc.
                         Section I Schedule of Findings and Questioned Costs
                          For the Period January 1, 2019 to December 31,2019


FINDING 2019-02: Incomplete Property Records

Material Weakness in Internal Control and Noncompliance

Condition: During our analysis of Blumont’s property records, we noted 613 of the 2,316 items appearing
in Blumont's inventory records did not include acquisition cost. In the absence of the acquisition data, we
deemed the property records were incomplete.

Criteria: In accordance with 2 CFR Part 200.313(d)(1), Blumont is required to maintain accurate property
records “that include a description of the property, a serial number or other identification number, the source
of funding for the property (including the FAIN 2), who holds title, the acquisition date, and cost of the
property."

According to Section IV of Blumont’s Property Management Guidelines, “Blumont is responsible and
accountable for all U.S. Government property in accordance with the provisions of its contracts and
grants/cooperative agreements, including property provided under contract in possession or control of a
subcontractor or a sub-grantee.”

Additionally, Section IV outlines the duties of the Project Designated Property Custodian which includes
being “is responsible for overall administration of Government property, for affixing property tags to
Government-owned property, for reviewing and approving all equipment purchases, for obtaining any
sponsoring agency approvals necessary, for preparing Government property inventory reports.”

Section VII states that, “During project implementation, the contractor or grantee must keep adequate
records, must maintain and care for the property and must ensure its proper use for project purposes. These
obligations are defined in U.S. laws and regulations and are included in the standard provisions of USAID
contracts and agreements.

In addition, an officer of Blumont (normally Chief of Party) must make the following attestations:
1) A physical inventory is made annually of the property;
2) The accountability records maintained for the property are in agreement with the inventories; and
3) The total of the detailed accountability records agrees with the property value stated in the report.”

Effect: Blumont's incomplete listing of property records may result in inaccurate financial and inventory
records.

Cause: Management asserted that the items missing acquisition data were transferred in from other
projects and that the missing data was not initially disclosed to the project team. Blumont’s monitoring
process was inadequate to detect and correct the omissions.

Questioned Costs: Exceptions identified were transferred from a previous project and were not purchased
with award funds. Therefore, we did not identify any questioned costs.

Recommendation: Crowe recommends that Blumont:
   a) Conduct additional analysis of the 613 equipment and real property items missing acquisition costs
      and update the inventory records accordingly; and
   b) Provide training to its employees to ensure the complete and accurate recording of all equipment
      items purchased with Federal funds.




2
    Federal Award Identification Number (FAIN)

                                                 (Continued)

                                                                                                            18
                                   Blumont Global Development, Inc.
                         Section I Schedule of Findings and Questioned Costs
                          For the Period January 1, 2019 to December 31,201 9


FINDING 2019-03: Eligibility Procedures Not Implemented as Designed

Material Weakness in Internal Control

Condition: During the audit period , Blumont reported -           incidents for which determinations were
required to be made prior to use of program funds. Crowe fes!ecl 60 incidents to determine whether Blumont
provided funds for eligible incidents and complied with internal policies and procedures regarding eligibility
determinations. Our testing resulted in no identified instances of inaccurate eligibility determinations.
However, we identified two areas related to internal control weaknesses relative to Blumont's eligibility
procedures, as detailed below:

•   Discrepancies in the Incident Reporting Forms ("IRF") - Within five of the 60 incidents tested, the IRF
    was incomplete. Specifically, the IRFs did not contain incident information required by the COMAC
    Victim Assistance Procedure, such as the time of incident, source of information , and incident
    confirmation by local authorities; and

•   For 14 of 60 incidents tested, evidence of the Deputy Chief of Party's ("DCOP") review and approval of
    the information indicated on the IRF was not provided. In each instance, Blumont provided evidence of
    a compensating control where an additional approval on a Procurement Requisition form, that includes
    the DCOP sign off, as part of the final procurement package is made once the final investigation and
    eligibility determination are completed.

We requested Blumont to provide a report documenting program funds disbursed in response to each of
the above-referenced incidents. Blumont did not provide the requested reports or other such supporting
documentation linking the incidents to program disbursements.




                                                (Continued)

                                                                                                           19
                                   Blumont Global Development, Inc.
                         Section I Schedule of Findings and Questioned Costs
                          For the Period January 1, 2019 to December 31,2019


Pursuant to 2 CFR Part 200.302(b)(2), Financial Management System, Blumont is required to maintain
“Records that identify adequately the source and application of funds for federally-funded activities.”

Effect: Without approvals, COMAC may be at an increased risk of providing assistance services to
ineligible families, resulting in a misuse of government funds. Additionally, in the absence of data quantifying
benefits provided to families, the potential financial risk resulting from control deficiencies is indeterminable.

Cause: Blumont’s initial eligibility determination review and approval process did not function effectively.
Management did not perform adequate monitoring of the approval of the incident reporting forms.
Additionally, Blumont’s financial records did not include sufficient data to properly identify beneficiary costs
per incident.

Questioned Costs: We did not identify any questioned costs. As indicated in the condition, we requested
that Blumont provide a report documenting program funds disbursed in response to each of the above-
referenced incidents. However, Blumont did not provide the requested reports or other such supporting
documentation linking the incidents to program disbursements.

Recommendation: Crowe recommends that Blumont:
   1. Provide training to their employees to ensure that all required approvals are received, and
      documents are complete and accurate prior to registering an incident as eligible for COMAC
      assistance; and
   2. Calculate and communicate to USAID the costs incurred per incident and update its financial
      records.




                                                  (Continued)

                                                                                                               20
                                  Blumont Global Development, Inc.
                        Section I Schedule of Findings and Questioned Costs
                         For the Period January 1, 2019 to December 31,201 9


FINDING 2019-04: Inadequate Micro-Purchase Procurement Procedures

Material Weakness in Internal Control

Condition: Blumont's procurement policy establishes a purchasing threshold of-            in the Field Office
~ in the Home Office, below which formal bids or quotes are not reqwrecr.-such an approach
align~the micro-purchase procurement method codified at 2 CFR Part 200.320. During our review of
Blumont's written procurement procedures required by 2 CFR Part 200.318, we noted the procedures did
not specify the method Blumont utilizes to ensure micro-purchases are equitably distributed and do not
exceed Blumont's micro-purchase thresholds in the aggregate.

Blumont provided a listing of micro-purchases during the audit period totaling - - cove. in 568
contractors. Of the 568 contractors, 45 contractors were noted as having receiv~   han        in
payments. The total costs for the 45 vendors was- - Both the total micro-purchases and e costs
for contractors exceeding -       in the aggregatearematei-ial.

Criteria: Pursuant to 2 CFR Part 200.303(a), Internal controls, Blumont is required to establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal
entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award.

2 CFR Part 200.320(a)(1)(i), Methods of procurement to be followed, states that procurement by micro-
purchase is "the acquisition of supplies or services, the aggregate dollar amount of which does not exceed
the micro-purchase threshold (§200.67 Micro-purchase). To the extent practicable, the non-Federal entity
must distribute micro-purchases equitably among qualified suppliers." Additionally, 2 CFR Part
200.320(a)(1)(ii) states that "Micro-purchases may be awarded without soliciting competitive quotations if
the non-Federal entity considers the price to be reasonable."




Effect: In the absence of a formal policy or procedure pertaining to micro-purchases, the likelihood that
Blumont will distribute micro-purchases to vendors in an unequitable manner or purchase goods and
services through micro-purchase processes that exceed the threshold is increased .

Cause: Blumont did not consider it necessary to document its procedure regarding equitable distribution.

Questioned Costs: No reportable questioned costs were determined.




                                                (Continued)

                                                                                                          21
                                Blumont Global Development, Inc.
                      Section I Schedule of Findings and Questioned Costs
                       For the Period January 1, 2019 to December 31,2019


Recommendation: We recommend that Blumont:
   1. Develop, document, and implement a policy or procedure regarding the equitable distribution of
      micro-purchases and that incorporates monitoring of micro-purchases for compliance with the
      Uniform Guidance; and
   2. Provide training to staff regarding implementation of the policy or procedure.




                                            (Continued)

                                                                                                 22
                                        Blumont Global Development, Inc.
                             Section I Schedule of Findings and Quest ioned Costs
                              For t he Period January 1, 2019 to December 31,201 9


FINDING 201 9-05: Incorrect Subrecipient -Cont ractor Determinations and Inaccurate Reporting of
Subawards to the Government

Material Weakness in Internal Control and Noncompliance

Condjtjon:  Blumont provided a listing of three subrecipients in response to Crowe's request for a

j'
subrecipient population . The subrecipient population provided by Blumont contained the following
  ganizations:




Analysis of Subrecipient-Contractor Determinations
We requested documentation to support Blumont's subrecipient-contractor determinations at the time
Blumont entered each subaward. In response, Blumont provided their Source Selection Justification
memorandum and Form A "Eligibility Checklist for Subinstruments of $25,000 or more under Prime US
Government Awards" which indicated that -           would be a contract. However, neither the form nor
memorandum provided sufficient detail or arialyslsto demonstrate alignment with 2 CFR 200.330.

Management also provided copies of its agreements wit                                      , including statements of work.
We analyzed the agreements entered into by and between umo                                       and Blumont and _        ,
respectively, and concurred with Blumont's determination that                           1s a contractor. Therefore.the
reporting of-      to www.fsrs.gov as a subgrantee is incorrect.

Regarding -        · we reviewed publicly available data regarding -          services, activities, and other
matters a s ~ s the agreement with Blumont. Further, we requested documentation from Blumont
evidencing -          provision of the applicable services in a commercial environment, providing the same
or similar services to many different purchasers, and providing the requested services within normal
business operations. Blumont did not provide documentation demonstrating that -                 operates in a
commercial environment or that the services provided, in general, are commercial in riature.' w e also noted
the services provided carry out the program for a public purpose and - based on our review of VOWO's
scope of work - carried out sco~ded within the Blumont cooperative agreement. In consideration of
these matters, we concluded -            is a subrecipient, consistent with Blumont's reporting of -
through www.fsrs.gov.4




3
  Per USAspending.gov, 'The Sub-Awards tab displays any sub-grants reported by this grant's recipient (the
"prime recipienr in a sub-award context). A sub-award is an agreement that a prime recipient makes with
another entity to perform a portion of their award. On our website, these recipients are known as sub-
recipients. Sub-awards might also be referred to as a sub-contract or a sub-grant Sub-grants are awards of
financial assistance made under a grant by a prime grantee to an eligible subgrantee."
4
   Subaward data presented on www.usaspending.gov is based on information provided by the recipient through its submission of
data to wwwfsrs.gov to comply with the provisions of the Federal Funding Accountability and Transparency Act.

                                                         (Continued)

                                                                                                                                23
                                    Blumont Glo bal Develo pment, Inc .
                        Section I Sc hedule of Findings and Quest io ned Costs
                         Fo r t he Period J anuary 1, 2019 to December 31,201 9




Crjterja: According to 2 CFR 200.330 Subrecipient and Contractor Determinations, 'The Non-Federal entity
may concurrently receive Federal awards as a recipient, a subrecipient, and a contractor, depending on the
substance of its agreements with Federal awarding agencies and pass-through entities. Therefore, a pass-
through entity must make case-by-case determinations whether each agreement it makes for the
disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or
a contractor. The Federal awarding agency may supply and require recipients to comply with additional
guidance to support these determinations provided such guidance does not conflict with this section.
(a) Subrecipients. A subaward is for the purpose of carrying out a portion of a Federal award and creates
a Federal assistance relationship with the subrecipient. See §200.92 Subaward . Characteristics which
support the classification of the non-Federal entity as a subrecipient include when the non-Federal entity:
(1) Determines who is eligible to receive what Federal assistance;
(2) Has its performance measured in relation to whether objectives of a Federal program were met;
(3) Has responsibility for programmatic decision making ;
(4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award ;
and
(5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose
specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-
through entity.

(b) Contractors. A contract is for the purpose of obtaining goods and services for the non-Federal entity's
own use and creates a procurement relationship with the contractor. See §200.22 Contract. Characteristics
indicative of a procurement relationship between the non-Federal entity and a contractor are when the non-
Federal entity receiving the Federal funds:
(1) Provides the goods and services within normal business operations;
(2) Provides similar goods or services to many different purchasers;
(3) Normally operates in a competitive environment;
(4) Provides goods or services that are ancillary to the operation of the Federal program; and
(5) Is not subject to compliance requirements of the Federal program as a result of the agreement, though
similar requirements may apply for other reasons.

(c) Use of judgment in making determination. In determining whether an agreement between a pass-
through entity and another non-Federal entity casts the latter as a subrecipient or a contractor, the
substance of the relationship is more important than the form of the agreement. All of the characteristics
listed above may not be present in all cases, and the passthrough entity must use judgment in classifying
each agreement as a subaward or a procurement contract."




2 CFR 200 states in that "[i]n determining whether an agreement between a pass-through entity and another
non-Federal entity casts the latter as a sub-recipient or a contractor, the substance of the relationship is
more important than the form of the agreement. All of the characteristics listed above may not be present
in all cases, and the pass-through entity must use judgment in classifying each agreement as a sub-award
or a procurement contract.

                                               (Continued)

                                                                                                         24
                                  Blumont Global Development, Inc.
                        Section I Schedule of Findings and Questioned Costs
                         For the Period January 1, 2019 to December 31,2019



Use sub-award when intent is to have another organization carry out the scope of work described in the
prime award.”

Effect: The Government may be charged additional costs that are ineligible for subrecipients (e.g., profit)
due to improper classification of       as a contractor. In addition, the misclassified contractor may fail
to comply with federal regulatory requirements applicable subrecipients if the entity is unaware it is a
subrecipient.

Cause: Blumont’s procedures for determining whether a vendor qualifies as sub recipient or contractor do
not include adequate requirements for documenting that determination, and Blumont’s personnel were not
adequately trained to make these determinations. In addition, Blumont’s procedures also do not require a
detailed determination of each vendor based on the requirements in to 2 CFR 200.330 Subrecipient and
Contractor Determinations.

Further, management did not sufficiently monitor the reporting of subrecipients to the US government nor
the recording of transactions in their financial records related to contractors and subrecipients.

Questioned Costs: Blumont’s accounting for these vendors was consistent with that of a subrecipient. As
such, no additional costs, such as indirect costs, were applied to the costs incurred by these vendors that
would be questioned. Additionally, Blumont notified and received approval from USAID for each of the
vendors indicated.

Recommendation: We recommend that Blumont:
   1. Update their policies and/or procedures to require a detailed determination of each vendor based
      on the requirements in to 2 CFR 200.330 Subrecipient and Contractor Determinations and provide
      training to personnel on how to make these determinations;
   2. Perform a review of all entities listed in the subaward account and reconcile the account to only
      include those transactions related to entities determined to be subrecipients, and implement
      monitoring process over the recording of subrecipient costs in the accounting system;
   3. Implement a process to monitor the reporting of sub-recipient to the government; and
   4. Provide training to applicable personnel on the additional monitoring processes.




                                               (Continued)

                                                                                                        25
                                   Blumont Global Development, Inc .
                         Section I Schedule of Findings and Questioned Costs
                          For the Period January 1, 2019 to December 31,201 9


FINDING 2019-06: Inadequate Monitoring Process Over Subrecipient Expenditures for Compliance
with Audit Requirements

Significant Deficiency in Internal Control

Condition: We requested the standard operating procedures related to the monitoring of subrecipients,
including procedures to determine when a subrecipient is required to be audited based on actual costs
incurred during the subrecipient's fiscal year. Blumont provided a Form C related to a Pre-Award Survey
and Due Diligence Questionnaire. However, Blumont's procedures and Form C did not indicate the steps
that are to be taken to identify total Federal expenditures/costs incurred during the fiscal year so as to
determine when expenditures reach the $750,000 required for an audit under federal regulations.

Blumont asserted they monitor the total expenditures through the use of an incurred cost worksheet. We
requested the supporting documentation; however, we did not receive support from Blumont to confirm that
assertion, and were unable to determine whether the sub-recipients had an audit conducted in accordance
with federal audit requirements.

Criteria: Pursuant to 2 CFR Part 200.303(a), Internal controls, Blumont is required to establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the non-Federal
entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award.

Pursuant to 2 CFR 200.501 , Audit requirements, Blumont is required to comply with the following
requirements:
(a) Audit required. A non-Federal entity that expends $750,000 or more during the non-Federal entity's
fiscal year in Federal awards must have a single or program-specific audit conducted for that year in
accordance with the provisions of this part.

(b) Single audit. A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal
year in Federal awards must have a single audit conducted in accordance with§ 200.514 except when it
elects to have a program-specific audit conducted in accordance with paragraph (c) of this section.




Effect: Management is at risk of issuing awards to entities who have not met their audit requirements,
resulting in a non-compliance with Federal requirements . In addition, should subawardees or contractors
not have audits conducted when required, Blumont may be unaware of errors and issues that impact federal
awards.

Cause: Blumont's Sub-Awards Policy was not properly designed to include monitoring procedures over an
awardee's expenditures during the post-award phase to ensure that awardees' are meeting their federal
requirements related to program-specific audits.

Questioned Costs: NIA. The finding is related to an inadequate internal control process and not an issue
with non-compliance. No specific costs are at question.
Recommendation: Crowe recommends that Blumont
    1. Revise its Sub-Awards Policy to include a procedure on the identification of when a recipient is
        subject to an audit and/or has triggered an audit requirement.
    2. Provide training to its employees to effectively implement the revised Sub-Awards Policy.




                                                (Continued)

                                                                                                          26
                                  Blumont Global Development, Inc.
              Section II Summary Schedule of Prior, Review and Assessment Findings
                         For the Period January 1, 2019 to December 31,2019




Crowe reviewed eight prior audit reports that contained (29) internal control findings and twenty-eight (28)
instances of noncompliance. We assessed the findings to ascertain whether the matters may be direct and
material to the Special Purpose Financial Statement or other financial information significant to the audit
objectives. In addition, we reviewed the prior auditor’s comments regarding the status of prior audit findings.
During our review of the reports, we noted there were no findings that were direct and material to the Special
Purpose Financial Statement and our audit objectives. Accordingly, Crowe concluded that no additional
procedures or follow up were required. We included reports issued to the Blumont’s previous, entity
International Relief and Development, Inc., to assist with our risk assessment.

The reports reviewed by Crowe are listed below:
1. Blumont Global Development – Audited Financial Statements for the Year Ended December 31, 2018
2. Blumont Global Development – Audited Financial Statements for the Year Ended December 31,2019
3. Blumont, Inc. and Affiliates – Audited Combined Financial Statements and Supplementary Information
   Years Ended December 31, 2018 and 2017
4. Blumont, Inc. and Affiliates – Audited Combined Financial Statements and Supplementary Information
   Years Ended December 31, 2019 and 2018
5. SIGAR 17-35 Financial Audit - USAID’s Kandahar Food Zone Program: Audit of Costs Incurred by
   International Relief and Development Inc. – April 2017
6. SIGAR 14-39 Financial Audit - USAID’s Strategic Provincial Roads Program: Audit of Costs Incurred
   by International Relief and Development, Inc. – February 2014
7. SIGAR 15-7 Financial Audit - USAID’s Afghanistan Vouchers for Increased Production in Agriculture
   Program: Audit of Costs Incurred by International Relief & Development, Inc. – October 2014
8. SIGAR Financial Audit 13-08 – USAID’s Human Resources and Logistical Support Program Audit of
   Costs Incurred by International Relief Development, Inc. – July 2013




                                                                                                            27
SIGAR                            Blumont Global Development, Inc.



APPENDIX A VIEWS OF RESPONSIBLE OFFICIALS
Blumont provided the following response to Crowe via email on February 26, 2021, regarding the findings
contained in the draft report. The response has been included herein verbatim and source formatting
retained.




                                                                                                    28
SIGAR   Blumont Global Development, Inc.




                                           29
SIGAR                            Blumont Global Development, Inc.




                                                                                                 ~
                                                                                          BLUMONT.
        other implementers, it is not possible forth ls finding to resu~ tn a materia l
        error and die current classrfication as a Material Weakne5s is unsupported by the facts.


        "Find ing 2 0 1 9 -0 3 : Eligibility Procedures Not Implemented a s Designed

        Recommenda ti on: 1) Provide training to their em ployees to ensure t hat all required
        approvals are received, and documents are complete and accurate prior to registering
        an incident as eligible for CO MAC assistance and 2) Calculate and communicate to
        USAID the costs incurred per incide_nt and update its financia l records."

        Blumont Response: Blumont disagrees with the statement include d in t he Condition
        section of this finding that Blumont did not provfde the requested reports orother such
        supporting documentation linking the incidents to program disbursements. In fact, we
        did provide to the audit team expense vouchers that show thts linkage. Regarding the
        recommendations, both have been cc1rrled out; trainfng has been conducted and USAID
        has been provided with updated info rmatio n. Additiona lty, t he COMAC team has
        updated SOP (Standard Operating Procedu re) guidelines for program staff and the
        staff undergo refresher trainings. As Crowe did not identify any instances of inaccurate
        eligibility or unallowable costs and determined appropriate mitigating controls were in
        p lace, the current classification of the finding as a Material Weakness is unsupported by
        the facts.


        "Find ing 2019-04: Undocumented Micro-Purchase Procu rement Procedures
        Recommendation: 1) Develop, document, and implement a policy or procedure
        regarding the equitable distribution of micro-purchases and that incorporat es
        monitoring of micro-purchases for complia nce with the Uniform Guidance; and 2)
        Provide training to staff regarding implementation of the policy or procedure."

        Blvmoht RespOhse: Procedures over micro-purchases, in accordance with 2 CFR Part
        200. 320  are included in Blumont's policies, which were shared with t he auditors during
        t he audit. Blumont complies with its micro-purchase policy which does not allow for the
        splitting of purchases to mitigate procurement requirements. As discussed with the
        a~dit~rs, micro-~~~chases are used on a c~           <1se basis. All pro~urements ove~t_he
        S1mpl1fied Acqu1s1t1on Threshold (SAT) of -         n the field office include compet1t1on
        and ensure an equitable and fa ir distribution to vendors. The vendors referenced in the
        Conditi on include all transactions that do not include a Purchase Order in Blumont's
        accounting system_ A transaction without a Purchase Order doe.snot necessarily
        indicate a micro-purchase as discussed with Crowe. This data was presented by month




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SIGAR   Blumont Global Development, Inc.




                                           31
SIGAR   Blumont Global Development, Inc.




                                           32
SIGAR                                Blumont Global Development, Inc.



APPENDIX B AUDITOR’S REBUTTAL
Crowe LLP (“Crowe” or “we” or “us”) has reviewed the management response of Blumont Global
Development, Inc. (“Blumont” or “the auditee”) responses to the draft report audit findings provided to Crowe
on February 26, 2021. In consideration of those views, Crowe has included the following rebuttal to certain
matters presented by the auditee. Crowe incorporates a rebuttal in those instances where management
disagrees with the facts presented within the condition, does not concur with Crowe’s recommendation, or
provides additional documentation for review. In those instances where management either agrees with the
finding or does not disagree with the facts in the finding, as presented, no rebuttal is provided. Using this
framework, Crowe has incorporated six rebuttals to management’s comments, below.

Finding 2019-01: Misstatements Identified in the Special Purpose Financial Statement and Note
Disclosures
Blumont disagreed with the finding due to the finding being specific to the inconsistent presentation of the
SIGAR audits and stated that “the Special Purpose Financial Statement (SPFS) was prepared consistent
with the instructions provided during the 2018 SIGAR audit 5 of the same project. The 2018 SIGAR auditors
(Clifton, Larson, Allen), requested that the SPFS be prepared in a consistent manner to the expenditures
reported on the Standard Form 425.” They also indicated that, “The criteria used by Crowe to evaluate the
SPFS is different than the 2018 SPFS criteria and was not initially communicated to Blumont.” It is Blumont’s
responsibility to provide the SPFS and accompanying notes and it is our responsibility to perform the audit
based on the information provided. On July 8, 2020, Blumont provided their Special Purpose Financial
Statement and Notes to the SIGAR SPFS. Note 2 Basis of Accounting, as filled out by Blumont, stated that,
“Revenues and expenditures reported on the Statement are reported on the Accrual Basis. “We performed
our procedures utilizing the SPFS and accompanying notes as presented by Blumont. Blumont’s later
assertion that the SPFS was developed utilizing a different basis of accounting does not warrant altering
our finding. We have reviewed management’s response and noted that the response did not alter the facts
underlying each finding. In consideration of these matters and management not having provided
documentation that may serve as sufficient, appropriate audit evidence to clear the reported matters, the
finding has not been changed.

Finding 2019-02: Incomplete Property Records
Blumont disagreed with the finding because the items were donated to COMAC from other implementing
partners without values and there was “no information regarding acquisition costs in existence.” Blumont
also stated that they had requested the information related to acquisition costs from the implementing
partners, but the documentation was never provided. However, Blumont did not provide additional evidence
to support this claim. Blumont also disagreed with the classification of the finding as a material weakness
as it “is not possible for this finding to result in a material error and the current classification as a Material
Weakness us unsupported by the facts.” Blumont is responsible for the items and required to include
acquisition costs in their property listing, including reporting the cost of the asset in accordance with 2 CFR
200, Uniform Guidance. Without being able to determine the financial impact due to the missing cost data,
management cannot support materiality conclusions. In consideration of these matters and management
not having provided documentation that may serve as sufficient, appropriate audit evidence to clear the
reported matters, the finding and its classification have not been changed.

Finding 2019-03: Eligibility Procedures Not Implemented as Designed
Blumont disagreed with the finding and stated that they provided the audit team expense vouchers that
show the linkage to program disbursement. Crowe notes that Blumont provided expense vouchers related
to two sampled incidents on November 4, 2020. However, as indicated in the finding, we requested details
of the expenses related to the following noted discrepancies:



5
  Blumont mistakenly cited SIGAR as the agency for who the referenced audit, and resulting report, was
conducted on behalf of. However, the referenced audit was conducted on behalf of USAID’s Office of
Inspector General and not SIGAR.



                                                                                                               33
SIGAR                               Blumont Global Development, Inc.


•



•   For 14 of 60 incidents tested , evidence of the Deputy Chief of Party's ("DCOP") review and approval
    of the information indicated on the IRF was not provided. In each instance, Blumont provided
    evidence of a compensating control where an additional approval on a Procurement Requisition form,
    that includes the DCOP sign off, as part of the final procurement package is made once the final
    investigation and eligibility determination are completed.

Blumont did not address these discrepancies in their response nor did they provide a report documenting
program funds disbursed in response to each of the above-referenced incidents or other such supporting
documentation linking the incidents to program disbursements. Blumont also disagreed with the current
classification of the finding as a material weakness. A material weakness is a deficiency, or a combination
of deficiencies, in internal control such that there is a reasonable possibility that a material misstatement of
the entity's financial statements will not be prevented or detected and corrected on a timely basis. Blumont
was unable to support that their eligibility processes were contemporaneously conducted or provide
financial details related to the identified incidents. In consideration of these matters and management not
having provided documentation that may serve as sufficient, appropriate audit evidence to clear the
reported matters, the finding and its classification have not been changed.

Finding 2019-04 : Inadequate Micro-Purchase Procurement Procedures
Blumont disagreed with the finding and discussed the procedures related to micro-purchases that are
included in their policy. Blumont stated that, "All procurements over the Simplified Acquisition Threshold
(SAT) of -           in the field office include competition and ensure an equitable and fair distribution to
vendors."~          er, Blumont did not provide additional procedures for review, nor other language detailing
how the equitable and fair distribution of those micro-purchases is accomplished included in the current
policy, for. As indicated in the finding and based on information provided by BluM  mont both the total value
  f ·        urchases - - and the costs for contractors exceeding                            in the aggregate
               are mat~                sideration of these matters and managemen not having provided
            ation that may serve as sufficient, appropriate audit evidence to clear the reported matters, the
finding and its classification have not been changed.

Finding 2019-05:       Incorrect Subrecipient-Contractor Determinations and Inaccurate Reporting of
Subawards to the Government
We have reviewed Blumont's response an noted it does not address how Blumont satisfied the
requirements from 2 CFR 200.330 Subrecipient and Contractor Determinations. Blumont disagreed with
the recommendation and stated that "bases its determination of sub-contractor vs. sub-recipient using the
agreed upon Scope of Work, i.e., the type of services and deliverables to be provided and the requirement
for technical direction." Crowe notes that the Scope of Work was used as the basis for the determination;
however, the scope of work by itself cannot be used to make that determination, and documentation to
support those assertions at the time the determination was made were not available. Additionally, Blumont
stated that "the USAID Agreement Officer is aware of Blumont's "sole" subcontractor and our files are
documented; therefore, we do not agree that policies need to be updated." We appreciate that the USAID
AO is aware of the "sole" subcontractor, but awareness is not relevant to the documentation that is required
to support the determination made. Further, management indicated in their response, "Blumont reviews,
monitors, and tracks entities listed in prime award, as well as our sub-award account. Currently, COMAC
has only one "Sub-Contractor" not "Sub-Recipient." Our finding discussed the improper classification and
accounting for their sub-recipients. Blumont was awarded a cooperative agreement and not a contract.
Therefore, Blumont could not technically have a sub-contractor and should classify and account for their
vendors or subrecipients appropriately. In consideration of these matters and management not having
provided documentation that may serve as sufficient, appropriate audit evidence to clear the reported
matters, the finding has not been changed .




                                                                                                             34
SIGAR                             Blumont Global Development, Inc.


Finding 2019-06: Inadequate Monitoring Process Over Subrecipient Expenditures for Compliance with
Audit Requirements
Blumont disagreed with the finding and indicated that they provided evidence of monitoring on the expired
RSI sub-award, as was Blumont’s Form A, which tracks sub-recipients federal spending if exceeding
$750,000 per year. As previously discussed with Blumont after receiving such additional documentation,
we stated that the procedures are lacking sufficient detail to document Blumont’s procedures performed to
determine if audit requirements were met. In consideration of these matters and management not having
provided documentation that may serve as sufficient, appropriate audit evidence to clear the reported
matters, the finding has not been changed.




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SIGAR   Blumont Global Development, Inc.




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                                            36
                               The mission of the Special Inspector General for Afghanistan
           SIGAR's Mission     Reconstruction (SIGAR) is to enhance oversight of programs for t he
                               reconst ruction of Afghanistan by conduct ing independent and
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