EIN: 061595035
UEI: FJHWGN95WDA7
Audited by: BDO USA, PC
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 28, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by November 28, 2026 (90 days from today).
What is a management decision? →FAC accepted this audit on May 21, 2025 — management decision was due November 21, 2025.
FAC accepted this audit on May 28, 2024 — management decision was due November 28, 2024.
FAC accepted this audit on June 4, 2023 — management decision was due December 4, 2023.
During our testing over special tests and provisions, we identified the following condition: Under the terms of the grant agreement, at no point in time for the duration of the grant agreement shall there be commingling of reserve account funds from the grant with other funds that the Organization may have, even if the funds are used for similar purposes. Based on four (4) credit enhancements sampled and tested from a population of four (4) credit enhancements obligated between 1/1/2022 and 12/31/2022, there was commingling of federal reserve funds with private funds for one (1) of the four (4) samples tested. Both the federal and private funds were commingled into one reserve account. While the monitoring process did not appropriately detect or prevent, on a timely basis, the noncompliance with the special provisions of the grant agreement, the monitoring process did ensure that the grantee met the special provisions of the grant agreement after the end of the year. Questioned Costs: There are no questioned costs as the item outlined above is an internal control related matter related to compliance requirements not met in accordance with the grant agreement. Context: This is a condition identified per review of the Organization?s compliance with the special tests and provisions criteria of the Uniform Guidance using a statistically valid sample. The prevalence of these findings is detailed in the condition section above. Cause: The Organization has documented monitoring policies and procedures; however, as identified above, the implementation of these policies and procedures did not detect or prevent the instance of noncompliance with the special tests and provisions criteria contained within the Uniform Guidance. Effect: While there are no known questioned costs that resulted from the condition identified above, the improper implementation of established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to expenditures incurred being disallowed or reserve funds being required to be returned for the major federal program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend that management regularly provide training to those involved with the grant to ensure that those monitoring the reserve fund accounts are knowledgeable of the terms of the grant agreement and have knowledge of the grant operations. We also recommend that management ensure that reserve fund accounts invested in certificates of deposits are tracked by maturity and for those coming due, management provides timely written instructions to the financial institution as to where to direct the reserve funds to ensure that reserve funds are not comingled. Views of Responsible Officials: Management agrees with the finding. Management plans to ensure that the financial institutions holding reserve funds have clear instruction in writing as to how to direct all reserve funds to ensure that the reserve funds are not comingled.
Show full finding ▾Hide full finding ▴2022-001 Internal Control over Compliance and Compliance with Special Tests and Provisions Information on Federal Program: U.S. Department of Education Name of Program: Credit Enhancement for Charter School Facilities Assistance Listing Number: 84.354 Grant Award Number: None Grant Award Period: February 4, 2003 until the Federal funds and earnings on those funds have been expended for the grant purposes or until financing facilitated by the grant has been retired, whichever is later. Criteria or Specific Requirement: In accordance with ?200.303(a), Internal Controls, a non-federal entity must 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. ?200.328, Monitoring and Reporting Program Performance, documents that the non-federal entity is responsible for oversight of the operations of the federal award supported activities. The non-federal entity must monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. Monitoring by the non-federal entity must cover each program, function or activity. The grant agreement section VI, paragraph 5, requires the grantee to not comingle reserve account funds from this grant with other funds the grantee may have, even if the funds are used for similar purposes. Condition: During our testing over special tests and provisions, we identified the following condition: Under the terms of the grant agreement, at no point in time for the duration of the grant agreement shall there be commingling of reserve account funds from the grant with other funds that the Organization may have, even if the funds are used for similar purposes. Based on four (4) credit enhancements sampled and tested from a population of four (4) credit enhancements obligated between 1/1/2022 and 12/31/2022, there was commingling of federal reserve funds with private funds for one (1) of the four (4) samples tested. Both the federal and private funds were commingled into one reserve account. While the monitoring process did not appropriately detect or prevent, on a timely basis, the noncompliance with the special provisions of the grant agreement, the monitoring process did ensure that the grantee met the special provisions of the grant agreement after the end of the year. Questioned Costs: There are no questioned costs as the item outlined above is an internal control related matter related to compliance requirements not met in accordance with the grant agreement. Context: This is a condition identified per review of the Organization?s compliance with the special tests and provisions criteria of the Uniform Guidance using a statistically valid sample. The prevalence of these findings is detailed in the condition section above. Cause: The Organization has documented monitoring policies and procedures; however, as identified above, the implementation of these policies and procedures did not detect or prevent the instance of noncompliance with the special tests and provisions criteria contained within the Uniform Guidance. Effect: While there are no known questioned costs that resulted from the condition identified above, the improper implementation of established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to expenditures incurred being disallowed or reserve funds being required to be returned for the major federal program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend that management regularly provide training to those involved with the grant to ensure that those monitoring the reserve fund accounts are knowledgeable of the terms of the grant agreement and have knowledge of the grant operations. We also recommend that management ensure that reserve fund accounts invested in certificates of deposits are tracked by maturity and for those coming due, management provides timely written instructions to the financial institution as to where to direct the reserve funds to ensure that reserve funds are not comingled. Views of Responsible Officials: Management agrees with the finding. Management plans to ensure that the financial institutions holding reserve funds have clear instruction in writing as to how to direct all reserve funds to ensure that the reserve funds are not comingled.
2022-001 Internal Control over Compliance and Compliance with Special Tests and Provisions Contact: Robin Odland Title: President Phone Number: 202-457-1989 Estimated Completion Date: First quarter 2023 Corrective Action: Management takes the provisions of the grant agreement very seriously and has procedures in place to address the prevention of commingling federal funds with private funds. The current condition regarding the commingling of funds was unintentional. Management distributed funds to an escrow agent using both federal and private funds. These funds were deposited into one account as reserved funds to support a credit enhancement transaction. The funds were separated into two sub-accounts to maintain the division of federal versus private funds. The account was a certificate of deposit account. On December 29, 2022 the certificate of deposit matured. Without management?s instruction, the escrow agent decided not to reinvest the funds according to the agreed upon policy and instead erroneously deposited the cash into one federal cash account. As soon as management became aware that the funds were commingled approximately a month later, the private funds were transferred from the federal account into a private account. Management utilizes general ledger accounts to display the separation of federal and private funds. On an ongoing basis, management reviews all cash accounts to ensure funds are not commingled. Monthly, management reviews the balance sheet to manage our cash activity and quarterly, reviews reports that present the separation of the cash groupings.
During our testing over reporting requirements, we noted that the required annual performance report (APR) as prepared and submitted in accordance with the terms of the award did not reconcile to underlying accumulated records. Cause: The Organization has documented monitoring policies and procedures; however, as identified above, the implementation of these policies and procedures did not detect or prevent the instance of noncompliance with the reporting criteria contained within the Uniform Guidance. Effect: While there are no known questioned costs that resulted from the condition identified above, the improper implementation of established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs or reserve funds being required to be returned for the major federal program. Questioned Costs: There are no questioned costs as the item outlined above is an internal control related matter related to compliance requirements not met in accordance with the grant agreement. Context: This is a condition identified during our testing over the reporting requirements. Any samples selected as part of the overall SEFA review and testing of reporting were performed using a non-statistical method. Repeat Finding: This is a repeat finding of 2021-001. Recommendation: In order to facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, we recommend management ensure all reporting requirements are documented, maintained and updated as necessary. Views of Responsible Officials: Management agrees with the finding. Management has identified the underlying calculation causing the reporting error and will use the proper calculation going forward as well as implementing a second review to ensure that the summarized data agrees to the underlying data.
Show full finding ▾Hide full finding ▴2022-002 Internal Control over Compliance and Compliance with Reporting Information on the Major Federal Program: U.S. Department of Education Name of Program: Credit Enhancement for Charter School Facilities Assistance Listing Number: 84.354 Grant Award Number: None Grant Award Period: February 4, 2003 until the Federal funds and earnings on those funds have been expended for the grant purposes or until financing facilitated by the grant has been retired, whichever is later. Criteria or Specific Requirement: In accordance with ?200.303(a), Internal Controls, a non-federal entity must 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. ?200.328, Monitoring and Reporting Program Performance, documents that the non-federal entity is required to submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be not less frequent than annually, nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the federal award or could significantly affect program outcomes. The reports submitted to the federal awarding agency should be accurate. The grant agreement section VI, paragraph 9, requires the grantee to submit an annual performance report (with such information and at such time as the Secretary may require) and audited financial statements to the Department of Education (ED) for each fiscal year that the grantee?s obligation to the Federal Government remains in effect. (The grantee?s commitment continues for the duration of time that reserve funds and earnings are used to achieve the specified grant purposes.). Condition: During our testing over reporting requirements, we noted that the required annual performance report (APR) as prepared and submitted in accordance with the terms of the award did not reconcile to underlying accumulated records. Cause: The Organization has documented monitoring policies and procedures; however, as identified above, the implementation of these policies and procedures did not detect or prevent the instance of noncompliance with the reporting criteria contained within the Uniform Guidance. Effect: While there are no known questioned costs that resulted from the condition identified above, the improper implementation of established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs or reserve funds being required to be returned for the major federal program. Questioned Costs: There are no questioned costs as the item outlined above is an internal control related matter related to compliance requirements not met in accordance with the grant agreement. Context: This is a condition identified during our testing over the reporting requirements. Any samples selected as part of the overall SEFA review and testing of reporting were performed using a non-statistical method. Repeat Finding: This is a repeat finding of 2021-001. Recommendation: In order to facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, we recommend management ensure all reporting requirements are documented, maintained and updated as necessary. Views of Responsible Officials: Management agrees with the finding. Management has identified the underlying calculation causing the reporting error and will use the proper calculation going forward as well as implementing a second review to ensure that the summarized data agrees to the underlying data.
2022-002 Internal Control over Compliance and Compliance with Reporting Contact: Robin Odland Title: President Phone Number: 202-457-1989 Estimated Completion Date: Second quarter 2023 Corrective Action: In April 2023, management identified a faulty calculation in its APR Spreadsheet and corrected the error. As a result of the correction, the total leverage on the APR spreadsheet and summary APR report filed with the U.S. Department of Education will be amended on May 1st, 2023. Management intends to resolve the problem in the future by taking the following additional actions: 1) future APR reports will be based upon the corrected spreadsheet, which has corrected summing error. 2) The sums of the APR spreadsheet will be checked by two parties before submission, to confirm accuracy?the parties will include the party preparing the report and the Accounting Manager responsible for accounting for credit enhancement grants.
2021-001
FAC accepted this audit on July 10, 2022 — management decision was due January 10, 2023.
During our testing over reporting requirements, we noted that the required annual performance report (APR) as prepared and submitted in accordance with the terms of the award did not reconcile to underlying accounting records. Questioned Costs: There are no questioned costs as the item outlined above is an internal control related matter related to compliance requirements not met in accordance with the grant agreement. Context: This is a condition identified during our testing over the reporting requirements. Cause: The Organization has documented monitoring policies and procedures; however, as identified above, the implementation of these policies and procedures did not detect or prevent the instance of noncompliance with the reporting criteria contained within the Uniform Guidance. Effect: While there are no known questioned costs that resulted from the condition identified above, the improper implementation of established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: In order to facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, we recommend management ensure all reporting requirements are documented, maintained and updated as necessary. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴2021-001 Internal Control over Compliance and Compliance with Reporting Information on Federal Program: U.S. Department of Education Name of Program: Credit Enhancement for Charter School Facilities Assistance Listing Number: 84.354 Grant Award Number: None Grant Award Period: February 4, 2003 until the Federal funds and earnings on those funds have been expended for the grant purposes or until financing facilitated by thegrant has been retired, whichever is later. Criteria or Specific Requirement: In accordance with ?200.303(a), Internal Controls, a non-federal entity must 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. A federal awarding agency may solicit only the standard, Office of Management and Budget (OMB) approved government-wide data elements for collection of financial information unless otherwise approved by the OMB in accordance with ?200.337, Financial Reporting. The information collected under this requirement must be collected with the frequency required by the terms and conditions of the federal award, but no less frequently than annually nor more frequently then quarterly except in unusual circumstances, for example where more frequent reporting if necessary, for the effective monitoring of the federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The reports submitted to the federal awarding agency should be accurate. Condition: During our testing over reporting requirements, we noted that the required annual performance report (APR) as prepared and submitted in accordance with the terms of the award did not reconcile to underlying accounting records. Questioned Costs: There are no questioned costs as the item outlined above is an internal control related matter related to compliance requirements not met in accordance with the grant agreement. Context: This is a condition identified during our testing over the reporting requirements. Cause: The Organization has documented monitoring policies and procedures; however, as identified above, the implementation of these policies and procedures did not detect or prevent the instance of noncompliance with the reporting criteria contained within the Uniform Guidance. Effect: While there are no known questioned costs that resulted from the condition identified above, the improper implementation of established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: In order to facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, we recommend management ensure all reporting requirements are documented, maintained and updated as necessary. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
2021-001 Internal Control over Compliance and Compliance with Reporting Contact: Robin Odland Title: President Phone Number: 202-457-1989 Estimated Completion Date: Second quarter 2022 Corrective Action: In June 2022, management incorporated two corrective actions: (i.) develop a spreadsheet that reconciles our accounting records with the APR records, to confirm that all APR records are properly entered, (ii.) have the APR reviewed by the Accounting Manager responsible for the maintenance of the Credit Enhancement Accounting Records.
FAC accepted this audit on May 17, 2021 — management decision was due November 17, 2021.
FAC accepted this audit on June 17, 2020 — management decision was due December 17, 2020.
During our testing over special tests and provisions, we identified the following condition: Per the grant agreement, at no point in time for the duration of the grant agreement shall there be commingling of reserve account funds from the grant with other funds that the Organization may have, even if the funds are used for similar purposes. Based on four (4) credit enhancements sampled and tested from a population of four (4) credit enhancements obligated between 1/1/2019 and 12/31/2019, there was commingling of federal reserve funds with private funds for one (1) of the four (4) samples tested. Both the federal and private funds were commingled into one reserve account. While the monitoring process did not appropriately detect or prevent, on a timely basis, the noncompliance with the special provisions of the grant agreement, the monitoring process did ensure that the grantee met the special provisions of the grant agreement after the end of the year. Questioned Costs: There are no questioned costs as the item outlined above is an internal control related matter related to compliance requirements not met in accordance with the grant agreement. Context: This is a condition identified per review of the Organization?s compliance with the special tests and provisions criteria of the Uniform Guidance using a statistically valid sample. The prevalence of these findings is detailed in the condition section above. Cause: The Organization has documented monitoring policies and procedures; however, as identified above, the implementation of these policies and procedures did not detect or prevent the instance of noncompliance with the special tests and provisions criteria contained within the Uniform Guidance. Effect: While there are no known questioned costs that resulted from the condition identified above, the improper implementation of established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to for the major federal program. Repeat Finding: This finding is not a repeat of finding. Recommendation: We recommend that management regularly provide training to those involved with the grant to ensure that those monitoring the performance goals are knowledgeable of period of performance criteria and have knowledge of the grant operations to ensure that they detect any credit enhancements not in line with the performance goals in a timely manner. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴Information on Federal Program: U.S. Department of Education Name of Program: Credit Enhancement for Charter School Facilities CFDA Number: 84.354 Grant Award Number: None Grant Award Period: February 4, 2003 until the Federal funds and earnings on those funds have been expended for the grant purposes or until financing facilitated by the grant has been retired, whichever is later. Criteria or Specific Requirement: In accordance with ?200.303(a), Internal Controls, a non-federal entity must 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. ?200.328, Monitoring and Reporting Program Performance, documents that the non-federal entity is responsible for oversight of the operations of the federal award supported activities. The non-federal entity must monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. Monitoring by the non-federal entity must cover each program, function or activity. The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be not less frequent than annually, nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the federal award or could significantly affect program outcomes. Condition: During our testing over special tests and provisions, we identified the following condition: Per the grant agreement, at no point in time for the duration of the grant agreement shall there be commingling of reserve account funds from the grant with other funds that the Organization may have, even if the funds are used for similar purposes. Based on four (4) credit enhancements sampled and tested from a population of four (4) credit enhancements obligated between 1/1/2019 and 12/31/2019, there was commingling of federal reserve funds with private funds for one (1) of the four (4) samples tested. Both the federal and private funds were commingled into one reserve account. While the monitoring process did not appropriately detect or prevent, on a timely basis, the noncompliance with the special provisions of the grant agreement, the monitoring process did ensure that the grantee met the special provisions of the grant agreement after the end of the year. Questioned Costs: There are no questioned costs as the item outlined above is an internal control related matter related to compliance requirements not met in accordance with the grant agreement. Context: This is a condition identified per review of the Organization?s compliance with the special tests and provisions criteria of the Uniform Guidance using a statistically valid sample. The prevalence of these findings is detailed in the condition section above. Cause: The Organization has documented monitoring policies and procedures; however, as identified above, the implementation of these policies and procedures did not detect or prevent the instance of noncompliance with the special tests and provisions criteria contained within the Uniform Guidance. Effect: While there are no known questioned costs that resulted from the condition identified above, the improper implementation of established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to for the major federal program. Repeat Finding: This finding is not a repeat of finding. Recommendation: We recommend that management regularly provide training to those involved with the grant to ensure that those monitoring the performance goals are knowledgeable of period of performance criteria and have knowledge of the grant operations to ensure that they detect any credit enhancements not in line with the performance goals in a timely manner. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Contact: Robin Odland Title: President Phone Number: 202-457-1989 Estimated completion date: Second quarter 2020 Corrective Action: Management takes the provisions of the grant agreement very serious and has procedures in place to address the commingling of federal funds with private funds issue. The current condition regarding the commingling of funds was unintentional and was a result of a lapse in communication. These funds were distributed to an escrow agent and we failed to communicate management?s intentions to separate the federal and private funds. As soon as management became aware of the situation, we began taking steps to correct this by reaching out to the escrow agent. Management uses general ledger accounts to separate federal and private funds. On an ongoing basis, we will review those accounts to ensure funds are not being commingled. In addition, starting in March 2020, we incorporated monthly discussions to support our efforts. We believe this approach will reduce the likelihood of this happening in the future.
During our testing over reporting requirements, we noted that required the annual performance report had not yet been prepared timely and submitted in accordance with the terms of the award. Questioned Costs: There are no questioned costs as the item outlined above is an internal control related matter related to compliance requirements not met in accordance with the grant agreement. Context: This is a condition identified during our testing over the reporting requirements. Cause: The Organization has documented monitoring policies and procedures; however, as identified above, the implementation of these policies and procedures was not completed and did not detect or prevent the instance of noncompliance with the reporting criteria contained within the Uniform Guidance. Effect: While there are no known questioned costs that resulted from the condition identified above, the improper implementation of established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This finding is not a repeat of finding. Recommendation: In order to facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, we recommend management ensure all reporting requirements are documented, maintained and updated as necessary. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Show full finding ▾Hide full finding ▴Information on Federal Program: U.S. Department of Education Name of Program: Credit Enhancement for Charter School Facilities CFDA Number: 84.354 Grant Award Number: None Grant Award Period: February 4, 2003 until the Federal funds and earnings on those funds have been expended for the grant purposes or until financing facilitated by the grant has been retired, whichever is later. Criteria or Specific Requirement: In accordance with ?200.303(a), Internal Controls, a non-federal entity must 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. A federal awarding agency may solicit only the standard, Office of Management and Budget (OMB) approved government-wide data elements for collection of financial information unless otherwise approved by the OMB in accordance with ?200.337, Financial Reporting. The information collected under this requirement must be collected with the frequency required by the terms and conditions of the federal award, but no less frequently than annually nor more frequently then quarterly except in unusual circumstances, for example where more frequent reporting if necessary for the effective monitoring of the federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The reports submitted to the federal awarding agency should be accurate. ?200.328, Monitoring and Reporting Program Performance, documents that the non-federal entity is responsible for oversight of the operations of the federal award supported activities. The non-federal entity must monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. Monitoring by the non-federal entity must cover each program, function or activity. The non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the federal award or could significantly affect program outcomes. Condition: During our testing over reporting requirements, we noted that required the annual performance report had not yet been prepared timely and submitted in accordance with the terms of the award. Questioned Costs: There are no questioned costs as the item outlined above is an internal control related matter related to compliance requirements not met in accordance with the grant agreement. Context: This is a condition identified during our testing over the reporting requirements. Cause: The Organization has documented monitoring policies and procedures; however, as identified above, the implementation of these policies and procedures was not completed and did not detect or prevent the instance of noncompliance with the reporting criteria contained within the Uniform Guidance. Effect: While there are no known questioned costs that resulted from the condition identified above, the improper implementation of established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This finding is not a repeat of finding. Recommendation: In order to facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, we recommend management ensure all reporting requirements are documented, maintained and updated as necessary. Views of Responsible Officials: Management agrees with the finding. See management?s corrective action plan.
Contact: Robin Odland Title: President Phone Number: 202-457-1989 Estimated completion date: Second quarter 2020 Corrective Action: To take corrective action, management has assigned responsibility for the monitoring and reporting associated with its credit enhancement program to the newly hired Chief Credit Officer, who will establish policies and procedures for underwriting staff to ensure that our credit enhancement portfolio is adequately monitored and that we file applicable reports with the Department of Education on a timely basis.
FAC accepted this audit on April 30, 2019 — management decision was due October 30, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on May 9, 2018 — management decision was due November 9, 2018.
FAC accepted this audit on May 8, 2017 — management decision was due November 8, 2017.
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