EIN: 113275392
UEI: DHEAJB4M1F37
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 29, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 29, 2025 (516 days ago).
What is a management decision? →Criteria Non-federal entities other than states are required to follow the procurement standards set out at 2 CFR § 200.318 through § 200.326. They must use their own documented procurement procedures, which conform to applicable federal statutes and the procurement requirements identified in 2 CFR 200. Condition The Corporation’s written procurement standards do not comply with all of the procurement requirements set out at 2 CFR § 200.318 through § 200.326. Effect The Corporation is not in compliance with 2 CFR § 200.318 through § 200.326.
Show full finding ▾Hide full finding ▴Criteria Non-federal entities other than states are required to follow the procurement standards set out at 2 CFR § 200.318 through § 200.326. They must use their own documented procurement procedures, which conform to applicable federal statutes and the procurement requirements identified in 2 CFR 200. Condition The Corporation’s written procurement standards do not comply with all of the procurement requirements set out at 2 CFR § 200.318 through § 200.326. Effect The Corporation is not in compliance with 2 CFR § 200.318 through § 200.326.
Corrective Action Plan: The Corporation has reviewed the current procurement standards and has identified gaps in compliance with the federal requirements. To address this, the Corporation will adopt a Procurement Policy Addendum, based on the attached draft, which includes compliance measures for: ● Small and minority business engagement ● Domestic preferences for procurements ● Recovered materials procurement ● Cost analysis for contracts over the Simplified Acquisition Threshold ● Bonding requirements for construction contracts ● Contract provisions regarding Equal Employment Opportunity, Davis-Bacon Act, and other federal mandates The attached model policy will be presented to the Board for formal adoption and will be incorporated into the Corporation's procurement procedures to ensure full compliance with 2 CFR § 200.318-326. Responsible Individual: Joseph Ninomiya - Chief Executive Officer Planned Date of Implementation: October 23, 2024
Criteria Per 2 CFR § 200.303, non-Federal entities are required to establish and maintain effective internal control over federal awards 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. Condition Our internal control testing revealed one instance in which the voucher package for one cash disbursement in the amount of $530,096 did not include documented review and approval by management prior to issuance of payment to the vendor. Effect Without proper review and approval by management prior to issuance of payment to vendors, the Corporation cannot provide reasonable assurance that the federal award has been managed in compliance with all applicable Federal statutes, regulations, and the terms and conditions of the federal award.
Show full finding ▾Hide full finding ▴Criteria Per 2 CFR § 200.303, non-Federal entities are required to establish and maintain effective internal control over federal awards 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. Condition Our internal control testing revealed one instance in which the voucher package for one cash disbursement in the amount of $530,096 did not include documented review and approval by management prior to issuance of payment to the vendor. Effect Without proper review and approval by management prior to issuance of payment to vendors, the Corporation cannot provide reasonable assurance that the federal award has been managed in compliance with all applicable Federal statutes, regulations, and the terms and conditions of the federal award.
Corrective Action Plan: The Corporation will enhance internal control procedures to ensure that all cash disbursements are reviewed and approved by management before issuance. The procedure will involve: 1. Voucher Review Protocol: A checklist will be created to ensure that all disbursements are accompanied by documented approvals. This checklist will include verification of the approval by both management and legal counsel when necessary. 2. Management Approval: Disbursements, particularly those over $500,000, will require formal sign-off from the Chief Executive Officer and review by the Legal Department. 3. Training & Compliance: Staff will be trained on the updated process, and compliance will be regularly reviewed by the internal audit team. A report on adherence to these new procedures will be made available to the Board quarterly. 4. Verification of Prior Disbursement: Regarding the specific instance cited, management will review the process followed to verify that the review by Albanese and LDC counsel, as referenced in the email, was correctly documented. If this was indeed the case, a follow-up with the auditors will be initiated to clarify the discrepancy. Responsible Individual: Joseph Ninomiya - Chief Executive Officer Planned Date of Implementation: October 15, 2024
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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