EIN: 135602319
UEI: LJ4BYCD34UJ9
Audited by: Grant Thornton LLP
Oversight agency: 93 [Department of Health and Human Services]
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 13, 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 13, 2026 (77 days from today).
What is a management decision? →During the audit of the Organization for the fiscal year ending September 30, 2025, it was noted that the Organization did not timely file the FFATA subaward reports. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System by the end of the month following the month in which the subaward was obligated or the beginning of the fiscal year for continuing awards. Cause: Management became aware of this requirement midway through the fiscal year. At that point, management implemented a process to ensure the information was reported. As a result, while the information was reported accurately, it was not reported timely. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Questioned Costs: None to report. Identified as a Repeat Finding: This finding was reported as Finding 2024-005. Recommendation: We recommend that the Organization continue to monitor new and existing subrecipients to ensure compliance with FFATA reporting requirements. Views of Responsible Officials: Management concurs with the finding. The Organization acknowledges the oversight in not reporting subawards exceeding $30,000 in the FFATA Subaward Reporting System (FSRS), which was due to a lack of awareness regarding this specific requirement after hand-over transitions to new staff. To address this, the Organization has implemented formal procedures to ensure full compliance with all FFATA reporting. These include clearly defined responsibilities and training of relevant staff and internal reviews to ensure timely submission of required reports. The organization is committed to strengthening internal controls to ensure transparency, maintain compliance with federal grant regulations, and prevent recurrence of this issue. Responsible Person: Director, Ethics & Compliance.
Show full finding ▾Hide full finding ▴Finding 2025-001 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2024-2025 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2025, it was noted that the Organization did not timely file the FFATA subaward reports. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System by the end of the month following the month in which the subaward was obligated or the beginning of the fiscal year for continuing awards. Cause: Management became aware of this requirement midway through the fiscal year. At that point, management implemented a process to ensure the information was reported. As a result, while the information was reported accurately, it was not reported timely. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Questioned Costs: None to report. Identified as a Repeat Finding: This finding was reported as Finding 2024-005. Recommendation: We recommend that the Organization continue to monitor new and existing subrecipients to ensure compliance with FFATA reporting requirements. Views of Responsible Officials: Management concurs with the finding. The Organization acknowledges the oversight in not reporting subawards exceeding $30,000 in the FFATA Subaward Reporting System (FSRS), which was due to a lack of awareness regarding this specific requirement after hand-over transitions to new staff. To address this, the Organization has implemented formal procedures to ensure full compliance with all FFATA reporting. These include clearly defined responsibilities and training of relevant staff and internal reviews to ensure timely submission of required reports. The organization is committed to strengthening internal controls to ensure transparency, maintain compliance with federal grant regulations, and prevent recurrence of this issue. Responsible Person: Director, Ethics & Compliance.
Finding 2025-001: Reporting - Other Finding Required to be Reported under Uniform Guidance View of Responsible Officials and Planned Corrective Action: Management concurs with the finding. The Organization acknowledges the oversight in not reporting subawards exceeding $30,000 in the FFATA Subaward Reporting System (FSRS), which was due to a lack of awareness regarding this specific requirement after hand-over transitions to new staff. To address this, the Organization developed formal procedures to ensure full compliance with all FFATA reporting. These include clearly defined responsibilities and training relevant staff and internal reviews to verify ongoing compliance, to ensure timely submission of required reports. The organization is committed to strengthening internal controls to ensure transparency, maintain compliance with federal grant regulations, and prevent recurrence of this issue. Name of contact person: Name: Michael Woliver Title: Senior Director, Compliance & Operations Contact: MWoliver@cmmb.org Proposed Completion Date : September 30, 2025, and ongoing
2024-005
FAC accepted this audit on June 27, 2025 — management decision was due December 27, 2025.
During our testing, we selected 40 payroll and 40 non-payroll transactions for testing. In our testing over payroll transactions, we noted that there were two (2) transactions in which the Organization was unable to provide evidence of a review and approval of the transaction. In our testing over non-payroll transactions, we noted that there was one (1) transaction in which the Organization was unable to provide evidence of a review and approval of the transaction. Cause and Effect: The Organization is not able at access supporting documentation due to political and social conditions in the countries where the Organization operates. Questioned Costs: None to report. Identified as a Repeat Finding: No. Recommendation: The Organization should ensure that headquarters staff have access to all supporting documentation for expenses charged to federal grants.
Show full finding ▾Hide full finding ▴Finding 2024-004 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Allowable Costs – Internal Control (Significant Deficiency) Criteria: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The internal control system will include reviews of expenses charged to federal awards to verify that the expenses charged are both allowable costs and allowable activities. These reviews should be documented by an approval noted on the supporting documentation for the specific expenditure. Context: During our audit, we sampled both payroll and non-payroll transactions from the country offices of the Organization. We noted that the Organization was unable to provide sufficient documentation to demonstrate that it had performed the required ongoing review and approval of expenses charged to the grant. The absence of such documentation indicates that the Organization did not fully comply with the federal requirements for internal controls over allowable costs and allowable activities. Condition: During our testing, we selected 40 payroll and 40 non-payroll transactions for testing. In our testing over payroll transactions, we noted that there were two (2) transactions in which the Organization was unable to provide evidence of a review and approval of the transaction. In our testing over non-payroll transactions, we noted that there was one (1) transaction in which the Organization was unable to provide evidence of a review and approval of the transaction. Cause and Effect: The Organization is not able at access supporting documentation due to political and social conditions in the countries where the Organization operates. Questioned Costs: None to report. Identified as a Repeat Finding: No. Recommendation: The Organization should ensure that headquarters staff have access to all supporting documentation for expenses charged to federal grants.
Management acknowledges the importance of maintaining accessible and complete documentation to support all transactions charged to federal grants. The inability to provide the requested approvals for certain transactions was due to the challenging security conditions in some country offices during the audit period. To strengthen documentation access and retention, the Organization has transitioned to NetSuite, where backup documentation for transactions is now stored centrally on the cloud and can be easily accessed by headquarters staff. This change enhances our ability to ensure timely review, approval, and audit readiness, regardless of field conditions. We remain committed to continuous improvement of our internal controls and documentation practices. Responsible Person: Country Finance Directors
During the audit of the Organization for the fiscal year ending September 30, 2024, it was noted that the Organization did not comply with the FFATA subaward reporting requirements. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System (FSRS). Cause: The noncompliance was due to a lack of internal controls and procedures to ensure timely FFATA reporting. Staff responsible for grant reporting were unaware of the requirements. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Recommendation: We recommend that the Organization establish formal written policies and procedures to ensure compliance with FFATA reporting requirements. This should include training for responsible personnel, monitoring of subaward obligations, and a calendar or automated reminders to ensure timely reporting.
Show full finding ▾Hide full finding ▴Finding 2024-005 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2024, it was noted that the Organization did not comply with the FFATA subaward reporting requirements. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System (FSRS). Cause: The noncompliance was due to a lack of internal controls and procedures to ensure timely FFATA reporting. Staff responsible for grant reporting were unaware of the requirements. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Recommendation: We recommend that the Organization establish formal written policies and procedures to ensure compliance with FFATA reporting requirements. This should include training for responsible personnel, monitoring of subaward obligations, and a calendar or automated reminders to ensure timely reporting.
Management concurs with the finding. The Organization acknowledges the oversight in not reporting subawards exceeding $30,000 in the FFATA Subaward Reporting System (FSRS), which was due to a lack of awareness regarding this specific requirement after hand-over transitions to new staff. To address this, the Organization is developing formal procedures to ensure full compliance with all FFATA reporting. These will include clearly defined responsibilities and training relevant staff and internal reviews to verify ongoing compliance, to ensure timely submission of required reports. The organization is committed to strengthening internal controls to ensure transparency, maintain compliance with federal grant regulations, and prevent recurrence of this issue. Responsible Person: Director, Ethics & Compliance
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