EIN: 201991334
UEI: KAEPADMRKHD3
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 2, 2022. 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 May 2, 2023 (1209 days ago).
What is a management decision? →Request for reimbursement under Federal Awards was made prior to cost being paid or incurred. Cause: The Organization did not have controls in place to ensure costs were paid or incurred prior to draw down under Federal Awards. As a result, a federal draw down was submitted twice in error. Effect: The Organization received federal funds before costs were paid or incurred. Context: Requests for reimbursement under Federal Awards are submitted through the Federal Payment Management System one to two times per month after costs have been paid or incurred. One reimbursement request was submitted twice in error. The error was detected and corrected within the grant year. Questioned costs: None Repeat Finding: This is a repeat finding. See finding 2021-01. Recommendation: We recommend the Organization improve its policies and procedures for reviewing reimbursement requests. Views of responsible officials of the auditee: Management concurs with the finding. The error occurred in second month of fiscal year before enhanced internal controls were implemented following the finding from the prior year?s audit. Controls implemented include a reconciliation process to ensure accuracy of reimbursement requests, improved record retention procedures, and documented standard operating procedures. Management considers this recommendation closed.
Show full finding ▾Hide full finding ▴2022-001 Assistance Listing Number and Title: 93.103 Food and Drug Administration_Research Research and Development Cluster Federal Agency: U.S. Department of Health and Human Services Federal Award Numbers: 5U18FD005320 Grant period: September 1, 2021 - August 31, 2022 Criteria: Cash management - Costs must be paid or incurred prior to request for reimbursement under federal awards. Condition: Request for reimbursement under Federal Awards was made prior to cost being paid or incurred. Cause: The Organization did not have controls in place to ensure costs were paid or incurred prior to draw down under Federal Awards. As a result, a federal draw down was submitted twice in error. Effect: The Organization received federal funds before costs were paid or incurred. Context: Requests for reimbursement under Federal Awards are submitted through the Federal Payment Management System one to two times per month after costs have been paid or incurred. One reimbursement request was submitted twice in error. The error was detected and corrected within the grant year. Questioned costs: None Repeat Finding: This is a repeat finding. See finding 2021-01. Recommendation: We recommend the Organization improve its policies and procedures for reviewing reimbursement requests. Views of responsible officials of the auditee: Management concurs with the finding. The error occurred in second month of fiscal year before enhanced internal controls were implemented following the finding from the prior year?s audit. Controls implemented include a reconciliation process to ensure accuracy of reimbursement requests, improved record retention procedures, and documented standard operating procedures. Management considers this recommendation closed.
Audit Period: Year ending June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS ? Major Federal Award Program Audit 2022-001 ? Cash Management Recommendation: We recommend the Organization improve its policies and procedures for reviewing reimbursement requests. Action Taken: Management concurs with the finding. The error occurred in second month of fiscal year before enhanced internal controls were implemented following the finding from the prior year?s audit. Controls implemented include a reconciliation process to ensure accuracy of reimbursement requests, improved record retention procedures, and documented standard operating procedures. Management considers this recommendation closed. If you have any questions regarding this plan, please contact Kevin B Perkins at (520) 647-8375. Sincerely, Kevin B Perkins, CFO Critical Path Institute
2021-001
FAC accepted this audit on November 8, 2021 — management decision was due May 8, 2022.
Request for reimbursement under Federal Awards was made prior to cost being incurred. Cause: Federal draw down was submitted twice in error. Effect: The Organization received federal funds before costs were incurred. Context: Requests for reimbursement under Federal Awards are submitted through the Federal Payment Management System one to two times per month after costs have been paid. One reimbursement request was submitted twice in error. Questioned costs: None Repeat Finding: No Recommendation: We recommend the Organization improve its policies and procedures for reviewing reimbursement requests. Views of responsible officials of the auditee: Existing internal controls caught the error in the following month and corrective action was immediately taken. In addition, new preventative controls concerning reimbursement requests were implemented to include a monthly three-way reconciliation, improved record retention procedures, and development of documented standard operating procedures.
Show full finding ▾Hide full finding ▴2021-001 Assistance Listing Number and Title: 93.103 Food and Drug Administration_Research Research and Development Cluster Federal Agency: U.S. Department of Health and Human Services Federal Award Numbers: 5U18FD005320 Grant period: September 1, 2020 - August 31, 2021 Criteria: Cash management - Costs must be paid or incurred prior to request for reimbursement under federal awards. Condition: Request for reimbursement under Federal Awards was made prior to cost being incurred. Cause: Federal draw down was submitted twice in error. Effect: The Organization received federal funds before costs were incurred. Context: Requests for reimbursement under Federal Awards are submitted through the Federal Payment Management System one to two times per month after costs have been paid. One reimbursement request was submitted twice in error. Questioned costs: None Repeat Finding: No Recommendation: We recommend the Organization improve its policies and procedures for reviewing reimbursement requests. Views of responsible officials of the auditee: Existing internal controls caught the error in the following month and corrective action was immediately taken. In addition, new preventative controls concerning reimbursement requests were implemented to include a monthly three-way reconciliation, improved record retention procedures, and development of documented standard operating procedures.
2021-001 ? Cash Management Recommendation: The Organization improve its policies and procedures for reviewing reimbursement requests. Action Taken: Existing internal controls caught the error in the following month and corrective action was immediately taken. In addition, new preventative controls concerning reimbursement requests were implemented to include: - A three-way reconciliation is now preformed monthly that ties G/L Expenses to the Payroll Allocation Spreadsheet to the FDA draws per the Payment Management Site from inception to date for each grant; by doing this, prior period adjustments and other reconciling items are easily and quicky identified and addressed (complete) - Record retention procedures were improved by saving the drawdown receipt/confirmation form in a file folder with a naming convention that corresponds to the pay period date to confirm that billing is done only for expenses incurred in the period being billed (complete) - Standard Operating Procedures were developed and are kept on file in written form and include provisions for reconciliation/balancing reports to be performed (complete) - C-Path contacted the FDA liaison and confirmed our responsibilities for reporting, drawdowns, and the approved method of handling over-billings should they occur; this information is kept on file and included in the revised Standard Operating Procedures (complete) The aforementioned corrective actions have been fully implemented and management considers this recommendation closed.
Unallowable salary was billed to federal award. Cause: Internal controls did not detect, on a timely basis, unallowable salary allocated to a federal award. Effect: Unallowable costs were billed to a federal award. Context: Unallowable salaries, fringe benefits, and related indirect costs of $39,064 were billed to a federal award. The error was detected and corrected within the grant year. Questioned costs: None Repeat Finding: No Recommendation: We recommend the Organization enhance its systems and procedures for review and approval of payroll allocations. Views of responsible officials of the auditee: Existing internal controls caught the salary misallocation within the grant year and corrective action was immediately taken. In addition, new preventative controls are being implemented to include: monthly reminders for managers to review and update payroll allocations; redundant and overlapping review and approval required by COO and CFO for each payroll allocation; staff training on procedures; and, additional end of month review procedures. Also, a new time and effort tracking system which will enhance reporting, approval and oversight functions will be deployed by early 2022.
Show full finding ▾Hide full finding ▴2021-002 Assistance Listing Number and Title: 93.103 Food and Drug Administration_Research Research and Development Cluster Federal Agency: U.S. Department of Health and Human Services Federal Award Numbers: 1U01FD006882 Grant period: September 1, 2019 - August 31, 2021 Criteria: Payroll disbursements - Costs must be allowable under federal awards. Condition: Unallowable salary was billed to federal award. Cause: Internal controls did not detect, on a timely basis, unallowable salary allocated to a federal award. Effect: Unallowable costs were billed to a federal award. Context: Unallowable salaries, fringe benefits, and related indirect costs of $39,064 were billed to a federal award. The error was detected and corrected within the grant year. Questioned costs: None Repeat Finding: No Recommendation: We recommend the Organization enhance its systems and procedures for review and approval of payroll allocations. Views of responsible officials of the auditee: Existing internal controls caught the salary misallocation within the grant year and corrective action was immediately taken. In addition, new preventative controls are being implemented to include: monthly reminders for managers to review and update payroll allocations; redundant and overlapping review and approval required by COO and CFO for each payroll allocation; staff training on procedures; and, additional end of month review procedures. Also, a new time and effort tracking system which will enhance reporting, approval and oversight functions will be deployed by early 2022.
2021-002 ? Payroll disbursements Recommendation: We recommend the Organization enhance its systems and procedures for review and approval of payroll allocations. Action Taken: Existing internal controls caught the salary misallocation within the grant year and corrective action was immediately taken. In addition, new preventative controls are being implemented to include: - Monthly reminders sent to payroll allocation managers to review and update payroll allocations (complete) - Redundant and overlapping review and approval required by COO and CFO for each payroll allocation file (complete) - Trainings for Program Managers and associated program staff on proper payroll allocation procedures and requirements (in progress) - Additional end of month review and feedback period for payroll allocation managers to review payroll charge report prior to month-end close (in progress) - Pending deployment of a new, cloud-based time and effort tracking system, Clockify, to replace the existing SharePoint based system; Clockify will allow only approved staff to allocate time to projects and will enhance reporting, approval, and oversight functionalities (in progress) The aforementioned in progress corrective actions will have full implementation by early 2022.
FAC accepted this audit on October 17, 2016 — management decision was due April 17, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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