AIDS Council of Northeastern New York, Inc. d/b/a Alliance for Positive Health

EIN: 222684595

UEI: M1RDRU4VA8X1

Data as of August 21, 2026

AIDS Council of Northeastern New York, Inc. d/b/a Alliance for Positive Health10 audit years7 findings2 repeat
10
Audit Years
7
Total Findings
2
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 27, 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 September 27, 2026 (36 days from today).

What is a management decision? →
2025-002
Cost Allowability
MATERIAL WEAKNESSREPEAT

2025-002: Allocation of Costs Other Than Payroll Criteria or specific requirement: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200.414, the Alliance must allocate indirect costs appropriately. Condition and context: The Alliance allocates certain shared costs, other than payroll, using an approach that details the full-time equivalents performing work on each grant. During the year ended June 30, 2025, costs were allocated using a schedule that did not agree to actual underlying payroll data. Cause: The NetSuite program, used to ensure that the proper allocations were used, was not reviewed for an error in the program that did not adequately account for the addition of new grants which slightly changed some allocations of space costs Effect or potential effect: Without adequate controls over this process, the Alliance could incorrectly charge costs to federal grants. Questioned costs: None. Identification as a repeat finding, if applicable: This is a repeat finding. Recommendation: The Alliance should ensure that internal control processes for the allocation of costs are consistently followed. A review process should be in place to ensure that accurate allocations are used. During the fiscal year ending June 30, 2025, the Alliance has implemented the use of the de minimis cost rate, which will alleviate the need to create an allocation approach for shared costs. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Show full finding ▾
Full finding narrative

2025-002: Allocation of Costs Other Than Payroll Criteria or specific requirement: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200.414, the Alliance must allocate indirect costs appropriately. Condition and context: The Alliance allocates certain shared costs, other than payroll, using an approach that details the full-time equivalents performing work on each grant. During the year ended June 30, 2025, costs were allocated using a schedule that did not agree to actual underlying payroll data. Cause: The NetSuite program, used to ensure that the proper allocations were used, was not reviewed for an error in the program that did not adequately account for the addition of new grants which slightly changed some allocations of space costs Effect or potential effect: Without adequate controls over this process, the Alliance could incorrectly charge costs to federal grants. Questioned costs: None. Identification as a repeat finding, if applicable: This is a repeat finding. Recommendation: The Alliance should ensure that internal control processes for the allocation of costs are consistently followed. A review process should be in place to ensure that accurate allocations are used. During the fiscal year ending June 30, 2025, the Alliance has implemented the use of the de minimis cost rate, which will alleviate the need to create an allocation approach for shared costs. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Corrective Action Plan

Starting in May 2024, the Alliance adapted its monthly Time and Effort Report that is reviewed by Kim Atkins, Executive Director, to be used for allocation of expenses other than payroll. This ensures a consistent, reviewed and authorized report is being used for expense allocation. This report is shared monthly with the Alliance’s funding agencies along with the submission of monthly vouchers for processing. During the year ended June 30, 2025, the Alliance has ensured that allocations were signed off on by Kim and has significantly reduced the amount of finance staff time required to process the allocation of administrative costs. The data from this monthly report is entered into NetSuite for allocation of administrative costs but subsequent review of the allocation program in NetSuite determined that the proper adjustment for adding new grants had not been built into the program. The Accounting Manager, Sarah Burgess, is currently working with NetSuite to fix this problem going forward. As of July 1, 2025 the Alliance is modifying all of its grants to adopt the 15% de minimis cost rate for all expenses other than personnel, direct program, and space costs.

Prior Finding References

2024-002

About Allowable Costs / Cost Principles →
2025-003
Other
REPEAT

2025-003: Accurate and Complete Schedule of Expenditures of Federal Awards (SEFA) Criteria or specific requirement: The Alliance must prepare a SEFA that is accurate and complete in accordance with 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Condition and context: The Alliance did not prepare a SEFA that was accurate and complete in accordance with the Uniform Guidance, as the unadjusted totals for federal expenditures were not accurate and did not agree to underlying support. In addition, an immaterial amount of allowable expenses were included on the 2025 SEFA, that should have been included on the 2024 SEFA. Cause: The cause is due to limited internal controls related to the preparation and review of the SEFA. Effect or potential effect: Without adequate controls over this process, the Alliance may not identify all federal awards received and related compliance and reporting requirements applicable to each award. Questioned costs: None. Identification as a repeat finding, if applicable: This is a repeat finding. Recommendation: The Alliance must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all federal grants received to ensure that the Alliance has met the applicable compliance and reporting requirements of each federal award. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter. 2025-004: Subrecipient Monitoring Identification of the federal program: Continuum of Care Program (AL # 14.267) Criteria or specific requirement: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200.332, the Alliance must perform specific monitoring over subrecipients. The Alliance as the pass-through entity (PTE) is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved.

Show full finding ▾
Full finding narrative

2025-003: Accurate and Complete Schedule of Expenditures of Federal Awards (SEFA) Criteria or specific requirement: The Alliance must prepare a SEFA that is accurate and complete in accordance with 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Condition and context: The Alliance did not prepare a SEFA that was accurate and complete in accordance with the Uniform Guidance, as the unadjusted totals for federal expenditures were not accurate and did not agree to underlying support. In addition, an immaterial amount of allowable expenses were included on the 2025 SEFA, that should have been included on the 2024 SEFA. Cause: The cause is due to limited internal controls related to the preparation and review of the SEFA. Effect or potential effect: Without adequate controls over this process, the Alliance may not identify all federal awards received and related compliance and reporting requirements applicable to each award. Questioned costs: None. Identification as a repeat finding, if applicable: This is a repeat finding. Recommendation: The Alliance must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all federal grants received to ensure that the Alliance has met the applicable compliance and reporting requirements of each federal award. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter. 2025-004: Subrecipient Monitoring Identification of the federal program: Continuum of Care Program (AL # 14.267) Criteria or specific requirement: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200.332, the Alliance must perform specific monitoring over subrecipients. The Alliance as the pass-through entity (PTE) is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved.

Corrective Action Plan

The NetSuite implementation and optimization, overseen by Joan Hayner, Interim Finance and Operation Lead, has been in process throughout 2025, which has allowed for the streamlining of many processes. As of July 2025, the schedule of federal expenditures was automatically produced in NetSuite using expenditure data within the accounting system, rather than being prepared manually. In order to ensure that the SEFA is being produced accurately and completely, the Accounting Manager, who joined the Alliance in April 2025, will become thoroughly familiar with the reporting requirements for the Alliance’s federal awards and work with NetSuite to ensure the data is accurately reflected in the system. As of March 2026, the Alliance is caught up on payments to vendors and their system now has information about the date a program service or item was for and the Alliance is better able to identify what period an expense belongs to.

Prior Finding References

2024-003

About Other →
2025-004
Subrecipient Monitoring
MATERIAL WEAKNESS

2025-004: Subrecipient Monitoring (Continued) Condition and context: In relation to Continuum of Care Program (AL # 14.267), the Alliance did not complete the required monitoring responsibilities, specifically: 1. Ensuring that every subaward is clearly identified to the subrecipient as a subaward, which is required to include Federal award identification, requirements of the subaward, any additional requirements imposed, indirect cost rate detail, a requirement that subrecipient permit the pass-through entity and auditors to access the subrecipient’s records and financial statements for the pass-through entity to fulfill its monitoring requirements and appropriate terms and conditions concerning the closeout of the subaward. There were no subaward contracts for the period October 1, 2023 to September 30, 2024. Subaward contracts for the period October 1, 2024 to September 30, 2025 did not include all required items. 2. Monitoring the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward including: Reviewing financial and performance reports, ensuring that the subrecipient takes corrective action on all significant developments that negatively affect the subaward, issuing a management decision for audit findings pertaining only to the Federal award, and resolving audit findings specifically related to the subaward. The subrecipient received a significant deficiency and compliance finding in their June 30, 2024 single audit noting that there was no rent calculation worksheet present for one of the individuals tested to indicate income in order to ensure program income portions are being appropriately calculated. The Alliance did not obtain the single audit report, nor resolve the finding specifically related to the subaward. As such, there were limited indications that the Alliance monitored the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. 3. Verifying that a subrecipient is audited as required by CFR, which the Alliance did not verify. Cause: The cause is due to limited internal controls related to subrecipient monitoring Effect or potential effect: Without adequate controls over this process, the subrecipient may not be complying with Federal statutes, regulations, and the terms and conditions of the subaward. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable Recommendation: The Alliance must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all subawards to ensure that the Alliance has met the applicable compliance and reporting requirements of each federal award. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Show full finding ▾
Full finding narrative

2025-004: Subrecipient Monitoring (Continued) Condition and context: In relation to Continuum of Care Program (AL # 14.267), the Alliance did not complete the required monitoring responsibilities, specifically: 1. Ensuring that every subaward is clearly identified to the subrecipient as a subaward, which is required to include Federal award identification, requirements of the subaward, any additional requirements imposed, indirect cost rate detail, a requirement that subrecipient permit the pass-through entity and auditors to access the subrecipient’s records and financial statements for the pass-through entity to fulfill its monitoring requirements and appropriate terms and conditions concerning the closeout of the subaward. There were no subaward contracts for the period October 1, 2023 to September 30, 2024. Subaward contracts for the period October 1, 2024 to September 30, 2025 did not include all required items. 2. Monitoring the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward including: Reviewing financial and performance reports, ensuring that the subrecipient takes corrective action on all significant developments that negatively affect the subaward, issuing a management decision for audit findings pertaining only to the Federal award, and resolving audit findings specifically related to the subaward. The subrecipient received a significant deficiency and compliance finding in their June 30, 2024 single audit noting that there was no rent calculation worksheet present for one of the individuals tested to indicate income in order to ensure program income portions are being appropriately calculated. The Alliance did not obtain the single audit report, nor resolve the finding specifically related to the subaward. As such, there were limited indications that the Alliance monitored the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. 3. Verifying that a subrecipient is audited as required by CFR, which the Alliance did not verify. Cause: The cause is due to limited internal controls related to subrecipient monitoring Effect or potential effect: Without adequate controls over this process, the subrecipient may not be complying with Federal statutes, regulations, and the terms and conditions of the subaward. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable Recommendation: The Alliance must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all subawards to ensure that the Alliance has met the applicable compliance and reporting requirements of each federal award. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Corrective Action Plan

As of September 2025, the Continuum of Care program was placed under the responsibility of the Director of Program Services, Quinn Lee, who has extensive experience managing housing programs in her previous employment, including federal programs. She is currently working to respond to the audit findings and rebuild the appropriate agreements and documentation with sub-awardees to meet the requirements. It must be noted that HUD has entered into legal action to make significant changes to this program which may affect how the Alliance is required to respond in the future.

About Subrecipient Monitoring →
2025-005
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESS

2025-005: Matching Requirement Identification of the federal program: Continuum of Care Program (AL # 14.267) Criteria or specific requirement: In accordance with the Continuum of Care Program (AL # 14.267) grant agreement, the recipient or the subrecipient must match all grant funds, except for leasing funds, with not less than 25% of cash or in-kind contributions from other sources. Condition and context: The Alliance did not receive documentation that the subrecipient matched the required grant funds. Additionally, documentation for the Alliance’s match did not adequately indicate that such funds were related the Continuum of Care Program (AL # 14.267) grant. Cause: The cause is due to limited internal controls related to the requirements of the match. Effect or potential effect: Verification that the match has been met is not possible with the supporting documentation. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable Recommendation: The Alliance must assign individuals who are experienced and knowledgeable in compliance requirements of the Uniform Guidance to ensure that adequate documentation is received related the matching requirement. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Show full finding ▾
Full finding narrative

2025-005: Matching Requirement Identification of the federal program: Continuum of Care Program (AL # 14.267) Criteria or specific requirement: In accordance with the Continuum of Care Program (AL # 14.267) grant agreement, the recipient or the subrecipient must match all grant funds, except for leasing funds, with not less than 25% of cash or in-kind contributions from other sources. Condition and context: The Alliance did not receive documentation that the subrecipient matched the required grant funds. Additionally, documentation for the Alliance’s match did not adequately indicate that such funds were related the Continuum of Care Program (AL # 14.267) grant. Cause: The cause is due to limited internal controls related to the requirements of the match. Effect or potential effect: Verification that the match has been met is not possible with the supporting documentation. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable Recommendation: The Alliance must assign individuals who are experienced and knowledgeable in compliance requirements of the Uniform Guidance to ensure that adequate documentation is received related the matching requirement. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Corrective Action Plan

As of November 2025, the Alliance has hired an Accountant, Anna Panyuta, with extensive experience in handling the cost documentation requirements for housing programs. She is currently working with the Director of Program Services to ensure all agency housing programs are meeting documentation requirements and will be transitioning in April 2026 to assuming responsibilities for the Continuum of Care program from Emma Sobocinski. This will include a complete review of the match program, how to work with the sub-awardees and ensuring proper documentation of the match. Again, it must be noted that there are potential changes to this program pending legal action taken by HUD.

About Matching, Level of Effort, Earmarking →

FY 2024-06-30

FAC accepted this audit on August 19, 2025 — management decision was due February 19, 2026.

2024-002
Cost Allowability
MATERIAL WEAKNESS

2024-002: Allocation of Costs Other Than Payroll Criteria or specific requirement: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200.414, the Alliance must allocate indirect costs appropriately. Condition and context: The Alliance allocates certain shared costs, other than payroll, using an approach that details the full-time equivalents performing work on each grant. During the year ended June 30, 2024, costs were allocation using a schedule that did not agree to actual underlying payroll data. Additionally, the schedule that was used was not reviewed by the Executive Director. Cause: The Alliance does not have adequate staffing in place to ensure that the proper allocations were used. Effect or potential effect: Without adequate controls over this process, the Alliance could charge unallowable costs to the HIV Formula Grants. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable. Recommendation: The Alliance should ensure that internal control processes for the allocation of cost are consistently followed. A review process should be in place to ensure that accurate allocations are used. The Alliance could also consider the use of the de minimis cost rate, which would alleviate the need to create an allocation approach for shared costs. Effective October 1, 2024, the de minimis cost rate increased to 15%. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Show full finding ▾
Full finding narrative

2024-002: Allocation of Costs Other Than Payroll Criteria or specific requirement: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200.414, the Alliance must allocate indirect costs appropriately. Condition and context: The Alliance allocates certain shared costs, other than payroll, using an approach that details the full-time equivalents performing work on each grant. During the year ended June 30, 2024, costs were allocation using a schedule that did not agree to actual underlying payroll data. Additionally, the schedule that was used was not reviewed by the Executive Director. Cause: The Alliance does not have adequate staffing in place to ensure that the proper allocations were used. Effect or potential effect: Without adequate controls over this process, the Alliance could charge unallowable costs to the HIV Formula Grants. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable. Recommendation: The Alliance should ensure that internal control processes for the allocation of cost are consistently followed. A review process should be in place to ensure that accurate allocations are used. The Alliance could also consider the use of the de minimis cost rate, which would alleviate the need to create an allocation approach for shared costs. Effective October 1, 2024, the de minimis cost rate increased to 15%. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Corrective Action Plan

Starting in May 2024, the Alliance adapted its monthly Time and Effort Report that is reviewed by Kim Atkins, Executive Director, to be used for allocation of expenses other than payroll. This ensures a consistent, reviewed and authorized report is being used for expense allocation. This report is shared monthly with the Alliance’s funding agencies along with the submission of monthly vouchers for processing. During the year ended June 30, 2025, the Alliance has ensured that allocations were signed off on by Kim and has significantly reduced the amount of finance staff time required to process the allocation of administrative costs. As of July 1, 2025, the approved staff allocations are being uploaded into ADP in the anticipation of a direct link between ADP and the NetSuite general ledger so that personnel costs will be allocated automatically going forward. As of July 1, 2025 the Alliance is modifying all of its grants to adopt the 15% de minimis cost rate for all expenses other than personnel, direct program, and space costs.

About Allowable Costs / Cost Principles →
2024-003
Other

2024-003: Accurate and Complete Schedule of Expenditures of Federal Awards (SEFA) Criteria or specific requirement: The Alliance must prepare a SEFA that is accurate and complete in accordance with 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Condition and context: The Alliance did not prepare a SEFA that was accurate and complete in accordance with the Uniform Guidance, as the unadjusted totals for federal expenditures were not accurate and did not agree to underlying support. Cause: The cause is due to limited internal controls related to the preparation and review of the SEFA. Effect or potential effect: Without adequate controls over this process, the Alliance may not identify all federal awards received and related compliance and reporting requirements applicable to each award. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable. Recommendation: The Alliance must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all federal grants received to ensure that the Alliance has met the applicable compliance and reporting requirements of each federal award. Views of responsible

Show full finding ▾
Full finding narrative

2024-003: Accurate and Complete Schedule of Expenditures of Federal Awards (SEFA) Criteria or specific requirement: The Alliance must prepare a SEFA that is accurate and complete in accordance with 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Condition and context: The Alliance did not prepare a SEFA that was accurate and complete in accordance with the Uniform Guidance, as the unadjusted totals for federal expenditures were not accurate and did not agree to underlying support. Cause: The cause is due to limited internal controls related to the preparation and review of the SEFA. Effect or potential effect: Without adequate controls over this process, the Alliance may not identify all federal awards received and related compliance and reporting requirements applicable to each award. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable. Recommendation: The Alliance must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all federal grants received to ensure that the Alliance has met the applicable compliance and reporting requirements of each federal award. Views of responsible

Corrective Action Plan

The NetSuite implementation and optimization, overseen by Joan Hayner, Interim Finance and Operation Lead, has been in process throughout 2025, which has allowed for the streamlining of many processes. As of July 2025, the schedule of federal expenditures was automatically produced in NetSuite using expenditure data within the accounting system, rather than being prepared manually.

About Other →
2024-004
Reporting

2024-004: Single Audit Report Submission Criteria or specific requirement: In accordance with 2 CFR 200.512, the Alliance was required to complete and submit the data collection form within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition and context: The Alliance did not submit the single audit within the required period for submission. Cause: The Alliance did not have sufficient staffing to complete the audit. Effect or potential effect: The Alliance did not comply with the requirements of 2 CFR 200.512. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable. Recommendation: Staffing should be sufficient to ensure that all external reports are prepared and submitted on a timely basis. Staffing should contemplate not only the preparation of the various reports but also a formal, documented review process. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Show full finding ▾
Full finding narrative

2024-004: Single Audit Report Submission Criteria or specific requirement: In accordance with 2 CFR 200.512, the Alliance was required to complete and submit the data collection form within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition and context: The Alliance did not submit the single audit within the required period for submission. Cause: The Alliance did not have sufficient staffing to complete the audit. Effect or potential effect: The Alliance did not comply with the requirements of 2 CFR 200.512. Questioned costs: None. Identification as a repeat finding, if applicable: Not applicable. Recommendation: Staffing should be sufficient to ensure that all external reports are prepared and submitted on a timely basis. Staffing should contemplate not only the preparation of the various reports but also a formal, documented review process. Views of responsible officials: Refer to the Corrective Action Plan prepared by the Alliance in regard to this matter.

Corrective Action Plan

During the year ended June 30, 2025, the finance department has been restructured to add a new Interim Finance and Operation Lead, Joan Regan Hayner, Accounting Manager, Sarah Burgess, and Staff Accountant, Diamond Payne. With the overhaul in staffing, implementation of a monthly close schedule, and efficiencies gained from automating and optimizing processes with the NetSuite system, the Alliance expects to complete the June 30, 2025 financial statement and single audits during the Fall of 2025 to be able to timely file the single audit before the filing deadline of March 31, 2026.

About Reporting →

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.

Are you this organization?

Track your findings and corrective action plans across audit cycles.

Start tracking findings →

Do you fund this organization?

Monitor subrecipient audit findings and compliance status.

Start monitoring →

Product

Resources

Legal

Single Audit Intelligence is an independent tool powered by Federal Audit Clearinghouse data. Not affiliated with GSA, OMB, or any federal agency.

© 2026 Single Audit Intelligence. All data is public domain.