EIN: 231706895
UEI: DK5MMAQ7DMM6
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2026 (39 days from today).
What is a management decision? →As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless), and lease or housing agreement (depending on program requirements). Of 40 resident client files reviewed, management could not provide proof of income or residency status for 16 clients, nor signed lease agreements or policies and procedures manuals for 22 clients. Questioned Costs: None identified. Context: The HOME program has income targeting requirements where only low-income or very low-income individuals, as defined in 24 CFR section 92.2, are eligible for housing assistance. Consequently, organizations receiving or using HOME funds must verify the annual income of each household, considering all members. These organizations must maintain records for every family assisted. HOMEassisted units in rental housing projects must be occupied only by households that qualify as low income families and must adhere to specific rent limits. According to 24 CFR Section 92.209(c), participating organizations must select families based on low-income or homeless criteria. Cause: The Organization’s residential program, Philly House, which operated from the Venango location, provided low-intensity residential services for adult men with substance use and co-occurring disorders. This program was relocated to another site within the Organization’s network as it better complied with the requirements specified in the Project HOME Loans due to its nature. In contrast, the Re-Entry House, a halfway house for adult men with substance use and co-occurring disorders offering stable residential housing services, represented a different type of residential program. During the transition, management, at the location, did not prepare policies and procedures to determine income eligibility as outlined in the Project Home Loan agreement and 24 CFR section 92.2. Consequently, no documentation was prepared or provided to the auditors to demonstrate compliance with the eligibility and Project HOME Loan requirements. Effect: Controls over the documentation of income eligibility requirements are not in place to determine if clients receiving residential services at the Venango location meet the criteria for being low income or homeless, as specified by Project HOME loan requirements. Non-compliance with these eligibility requirements could result in the return of funding as described in the Project HOME loan agreements. Repeat Finding: Yes Recommendation: We recommend that management adopt and implement formal policies and procedures to ensure compliance with HOME eligibility requirements. Such policies and procedures should include clear communication of compliance requirements between staff and locations, standardized documentation and processes for determining and verifying income eligibility during intake, and procedures for the redetermination of income eligibility for residential clients residing at a location for more than one year. View of Responsible Officials and Planned Corrective Action: Please refer to Gaudenzia, Inc. and Gaudenzia Foundation, Inc.’s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of Schuylkill - Home Investment Partnerships and Housing Trust Funds Programs: Fountain Springs – Loan Mayor and City of Baltimore: Baltimore Housing - Park Heights Women and Children – Loan Type of Finding: Material Weakness in Internal Control over Compliance Other Matters Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award require compliance with the provision of eligibility. The Organization should have procedures and controls in place to ensure that the Organization leases the property to low-income homeless persons and complies with the terms and conditions dictated in the HOME loan agreement. Proper documentation should be maintained demonstrating evidence that residents living at the property meet the HOME loan criteria. Condition: As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless), and lease or housing agreement (depending on program requirements). Of 40 resident client files reviewed, management could not provide proof of income or residency status for 16 clients, nor signed lease agreements or policies and procedures manuals for 22 clients. Questioned Costs: None identified. Context: The HOME program has income targeting requirements where only low-income or very low-income individuals, as defined in 24 CFR section 92.2, are eligible for housing assistance. Consequently, organizations receiving or using HOME funds must verify the annual income of each household, considering all members. These organizations must maintain records for every family assisted. HOMEassisted units in rental housing projects must be occupied only by households that qualify as low income families and must adhere to specific rent limits. According to 24 CFR Section 92.209(c), participating organizations must select families based on low-income or homeless criteria. Cause: The Organization’s residential program, Philly House, which operated from the Venango location, provided low-intensity residential services for adult men with substance use and co-occurring disorders. This program was relocated to another site within the Organization’s network as it better complied with the requirements specified in the Project HOME Loans due to its nature. In contrast, the Re-Entry House, a halfway house for adult men with substance use and co-occurring disorders offering stable residential housing services, represented a different type of residential program. During the transition, management, at the location, did not prepare policies and procedures to determine income eligibility as outlined in the Project Home Loan agreement and 24 CFR section 92.2. Consequently, no documentation was prepared or provided to the auditors to demonstrate compliance with the eligibility and Project HOME Loan requirements. Effect: Controls over the documentation of income eligibility requirements are not in place to determine if clients receiving residential services at the Venango location meet the criteria for being low income or homeless, as specified by Project HOME loan requirements. Non-compliance with these eligibility requirements could result in the return of funding as described in the Project HOME loan agreements. Repeat Finding: Yes Recommendation: We recommend that management adopt and implement formal policies and procedures to ensure compliance with HOME eligibility requirements. Such policies and procedures should include clear communication of compliance requirements between staff and locations, standardized documentation and processes for determining and verifying income eligibility during intake, and procedures for the redetermination of income eligibility for residential clients residing at a location for more than one year. View of Responsible Officials and Planned Corrective Action: Please refer to Gaudenzia, Inc. and Gaudenzia Foundation, Inc.’s Corrective Action Plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of Schuylkill - Home Investment Partnerships and Housing Trust Funds Programs: Fountain Springs - Loan Mayor and City of Baltimore: Baltimore Housing - Park Heights Women and Children - Loan Type of Finding: - Material Weakness in Internal Control over Compliance - Other Matters Condition: As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless). Of 40 resident client files reviewed, management could not provide proof of income or residency status for 16 clients, or policies and procedures manuals for 22 clients. Recommendation: We recommend that management adopt and implement formal policies and procedures to ensure compliance with HOME eligibility requirements. Such policies and procedures should include clear communication of compliance requirements between staff and locations, standardized documentation and processes for determining and verifying income eligibility during intake, and procedures for the redetermination of income eligibility for residential clients residing at a location for more than one year. Repeat Finding: 2024-001 Explanation of Disagreement with Audit Finding Management acknowledges the finding and continues to strengthen internal controls related to HOME program compliance, including eligibility documentation and file retention practices across all residential program locations. Management agrees that consistent documentation of eligibility, including proof of income and residency status (as applicable under HOME requirements), is critical. We are currently reviewing and enhancing intake procedures, documentation standards, and internal monitoring processes to ensure all required eligibility documentation is properly obtained, maintained, and uniformly applied across all locations. Action taken in response to finding: In response to the recommendation, management will develop and implement formalized policies and procedures to strengthen compliance with HOME requirements. These will include standardized guidance for eligibility determination at intake, clear documentation requirements across all sites, and procedures for ongoing eligibility review for clients residing in programs beyond one year. Name of the contact person responsible for corrective action: Dr. Deja Gilbert, PhD, MDA, FACHE, LPC, LMHC, President and CEO dgilbert@gaudenzia.org Planned completion date for corrective action plan: June 30, 2026
2024-001
As part of our audit procedures over the Organization’s procurement policy and the small purchase requirements under 2 CFR 200.320(a)(2), we sampled a total of five vendors who incurred costs exceeding $10,000 for each of the two major programs. For two of the five vendors selected, management was unable to provide written documentation demonstrating that price or rate quotations were obtained from an adequate number of qualified sources (generally 2-3 quotes) for purchases above the micro-purchase threshold ($10,000) and below the Simplified Acquisition Threshold ($250,000). This documentation should have included the names of suppliers contacted, prices quoted, and the justification for vendor selection. Questioned Costs: None identified. Context: The Organization is responsible for administering federal funds under the Continuum of Care (CoC) Certified Community Behavioral Health Clinic programs and must adhere to the procurement standards outlined in 2 CFR Part 200. As part of the single audit process, procurement transactions were reviewed to verify that the organization implemented appropriate procurement methods based on total vendor expenditures and maintained all required supporting documentation for purchases exceeding the micro-purchase threshold. Cause: Management’s procedures did not consistently ensure that the required procurement documentation was obtained and retained, and there were limited controls in place to monitor vendor expenditures in the aggregate to help determine the appropriate procurement method. Effect: Controls over the procurement process are not in place to determine that all procurement transactions are conducted in a manner providing full and open competition, in accordance with 2 CFR 200.319. Repeat Finding: N/A: Not a repeat finding Recommendation: We recommend management update its policies and procedures over procurement to ensure compliance with 2 CFR Part 200. This includes requiring and retaining documentation supporting the use of small purchase procedures, obtaining price or rate quotations from an adequate number of qualified sources, and monitoring vendor expenditures on an aggregate basis to ensure the appropriate procurement method is applied. Management should also provide training for staff responsible for procurement activities to promote consistent compliance with federal requirements. View of Responsible Officials and Planned Corrective Action: Please refer to Gaudenzia, Inc. and Gaudenzia Foundation, Inc.’s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development and U.S. Department of Health and Human Services Federal Program Name: Continuum of Care Program Center for Substance Abuse Treatment - Certified Community Behavioral Health Clinic Assistance Listing Number: 14.267 93.696 Direct Federal Award Program: PA0029L3T002316 - Tioga Arms PA0568L3T002308 - Shelton Court 22TI85374A – Certified Community Behavioral Health Clinic Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria: Federal regulations at 2 CFR Part 200 require non-Federal entities to follow documented procurement procedures that comply with applicable federal statutes and procurement standards. Under 2 CFR 200.320(a)(2), small purchase procedures must include obtaining price or rate quotations from an adequate number of qualified sources for purchases exceeding the micro-purchase threshold but not exceeding the simplified acquisition threshold. Additionally, 2 CFR 200.319 requires procurement transactions to be conducted in a manner providing full and open competition. Condition: As part of our audit procedures over the Organization’s procurement policy and the small purchase requirements under 2 CFR 200.320(a)(2), we sampled a total of five vendors who incurred costs exceeding $10,000 for each of the two major programs. For two of the five vendors selected, management was unable to provide written documentation demonstrating that price or rate quotations were obtained from an adequate number of qualified sources (generally 2-3 quotes) for purchases above the micro-purchase threshold ($10,000) and below the Simplified Acquisition Threshold ($250,000). This documentation should have included the names of suppliers contacted, prices quoted, and the justification for vendor selection. Questioned Costs: None identified. Context: The Organization is responsible for administering federal funds under the Continuum of Care (CoC) Certified Community Behavioral Health Clinic programs and must adhere to the procurement standards outlined in 2 CFR Part 200. As part of the single audit process, procurement transactions were reviewed to verify that the organization implemented appropriate procurement methods based on total vendor expenditures and maintained all required supporting documentation for purchases exceeding the micro-purchase threshold. Cause: Management’s procedures did not consistently ensure that the required procurement documentation was obtained and retained, and there were limited controls in place to monitor vendor expenditures in the aggregate to help determine the appropriate procurement method. Effect: Controls over the procurement process are not in place to determine that all procurement transactions are conducted in a manner providing full and open competition, in accordance with 2 CFR 200.319. Repeat Finding: N/A: Not a repeat finding Recommendation: We recommend management update its policies and procedures over procurement to ensure compliance with 2 CFR Part 200. This includes requiring and retaining documentation supporting the use of small purchase procedures, obtaining price or rate quotations from an adequate number of qualified sources, and monitoring vendor expenditures on an aggregate basis to ensure the appropriate procurement method is applied. Management should also provide training for staff responsible for procurement activities to promote consistent compliance with federal requirements. View of Responsible Officials and Planned Corrective Action: Please refer to Gaudenzia, Inc. and Gaudenzia Foundation, Inc.’s Corrective Action Plan.
Federal Agency: U.S. Department of Housing and Urban Development U.S. Department of Health and Human Services Federal Program Name: Continuum of Care Program Center for Substance Abuse Treatment - Certified Community Behavioral Health Clinic Assistance Listing Number: 14.267 93.696 Direct Federal Award Program: PA0029L3T002316 - Tioga Arms PA0568L3T002308 - Shelton Court 22TI85374A – Certified Community Behavioral Health Clinic Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Condition: As part of our audit procedures over the Organization’s procurement policy and the small purchase requirements under 2 CFR 200.320(a)(2), we sampled a total of five vendors who incurred costs exceeding $10,000 for each of the two major programs. For three of the five vendors selected, management was unable to provide written documentation demonstrating that price or rate quotations were obtained from an adequate number of qualified sources (generally 2-3 quotes) for purchases above the micro-purchase threshold ($10,000) and below the Simplified Acquisition Threshold ($250,000). This documentation should have included the names of suppliers contacted, prices quoted, and the justification for vendor selection. Recommendation: We recommend management update its policies and procedures over procurement to ensure compliance with 2 CFR Part 200. This includes requiring and retaining documentation supporting the use of small purchase procedures, obtaining price or rate quotations from an adequate number of qualified sources, and monitoring vendor expenditures on an aggregate basis to ensure the appropriate procurement method is applied. Management should also provide training for staff responsible for procurement activities to promote consistent compliance with federal requirements. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action taken in response to finding: Management acknowledges the deficiency related to procurement documentation and compliance. While the Organization has procurement practices in place, documentation supporting the solicitation of price or rate quotations from an adequate number of qualified sources was not consistently maintained for certain purchases during the audit period. In certain instances, vendor selection was influenced by the need to ensure continuity of care and avoid disruption to critical services provided to clients. As a result, management prioritized maintaining established vendor relationships to support uninterrupted service delivery; however, formal documentation supporting this rationale was not consistently retained in accordance with procurement requirements. To address this matter, management will update and formalize procurement policies and procedures to ensure full compliance with federal requirements. This will include clearly defined documentation standards for all purchases exceeding the micro-purchase threshold, including retention of vendor quotes, identification of suppliers contacted, and justification for vendor selection—including instances where continuity of care is a determining factor. In addition, training will be provided to all staff involved in procurement activities to reinforce compliance expectations and documentation requirements. Management expects these corrective actions to be implemented in the current fiscal year and will conduct periodic reviews to ensure adherence and ongoing compliance. Name of the contact person responsible for corrective action: Dr. Deja Gilbert, PhD, MDA, FACHE, LPC, LMHC, President and CEO dgilbert@gaudenzia.org Planned completion date for corrective action plan: June 30, 2026
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless), and lease or housing agreement (depending on program requirements). Of the 40 resident client files reviewed, management was unable to provide any proof of income or determination of homelessness or residency for 24 files. Questioned costs: None Context: The HOME program has income targeting requirements where only low-income or very low-income individuals, as defined in 24 CFR section 92.2, are eligible for housing assistance. Consequently, organizations receiving or using HOME funds must verify the annual income of each household, considering all members. These organizations must maintain records for every family assisted. HOME-assisted units in rental housing projects must be occupied only by households that qualify as low-income families and must adhere to specific rent limits. According to 24 CFR Section 92.209(c), participating organizations must select families based on low-income or homeless criteria. Cause: The Organization’s residential program, Philly House, which operated from the Venango location, provided low-intensity residential services for adult men with substance use and co-occurring disorders. This program was relocated to another site within the Organization’s network as it better complied with the requirements specified in the Project HOME Loans due to its nature. In contrast, the Re-Entry House, a halfway house for adult men with substance use and co-occurring disorders offering stable residential housing services, represented a different type of residential program. During the transition, management, at the location, did not prepare policies and procedures to determine income eligibility as outlined in the Project Home Loan agreement and 24 CFR section 92.2. Consequently, no documentation was prepared or provided to the auditors to demonstrate compliance with the eligibility and Project HOME Loan requirements.
Show full finding ▾Hide full finding ▴2024-001 Federal Agencies: U.S. Department of Housing and Urban Development Federal Program Names: HOME Investment Partnership Program Assistance Listing Numbers: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of Schuylkill - Home Investment Partnerships and Housing Trust Funds Programs: Fountain Springs - Loan Mayor and City of Baltimore: Baltimore Housing - Park Heights Women and Children - Loan Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Material Witness in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provision of eligibility. The Organization should have procedures and controls in place to ensure that the Organization leases the property to low-income homeless persons and complies with the terms and conditions dictated in the HOME loan agreement. Proper documentation should be maintained demonstrating evidence that residents living at the property meet the HOME loan criteria. Condition: As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless), and lease or housing agreement (depending on program requirements). Of the 40 resident client files reviewed, management was unable to provide any proof of income or determination of homelessness or residency for 24 files. Questioned costs: None Context: The HOME program has income targeting requirements where only low-income or very low-income individuals, as defined in 24 CFR section 92.2, are eligible for housing assistance. Consequently, organizations receiving or using HOME funds must verify the annual income of each household, considering all members. These organizations must maintain records for every family assisted. HOME-assisted units in rental housing projects must be occupied only by households that qualify as low-income families and must adhere to specific rent limits. According to 24 CFR Section 92.209(c), participating organizations must select families based on low-income or homeless criteria. Cause: The Organization’s residential program, Philly House, which operated from the Venango location, provided low-intensity residential services for adult men with substance use and co-occurring disorders. This program was relocated to another site within the Organization’s network as it better complied with the requirements specified in the Project HOME Loans due to its nature. In contrast, the Re-Entry House, a halfway house for adult men with substance use and co-occurring disorders offering stable residential housing services, represented a different type of residential program. During the transition, management, at the location, did not prepare policies and procedures to determine income eligibility as outlined in the Project Home Loan agreement and 24 CFR section 92.2. Consequently, no documentation was prepared or provided to the auditors to demonstrate compliance with the eligibility and Project HOME Loan requirements.
2024-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of Schuylkill - Home Investment Partnerships and Housing Trust Funds Programs: Fountain Springs - Loan Mayor and City of Baltimore: Baltimore Housing - Park Heights Women and Children - Loan Condition: As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless), and lease or housing agreement (depending on program requirements). Of the 40 resident client files reviewed, management was unable to provide any proof of income or determination of homelessness or residency for 24 files. Recommendation: We recommend that management adopt policies and procedures including both the communication of compliance requirements between staff and locations and the development of documentation and processes to assist in how income eligibility is determined. This includes management developing certain income verification documents that can be used as part of the intake process for determining the eligibility of the residential client. In addition, process will need to be developed for the redetermination of income if a residential client has lived over a year at a particular location. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Gaudenzia, Inc believes that had the requisite documentation been completed, it would have been in compliance with the low-income compliance requirement as the referral sources that were used to place the clients in the program are all coming from CBH as well as other MCO funded partners. These referral sources are typically Medicaid clients and are typically well below the low-income requirement thresholds. Action taken in response to finding: Gaudenzia, Inc has incorporated existing low-income eligibility procedures to the Project Home Loans program sites to be in full compliance of the eligibility requirements. These procedures will be reinforced within our programs to ensure the requisite documentation is in place. Name of the contact person responsible for corrective action: Nikant Ohri, Chief Financial Officer, nikant.ohri@guadenzia.org (610) 860-2061 Planned completion date for corrective action plan: June 30, 2025
FAC accepted this audit on March 30, 2021 — management decision was due September 30, 2021.
During our testing of program service revenue and receivables, specifically for grant-funded programs, we noted a lack of supervisory review and approval over the invoicing process. Additionally, management was only able to provide us with evidence of payment and funder acceptance of invoices submitted rather than the actual authorized invoice generated and documentation supporting what had been recorded in the general ledger for 5 out of a total of 40 transactions sampled. Certain invoices did not match what had been recorded in revenue due to some modifications made in the billing system. The documentation provided by management did support the existence, accuracy and completeness of the population sampled, but did not demonstrate the overall function of internal controls over the billing system. Questioned Cost: None Cause: Management at Gaudenzia, Inc. and Gaudenzia Foundation is not reviewing and approving various transactions in accordance with the cash management and reporting provisions of 2 CFR 200, Subpart E, Cost Principles of Uniform Guidance. Effect: Noncompliance to the cash management and reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the payback of costs or loss of future funding. Recommendation: We recommend that management implement invoice submission procedures to ensure that the review and approval process is being appropriately documented. In addition, there is a separation between employees of the financial department, so the employee preparing the invoice or drawdown is not the person authorizing the drawdown or invoice submitted to a federal, state, county or city agency. We would also recommend that documentation supporting the amounts in an invoice provided to a funder show evidence of authorization to possibly reduce any questions or possible disallowance of invoice amounts. Views of Responsible Officials: Please refer to Gaudenzia, Inc. and Gaudenzia Foundation?s Corrective Action Plan
Show full finding ▾Hide full finding ▴2020-001 Entity: Gaudenzia, Inc. and Gaudenzia Foundation, Inc. Federal agency: U.S. Department of Health and Human Services Federal program: Block Grants for Prevention and Treatment of Substance Abuse Opioid STR CFDA Number: 93.959 93.788 Pass-Through Agencies: Various, state, county, and local agency contracts Pass-Through Number: Various Award Period: Various Type of Finding: ? Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of cash management and reporting. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Condition: During our testing of program service revenue and receivables, specifically for grant-funded programs, we noted a lack of supervisory review and approval over the invoicing process. Additionally, management was only able to provide us with evidence of payment and funder acceptance of invoices submitted rather than the actual authorized invoice generated and documentation supporting what had been recorded in the general ledger for 5 out of a total of 40 transactions sampled. Certain invoices did not match what had been recorded in revenue due to some modifications made in the billing system. The documentation provided by management did support the existence, accuracy and completeness of the population sampled, but did not demonstrate the overall function of internal controls over the billing system. Questioned Cost: None Cause: Management at Gaudenzia, Inc. and Gaudenzia Foundation is not reviewing and approving various transactions in accordance with the cash management and reporting provisions of 2 CFR 200, Subpart E, Cost Principles of Uniform Guidance. Effect: Noncompliance to the cash management and reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the payback of costs or loss of future funding. Recommendation: We recommend that management implement invoice submission procedures to ensure that the review and approval process is being appropriately documented. In addition, there is a separation between employees of the financial department, so the employee preparing the invoice or drawdown is not the person authorizing the drawdown or invoice submitted to a federal, state, county or city agency. We would also recommend that documentation supporting the amounts in an invoice provided to a funder show evidence of authorization to possibly reduce any questions or possible disallowance of invoice amounts. Views of Responsible Officials: Please refer to Gaudenzia, Inc. and Gaudenzia Foundation?s Corrective Action Plan
Gaudenzia?s management agrees with the auditor?s recommendation and has hired a Revenue Cycle Manager responsible for oversight and approval of billed services, centralization and implementation of best practices, and application of payments. This will be ready for the June 30, 2021 audit. Management is in the process of reviewing internal processes related to how invoices are submitted and prepared to ensure a separation of duties between preparer, reviewer and processer is being clearly communicated to employees. After this review, Management will seek to emphasize the importance of a review and the separations of duties with employees and train employees on this process as required. As of July 1, 2020, management had implemented a new Electronic Record System which will significantly improve the process, consistency in invoicing between locations, and provide the necessary documentation supporting invoices submitted to government agencies.
FAC accepted this audit on March 23, 2020 — management decision was due September 23, 2020.
During our testing of procurement, we had sampled nine out of ten vendors whose services were provided and expended as part of this major federal award program. We had observed that management had not prepared its procurement policy to document the requirements under Uniform Guidance. The Organization had also not implemented a procedure to document cost and price analysis of vendors. This would include the tracking of quotations from multiple vendors, maintaining of vendor files, and the use of minority vendors. None of the small purchase procurements tested had supporting documentation of price or rate quotations from an adequate number of qualified sources. Questioned Cost: None Cause: Based on the Organization?s procurement policy not being up to date with the requirements described in 2 CFR 200, Subpart E, Cost Principles of Uniform Guidance, the Organization?s processes for the hiring and/or evaluating vendors under a method of full or open competition, described in the general procurement standards under Uniform Guidance was not being performed. Effect: The Organization was not in compliance with small purchases procurement methods under the Uniform Guidance. Recommendation: We recommend that management review and update its procurement and purchasing policies, which include adding steps within the policies to include the requirements described under 2 CFR 200.317-200.326 of Uniform Guidance. Additionally, we recommend that management to add procedures encompassing the steps of both tracking and maintenance of files, which would include price quotes, bidding procedures, cost analysis and include minority vendors. Views of Responsible Officials: Please refer to Gaudenzia, Inc. and Gaudenzia Foundation?s Corrective Action Plan
Show full finding ▾Hide full finding ▴Criteria: Procurement guidance is specifically located in sections 2 CFR 200.317-200.326 of Uniform Guidance focusing on increased competition and transparency in the procurement process. There are five general procurement standards covering the purchase of property, supplies and services under the Uniform Guidance. These include; (a) Costs must be reasonable and necessary, (b) must provide for full and open competition, (c) an Organization must maintain written standards of conduct covering internal and external conflicts of interest., and (d) the organization must maintain documentation addressing cost and price analysis and vendor selections where applicable based on the method of procurement used. The non-Federal entity must use one of the following methods of procurement. (a) micro-purchases, (b) small purchases, (c) sealed bids, (d) competitive proposals and (e) sole source. For procurement by small purchase, procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. (2 CFR 200.320). Condition: During our testing of procurement, we had sampled nine out of ten vendors whose services were provided and expended as part of this major federal award program. We had observed that management had not prepared its procurement policy to document the requirements under Uniform Guidance. The Organization had also not implemented a procedure to document cost and price analysis of vendors. This would include the tracking of quotations from multiple vendors, maintaining of vendor files, and the use of minority vendors. None of the small purchase procurements tested had supporting documentation of price or rate quotations from an adequate number of qualified sources. Questioned Cost: None Cause: Based on the Organization?s procurement policy not being up to date with the requirements described in 2 CFR 200, Subpart E, Cost Principles of Uniform Guidance, the Organization?s processes for the hiring and/or evaluating vendors under a method of full or open competition, described in the general procurement standards under Uniform Guidance was not being performed. Effect: The Organization was not in compliance with small purchases procurement methods under the Uniform Guidance. Recommendation: We recommend that management review and update its procurement and purchasing policies, which include adding steps within the policies to include the requirements described under 2 CFR 200.317-200.326 of Uniform Guidance. Additionally, we recommend that management to add procedures encompassing the steps of both tracking and maintenance of files, which would include price quotes, bidding procedures, cost analysis and include minority vendors. Views of Responsible Officials: Please refer to Gaudenzia, Inc. and Gaudenzia Foundation?s Corrective Action Plan
U.S. Department of Health and Human Services Gaudenzia, Inc. and Gaudenzia Foundation, Inc. and Gaudenzia Erie respectfully submits the following corrective action plan for the year ended June 30, 2019. Audit period: Fiscal year June 30, 2019 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development U.S. Department of Health and Human Services FA 2019-001 Continuum Care Program and Substance Abuse and Mental Health Services Projects of Regional and National Significance Recommendation: We recommend that management review and update its procurement and purchasing policies, which include adding steps within the policies to include the requirements described under 2 CFR 200.317-200.326 of Uniform Guidance. Additionally, we recommend that management to add procedures encompassing the steps of both tracking and maintenance of files, which would include price quotes, bidding procedures, cost analysis and include minority vendors. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Gaudenzia has updated our purchasing policies and procedures to adhere to the requirements described under 2 CFR200.317-200.326. This will allow us to track all purchases including price quotes and include minority vendors. Gaudenzia has also put in place a new and improved bidding and RFP procedures to adhere to the new requirements. Name of the contact person responsible for corrective action: Nicholas Chaban, Chief of Corporate Finance ? Phone: 610-239-9600, Ext. 1025 Email: nchaban@Gaudenzia.org Planned completion date for corrective action plan: June 30, 2020
FAC accepted this audit on February 26, 2019 — management decision was due August 26, 2019.
GSA_MIGRATION
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2017-001
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2017-002
FAC accepted this audit on March 16, 2018 — management decision was due September 16, 2018.
GSA_MIGRATION
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2016-004
GSA_MIGRATION
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GSA_MIGRATION
2016-005
FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-003
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
2015-003
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
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