EIN: 232059489
UEI: LHRJBJK32WH6
Audited by: WENTZEL AND COMPANY PC
Oversight agency: 21 [Department of the Treasury]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 23, 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 23, 2026 (24 days from today).
What is a management decision? →FAC accepted this audit on May 15, 2025 — management decision was due November 15, 2025.
The organization’s procurement policies were not followed when selecting the major contractors for the expansion project. Specifically, there was no documentation maintained for federal compliance checks or the evaluation and ranking of candidates by the infrastructure committee. Criteria: Under 2 CFR 200.318, non-federal entities are required to maintain documented procurement procedures that align with applicable federal, state, and local laws; this includes maintaining records that detail the history of procurement. Cause: The organization does not have effective controls in place to ensure the procurement policies and procedures are followed. Effect: Noncompliance with federal procurement standards could lead to questioned costs for expenditures under the Coronavirus State and Local Fiscal Recovery Funds program. It also increases the risk of noncompetitive practices and missed opportunities to engage small and disadvantaged businesses. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A sample of 4 contractors was selected for testing of Procurement. Repeat Finding from Prior Year: No. Recommendation: The organization should provide training for staff involved in procurement to ensure they understand and follow the documented policies, conduct periodic reviews of procurement activities to verify compliance with the policies, and maintain documentation of the procurement activities. Views of Responsible Officials and Planned Corrective Action: We agree with the auditors’ comments, and the following action will be taken to improve the situation. We have taken steps to strengthen compliance and oversight. We are committed to developing and implementing standardized procedures for documenting meetings and procurement-related decisions, in collaboration with a delegate from the Infrastructure Committee. These procedures are being led by ACLAMO and will involve a designated Construction Manager to monitor compliance with standardized procedures and reporting throughout the project, that meeting minutes are properly recorded by the grantor’s requirements, and that all activities are compliant with the grant and contract requirements. The Infrastructure Committee delegate’s role will be to ensure alignment and transparency. ACLAMO will provide mandatory training for all staff involved in the procurement process and will conduct a comprehensive review of its procurement policy to ensure alignment with Uniform Guidance.
Show full finding ▾Hide full finding ▴2024-002: Procurement Program: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: U.S. Department of the Treasury Passed-through: Montgomery County Grant No.: MPRF-22-435, ACLAMO Expansion ARPA Grant Type of Finding: Significant Deficiency in Internal Control Condition: The organization’s procurement policies were not followed when selecting the major contractors for the expansion project. Specifically, there was no documentation maintained for federal compliance checks or the evaluation and ranking of candidates by the infrastructure committee. Criteria: Under 2 CFR 200.318, non-federal entities are required to maintain documented procurement procedures that align with applicable federal, state, and local laws; this includes maintaining records that detail the history of procurement. Cause: The organization does not have effective controls in place to ensure the procurement policies and procedures are followed. Effect: Noncompliance with federal procurement standards could lead to questioned costs for expenditures under the Coronavirus State and Local Fiscal Recovery Funds program. It also increases the risk of noncompetitive practices and missed opportunities to engage small and disadvantaged businesses. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A sample of 4 contractors was selected for testing of Procurement. Repeat Finding from Prior Year: No. Recommendation: The organization should provide training for staff involved in procurement to ensure they understand and follow the documented policies, conduct periodic reviews of procurement activities to verify compliance with the policies, and maintain documentation of the procurement activities. Views of Responsible Officials and Planned Corrective Action: We agree with the auditors’ comments, and the following action will be taken to improve the situation. We have taken steps to strengthen compliance and oversight. We are committed to developing and implementing standardized procedures for documenting meetings and procurement-related decisions, in collaboration with a delegate from the Infrastructure Committee. These procedures are being led by ACLAMO and will involve a designated Construction Manager to monitor compliance with standardized procedures and reporting throughout the project, that meeting minutes are properly recorded by the grantor’s requirements, and that all activities are compliant with the grant and contract requirements. The Infrastructure Committee delegate’s role will be to ensure alignment and transparency. ACLAMO will provide mandatory training for all staff involved in the procurement process and will conduct a comprehensive review of its procurement policy to ensure alignment with Uniform Guidance.
Procurement – policies related to procurement for the APRA contract were not followed, effective internal controls were not in place to ensure policies related to procurement were followed. ACLAMO acknowledges and agrees with Finding 2024-002 regarding the lack of adherence to procurement policies and internal controls under the ARPA (American Rescue Plan Act) contract. To address this issue, the Interim Executive Director and the Financial Team have taken immediate steps to strengthen compliance and oversight. Specifically: Oversight and Delegation: ACLAMO and its Board of Directors have agreed to hire a full-time finance director for the organization. In conjunction with the ongoing designated Construction Manager, these individuals will ensure that all procurement and financial reporting actions are in accordance with internal policies and federal guidelines stated in the contract, and that project documentation is compiled and securely stored in a timely manner for audit readiness. Infrastructure Committee Procedures: The Interim Executive Director, alongside other members of ACLAMO management, are committed to developing and implementing standardized procedures for documenting meetings and procurement-related decisions, in collaboration with a delegate from the Infrastructure Committee. These procedures are being led by ACLAMO and will involve the designated Construction Manager to monitor compliance with standardized procedures & reporting throughout the project, that meeting minutes are properly recorded by the grantor's requirements, and that all activities are compliant with the grant and contract requirements. The Infrastructure Committee delegate’s role will be to ensure alignment and transparency. Training and Capacity Building: To ensure consistent application of procurement policies, ACLAMO will provide and require mandatory training for all staff involved in procurement and contract management. Training will cover federal procurement standards, internal procedures, and documentation protocols. Policy Review and Update: As part of our continuous improvement efforts, ACLAMO will conduct a comprehensive review of its procurement policy to ensure it fully aligns with federal Uniform Guidance (2 CFR 200) and make updates where needed. The revised policy will be disseminated to all relevant personnel. ACLAMO is committed to strengthening internal controls, ensuring transparency, and maintaining full compliance with all contractual and federal requirements.
The organization did not retain copies of the quarterly reports filed with the county or confirmation of the submission. Criteria: Under the subrecipient agreement, the organization was required to submit quarterly reports to Montgomery County by the 15th of the following month. Internal controls should be in place over retention of supporting documentation to verify reports were filed accurately and timely. Cause: Internal controls over document retention for filed reports are inadequately designed and copies of reports or proof of submission were not maintained. Effect: Because copies of reports or proof of submission were not maintained, there is no supporting documentation to show that the reports were filed accurately or timely. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A sample of 4 quarterly reports was selected for testing of Reporting. Repeat Finding from Prior Year: No. Recommendation: The organization should develop procedures to ensure that copies of filed reports or proof of submission are maintained. Views of Responsible Officials and Planned Corrective Action: We agree with the auditors’ comments, and the following action will be taken to improve the situation. The Interim Executive Director will assume responsibility for submitting all required quarterly reports related to ARPA funding. Following report submission, we will request confirmation of receipt and a copy of the submitted report, which will be stored on the Financial Team SharePoint site. ACLAMO will also implement a formal tracking system to document submission dates, confirmation receipts, and responsible staff members. Relevant team members will receive training on proper document retention procedures.
Show full finding ▾Hide full finding ▴2024-003: Reporting Program: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: U.S. Department of the Treasury Passed-through: Montgomery County Grant No.: MPRF-22-435, ACLAMO Expansion ARPA Grant Type of Finding: Significant Deficiency in Internal Control Condition: The organization did not retain copies of the quarterly reports filed with the county or confirmation of the submission. Criteria: Under the subrecipient agreement, the organization was required to submit quarterly reports to Montgomery County by the 15th of the following month. Internal controls should be in place over retention of supporting documentation to verify reports were filed accurately and timely. Cause: Internal controls over document retention for filed reports are inadequately designed and copies of reports or proof of submission were not maintained. Effect: Because copies of reports or proof of submission were not maintained, there is no supporting documentation to show that the reports were filed accurately or timely. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A sample of 4 quarterly reports was selected for testing of Reporting. Repeat Finding from Prior Year: No. Recommendation: The organization should develop procedures to ensure that copies of filed reports or proof of submission are maintained. Views of Responsible Officials and Planned Corrective Action: We agree with the auditors’ comments, and the following action will be taken to improve the situation. The Interim Executive Director will assume responsibility for submitting all required quarterly reports related to ARPA funding. Following report submission, we will request confirmation of receipt and a copy of the submitted report, which will be stored on the Financial Team SharePoint site. ACLAMO will also implement a formal tracking system to document submission dates, confirmation receipts, and responsible staff members. Relevant team members will receive training on proper document retention procedures.
Reporting – reports submitted to the county for the ARPA contract were not retained, effective internal controls were not in place to ensure proper document retention. ACLAMO acknowledges and agrees with Finding 2024-003 regarding the lack of effective internal controls to ensure the retention of reports submitted to the County under the ARPA contract. To address this issue, the Interim Executive Director, in coordination with the Financial Team, has taken the following corrective actions: Quarterly Report Oversight: The Interim Executive Director will assume responsibility for submitting all required quarterly reports related to ARPA funding. This ensures a single point of accountability for timely and accurate reporting. Document Retention and Audit Readiness: Immediately following each report submission, ACLAMO will request confirmation of receipt and a copy of the submitted report from the County. These documents will be promptly uploaded and stored in ACLAMO’s Financial Team SharePoint Site to ensure secure access and proper audit documentation. Internal Control Enhancements: ACLAMO will also implement a formal tracking system (such as a report log) to document submission dates, confirmation receipts, and responsible staff members. This log will be reviewed quarterly by the Financial Team to ensure completeness and compliance. Staff Training: Relevant team members will receive training on proper document retention procedures, the importance of audit trails, and use of the SharePoint system to reinforce accountability and sustainability of this corrective action. ACLAMO is committed to improving its reporting systems and internal controls to ensure compliance with all federal and contractual requirements and to promote transparency and accountability.
FAC accepted this audit on March 30, 2024 — management decision was due September 30, 2024.
FAC accepted this audit on May 14, 2023 — management decision was due November 14, 2023.
FAC accepted this audit on March 20, 2022 — management decision was due September 20, 2022.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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