EIN: 232364586
UEI: NJQQXVND1986
Audited by: Baker Tilly US, LLP
Oversight agency: 21 [Department of the Treasury]
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Data as of August 31, 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 (30 days from today).
What is a management decision? →Item 2025-002 - Material Weakness in Internal Control, Material Noncompliance - Procurement, Suspension and Debarment Assistance Listing Number: 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-Through Entity: Spanish American Civic Association for Equality, Inc. Federal Award Identification Number: Not available Criteria: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at Title 2 U.S. Code of Federal Regulations (CFR) sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. In addition, nonfederal entities also need to follow the standards in 2 CFR Part 180 regarding suspension and debarment of contractors. Condition/Context: Management's procurement policy did not conform with the standards of 2 CFR Part 200. As a result, for two of the two procurement transactions selected, the Organization did not properly document the following for items tested exceeding the Simplified Acquisition Threshold of $250,000 – procurement method rationale, basis for contractor selection, and a cost-price analysis. Additionally, the Organization's policies did not include a procedure to verify a contractor's suspension or debarment status before entering into a covered transaction. The sample was not statistically valid. Cause: Management was not aware of the requirement(s) that their policy needed to comply with all relevant provisions of 2 CFR Part 200 and therefore, were not processing procurement transactions in accordance with the relevant provisions. Effect: The Organization did not establish and implement a procurement policy consistent with the requirements of 2 CFR Part 200. As such, they did not document procurements consistent with the standards of 2 CFR sections 200.318, 200.319 and 200.320. As a result, procurements of goods and services may be made to individuals who are suspended or debarred or would be made without obtaining the best possible price. Questioned Costs: Not determinable, as the questioned costs, if any, would be calculated based upon the price paid vs. the price that would have been paid had the organization followed the proper methods of procurement, which may or may not have been more economical. Recommendation: We recommend management enhances its procurement policy to conform to 2 CFR sections 180 and 200.318 through 200.326. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and is in the process of enhancing the Organization's written policies and procedures for procurement.
Show full finding ▾Hide full finding ▴Item 2025-002 - Material Weakness in Internal Control, Material Noncompliance - Procurement, Suspension and Debarment Assistance Listing Number: 21.027 Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Name of Pass-Through Entity: Spanish American Civic Association for Equality, Inc. Federal Award Identification Number: Not available Criteria: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at Title 2 U.S. Code of Federal Regulations (CFR) sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. In addition, nonfederal entities also need to follow the standards in 2 CFR Part 180 regarding suspension and debarment of contractors. Condition/Context: Management's procurement policy did not conform with the standards of 2 CFR Part 200. As a result, for two of the two procurement transactions selected, the Organization did not properly document the following for items tested exceeding the Simplified Acquisition Threshold of $250,000 – procurement method rationale, basis for contractor selection, and a cost-price analysis. Additionally, the Organization's policies did not include a procedure to verify a contractor's suspension or debarment status before entering into a covered transaction. The sample was not statistically valid. Cause: Management was not aware of the requirement(s) that their policy needed to comply with all relevant provisions of 2 CFR Part 200 and therefore, were not processing procurement transactions in accordance with the relevant provisions. Effect: The Organization did not establish and implement a procurement policy consistent with the requirements of 2 CFR Part 200. As such, they did not document procurements consistent with the standards of 2 CFR sections 200.318, 200.319 and 200.320. As a result, procurements of goods and services may be made to individuals who are suspended or debarred or would be made without obtaining the best possible price. Questioned Costs: Not determinable, as the questioned costs, if any, would be calculated based upon the price paid vs. the price that would have been paid had the organization followed the proper methods of procurement, which may or may not have been more economical. Recommendation: We recommend management enhances its procurement policy to conform to 2 CFR sections 180 and 200.318 through 200.326. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and is in the process of enhancing the Organization's written policies and procedures for procurement.
Corrective Action Plan Corrective Action Planned: Corrective Action Steps 1. Revise Procurement Policy to Align with 2 CFR Part 200 • Update the Organization’s written procurement policy to incorporate the federal requirements of 2 CFR §§ 200.318–200.326, including: o Full and open competition requirements (200.319) o Required procurement methods and thresholds (200.320) o Documentation standards for cost/price analysis (200.324) o Requirements for contractor integrity and debarment checks (200.214 & 200.213) • Ensure the policy clearly outlines the documentation required for all procurement types, including those above the Simplified Acquisition Threshold. Target Date: Draft completed within 30 days; governing body approval within 60 days. ________________________________________ 2. Implement Mandatory Debarment Verification Procedures • Establish written procedures requiring staff to verify contractor suspension/debarment status prior to contract award using: o SAM.gov (System for Award Management), or o A compliant certification from the contractor. • Implement a verification log or standardized form to be included in every procurement file. Target Date: Immediately upon policy adoption. ________________________________________ 3. Develop Required Procurement Documentation Templates Management will create standardized, easy to use templates to ensure consistent documentation, including: • Procurement method determination and rationale • Basis for contractor selection • Cost/price analysis form • Conflict of interest certification • Debarment verification form • Procurement checklist for all purchases over each threshold Target Date: Within 90 days. ________________________________________ 4. Staff Training • Provide mandatory training to all staff involved in purchasing, contracting, and grant management. • Training will focus on: o Federal procurement standards o Documentation expectations o Use of new templates o Debarment verification procedures Target Date: Within 30 days after the policy update. ________________________________________ 5. Ongoing Monitoring and Quality Assurance • The Finance Department will periodically review procurement files to verify compliance. • Findings will be reported to management and corrective actions taken promptly. Target Date: Ongoing; monitoring process implemented within 90 days. Name(s) of Contact Person(s) Responsible for Corrective Action: Jose Lopez – CEO and Ryan Ellis – CFO will ensure that the above corrective action plan is carried out. Anticipated Completion Date: 06/30/2026
FAC accepted this audit on April 1, 2024 — management decision was due October 1, 2024.
FAC accepted this audit on June 1, 2023 — management decision was due December 1, 2023.
FAC accepted this audit on March 13, 2022 — management decision was due September 13, 2022.
Item 2021-001 - Internal Control Over Financial Reporting - Material Audit Adjustments Criteria: All consolidated financial statement line items should be fairly presented in accordance with accounting standards generally accepted in the United States of America. Condition/Context: Two material adjustments were required to correct consolidated financial statement line items as of and for the year ended June 30, 2021. One of the adjustments related to a subsidy allowance on property held for sale, and the other related to recording federal grants received as refundable advances rather than revenues until the performance barriers are substantially met. Cause: Management did not accurately record two complex transaction in accordance with accounting standards generally accepted in the United States of America. Effect: The Organization recorded two material audit adjustments related to complex financial reporting matters. This constitutes a material weakness in internal controls over financial reporting. Recommendation: We recommend that management understand the financial reporting requirements of all complex transactions it has. Views of Responsible Officials and Planned Corrective Actions: The Organization infrequently has transactions outside of the scope of normal operations. In these instances management will review related agreements and financial reporting requirements to determine the appropriate accounting treatment.
Show full finding ▾Hide full finding ▴Item 2021-001 - Internal Control Over Financial Reporting - Material Audit Adjustments Criteria: All consolidated financial statement line items should be fairly presented in accordance with accounting standards generally accepted in the United States of America. Condition/Context: Two material adjustments were required to correct consolidated financial statement line items as of and for the year ended June 30, 2021. One of the adjustments related to a subsidy allowance on property held for sale, and the other related to recording federal grants received as refundable advances rather than revenues until the performance barriers are substantially met. Cause: Management did not accurately record two complex transaction in accordance with accounting standards generally accepted in the United States of America. Effect: The Organization recorded two material audit adjustments related to complex financial reporting matters. This constitutes a material weakness in internal controls over financial reporting. Recommendation: We recommend that management understand the financial reporting requirements of all complex transactions it has. Views of Responsible Officials and Planned Corrective Actions: The Organization infrequently has transactions outside of the scope of normal operations. In these instances management will review related agreements and financial reporting requirements to determine the appropriate accounting treatment.
Finding 2021-001 Condition Two material adjustments were required to correct financial statement line items as of and for the year ended June 30, 2021 in accordance with accounting standards generally accepted in the United States of America. One of the adjustments related to a subsidy allowance on property held for sale, and the other related to recording federal grants received as refundable advances rather than revenues until the performance barriers are substantially met. Corrective Action Plan Corrective Action Planned: The Organization infrequently has transactions outside of the scope of normal operations. In these instances, management will review related agreements and financial reporting requirements to determine the appropriate accounting treatment. Name(s) of Contact Person(s) Responsible for Corrective Action: Rosa Graupera, Chief Financial Officer, rgraupera@sacapa.org, 717.295.7987. Anticipated Completion Date: For all transactions subsequent to June 30, 2021.
FAC accepted this audit on January 24, 2018 — management decision was due July 24, 2018.
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