EIN: 237004354
UEI: R4YCXMYKJAK7
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 17, 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 December 17, 2026 (114 days from today).
What is a management decision? →Condition The Foundation had advance draws of funds on a quarterly basis and as such had funds on hand when there was not an immediate cash requirement to meet disbursement need to carry out the various programs or project costs. Criteria The Foundation is responsible for establishing and maintaining effective internal controls that provide reasonable assurance the Foundations is managing federal awards in compliance with the terms and conditions of the federal awards. Federal regulations that advance payments to a recipient must be limited to the minimum amounts needed and be timed with actual, immediate cash requirements of the recipient carrying out the purpose of the approved programs or projects. The time and amount of advance payments must be close as is administratively feasible to the actual disbursements by the recipient for direct program or project costs and the proportionate share of any allowable indirect costs. Cause The Foundation incorrectly determined that it was appropriate to make requests for advances on a quarterly basis rather than making requests when there was an immediate cash requirement in order to carry out the purpose of the approved programs or projects. Effect Funds were held requested and received and held longer in the Foundation’s cash account than allowed by Federal regulations. Questioned costs $-0- Recommendation We recommend that the Foundation implement proper procedures and processes to ensure that requests for advance payments be limited to the minimum amounts needed and be timed with actual, immediate cash requirements to carry out the purpose of approved programs and projects.
Show full finding ▾Hide full finding ▴Condition The Foundation had advance draws of funds on a quarterly basis and as such had funds on hand when there was not an immediate cash requirement to meet disbursement need to carry out the various programs or project costs. Criteria The Foundation is responsible for establishing and maintaining effective internal controls that provide reasonable assurance the Foundations is managing federal awards in compliance with the terms and conditions of the federal awards. Federal regulations that advance payments to a recipient must be limited to the minimum amounts needed and be timed with actual, immediate cash requirements of the recipient carrying out the purpose of the approved programs or projects. The time and amount of advance payments must be close as is administratively feasible to the actual disbursements by the recipient for direct program or project costs and the proportionate share of any allowable indirect costs. Cause The Foundation incorrectly determined that it was appropriate to make requests for advances on a quarterly basis rather than making requests when there was an immediate cash requirement in order to carry out the purpose of the approved programs or projects. Effect Funds were held requested and received and held longer in the Foundation’s cash account than allowed by Federal regulations. Questioned costs $-0- Recommendation We recommend that the Foundation implement proper procedures and processes to ensure that requests for advance payments be limited to the minimum amounts needed and be timed with actual, immediate cash requirements to carry out the purpose of approved programs and projects.
View of Responsible Officials The Foundation is of the opinion that finding number 2025-001 for Cash Management is not applicable to the Equipment for Skilled Trades Training Programs as part of the Virginia Infrastructure Academy under ALN 84-116Z as requests for advance payments were limited to the minimum amounts needed and were timed with actual, immediate cash requirements to carry out the purpose of the approved programs and projects. With regards to College and Career Success for Foster Youth through Work-based Learning Opportunities and Coaching Support under ALN 84-116Z, the Foundation was notified by the U.S. Department of Education on September 12, 2024, that unused principal be returned. On September 25, 2024, the funds in the amount of $753,800 were refunded by wire transfer. This was the only notification the Foundation received from the U.S. Department of Education; no other notification was received regarding other advance payments made during the fiscal year. With regards to Improving the Quality of Early Childhood Educators under ALN 84-116Z, the Foundation did not receive any notification from the U.S. Department of Education requesting that advance payments be returned. In all instances of advance payments, the Foundation maintained funds in interest bearing accounts as outlined in the respective agreements for the three federal awards. With regards to the requests for advances that were made on a quarterly basis, the respective agreements for the three federal awards do not explicitly outline a timeframe for advance payments, nor did these advances trigger the federal government’s threshold for excessive drawdown. Estimated quarterly advance payments were made from the uncertainty of the U.S. Department of Education clawing back award funding while ensuring sufficient cash on hand to support approaching distributions to students and colleges and mitigating risk to the Foundation covering respective distributions with its own funds. Brown Edwards shared the suggested interpretation is a one-to-three-day timeframe between drawdown and distribution. Action taken: The Foundation calculated advance payment balances as of November 4, 2025, and issued respective returns to the U.S. Department of Education on November 5, 2025. Subsequent drawdowns have been made on a reimbursement basis. Action planned: The Foundation will revise its policies and procedures for requesting federal funds to ensure that requests for advance payments be limited to the minimum amounts needed and be timed with actual, immediate cash requirements to carry out the purpose of approved programs and projects. Specific steps: The Foundation will develop and implement a written policy requiring a documented review of immediate cash needs before any federal fund drawdown request is submitted and establishing a process to request funds on a reimbursement basis or just-in-time advance basis to align drawdowns with actual disbursements. Responsibility: The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. Timeline: Policy approved and implemented by February 2026.
Condition Proper reporting was not completed in accordance with the grant agreements. Criteria The Foundation is responsible for establishing and maintaining effective internal controls that provide reasonable assurance the Foundations is managing federal awards in compliance with the terms and conditions of the federal awards. In accordance with the Federal Funding Accountability Transparency Act (FFATA), the Foundation had an obligation to report first-tier subawards under Federal grants that are funded at $30,000 or more that meet the reporting conditions as set forth in the grant award term. Cause The Foundation had made the determination that the community colleges that they provided funding to were contractors and not subrecipients. This was an incorrect determination as the community colleges did not provide any goods or services to the Foundation in exchange for the funds distributed and as such should have been considered subrecipients and reported in accordance with the FFATA regulations. Effect The Foundation did not file three FFATA reports in accordance with the grant agreements. Questioned costs $-0- Recommendation The Foundation should consult with the federal funding agency to determine the requirements for proper reporting in accordance with the grant agreements.
Show full finding ▾Hide full finding ▴Condition Proper reporting was not completed in accordance with the grant agreements. Criteria The Foundation is responsible for establishing and maintaining effective internal controls that provide reasonable assurance the Foundations is managing federal awards in compliance with the terms and conditions of the federal awards. In accordance with the Federal Funding Accountability Transparency Act (FFATA), the Foundation had an obligation to report first-tier subawards under Federal grants that are funded at $30,000 or more that meet the reporting conditions as set forth in the grant award term. Cause The Foundation had made the determination that the community colleges that they provided funding to were contractors and not subrecipients. This was an incorrect determination as the community colleges did not provide any goods or services to the Foundation in exchange for the funds distributed and as such should have been considered subrecipients and reported in accordance with the FFATA regulations. Effect The Foundation did not file three FFATA reports in accordance with the grant agreements. Questioned costs $-0- Recommendation The Foundation should consult with the federal funding agency to determine the requirements for proper reporting in accordance with the grant agreements.
View of Responsible Officials In partnership with the federal program officers assigned to the three federal grant awards, the Foundation filed all required reporting available in SAM.gov by the specified due dates. Action taken: Following the government reopening, the Foundation reached out multiple times to the federal program officers to clarify and determine the requirements for proper reporting in accordance with the grant agreements. The response received was that they were not familiar with the Federal Funding Accountability Transparency Act and suggested filing the report independently. Action planned: Based on the response, the Foundation will file the required reporting. Specific steps: The Foundation will work with the U.S. Department of Education to ensure the proper steps for filing the missing reports are taken and all required information is submitted. In addition, the Foundation will develop and implement a written policy to provide clear guidance on FFATA reporting responsibilities, including the criteria for identifying reportable subawards and the required submission process and deadlines alongside an internal review process. Responsibility: • The Director of Development, Chief Operating Officer, and Finance Manager will ensure the three FFATA reports are filed. • The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. Timeline: • The Foundation will file required reporting alongside due dates outlined by Federal Funding Accountability Transparency Act. • Policy approved and implemented by March 2026.
Condition The Foundation did not perform subrecipient monitoring procedures in accordance with federal regulations. Criteria The Foundation is responsible for establishing and maintaining effective internal controls that provide reasonable assurance the Foundations is managing federal awards in compliance with the terms and conditions of the federal awards. Federal regulations require recipients of federal awards to ensure their subrecipients expending $750,000 or more during fiscal years prior to October 1, 2024, are audited in accordance with requirements in 2 CFR 200 Subpart F, and then to perform certain actions dependent upon audit results. To satisfy this requirement, the Foundation is required to: • Ensure the subrecipient received an audit or consider sanctions per 2 CFR 200.339. • Ensure the subrecipient takes corrective action on all findings negatively affecting subawards. • Issue a management decision within six months of the Federal Audit Clearinghouse’s acceptance of the subrecipient’s audit report if there were findings pertaining to the agency’s subawards. Cause The Foundation was not aware of the federal regulations regarding the requirements for proper subrecipient monitoring. Effect Subrecipients were not properly monitored by the Foundation in accordance with federal regulations. Questioned costs $-0- Recommendation We recommend that the Foundation implement proper procedures and processes to ensure that subrecipients are monitored in accordance with federal regulations.
Show full finding ▾Hide full finding ▴Condition The Foundation did not perform subrecipient monitoring procedures in accordance with federal regulations. Criteria The Foundation is responsible for establishing and maintaining effective internal controls that provide reasonable assurance the Foundations is managing federal awards in compliance with the terms and conditions of the federal awards. Federal regulations require recipients of federal awards to ensure their subrecipients expending $750,000 or more during fiscal years prior to October 1, 2024, are audited in accordance with requirements in 2 CFR 200 Subpart F, and then to perform certain actions dependent upon audit results. To satisfy this requirement, the Foundation is required to: • Ensure the subrecipient received an audit or consider sanctions per 2 CFR 200.339. • Ensure the subrecipient takes corrective action on all findings negatively affecting subawards. • Issue a management decision within six months of the Federal Audit Clearinghouse’s acceptance of the subrecipient’s audit report if there were findings pertaining to the agency’s subawards. Cause The Foundation was not aware of the federal regulations regarding the requirements for proper subrecipient monitoring. Effect Subrecipients were not properly monitored by the Foundation in accordance with federal regulations. Questioned costs $-0- Recommendation We recommend that the Foundation implement proper procedures and processes to ensure that subrecipients are monitored in accordance with federal regulations.
View of Responsible Officials The Foundation did indicate to the subrecipients that the subawards were federal funds and outlined terms and uses associated with the subawards. The Foundation also monitored and reviewed subrecipient reimbursement submissions and corresponding support to ensure requests complied with the terms and conditions of the subaward. Action planned: • Develop and implement written policies and procedures that: o Establish a formal process for identifying all subrecipients receiving federal awards and determining which ones meet the single audit threshold. o Define procedures to ensure subrecipients complete the required audits under 2 CFR 200 Subpart F. o Outline steps for reviewing subrecipient audit reports, identifying findings related to the Foundation's subawards, and ensuring the subrecipient develops a corrective action plan for those findings. o Formalize the process for the Foundation to issue a management decision on relevant findings within the required six-month timeframe. o Include procedures for considering sanctions if a subrecipient does not comply with audit requirements. • Perform a lookback review: o Review existing subrecipient agreements to identify any instances of non-compliance with past monitoring requirements and ensure the necessary follow-up actions (e.g., obtaining audit reports, issuing management decisions) are completed for those periods. • Establish a monitoring system: o Implement a tracking system (e.g., a spreadsheet or software) to monitor the status of subrecipient audits, deadlines for management decisions, and follow-up on corrective actions. o Designate a responsible individual/department to oversee the subrecipient monitoring process and ensure all requirements are met consistently. Responsibility: The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. The Finance Manager will be responsible for overseeing the implementation and ongoing compliance of the new subrecipient monitoring procedures. Timeline: • February 2026: Policy approved and implemented, and lookback review of prior periods completed. • Ongoing: Continuously monitor subrecipients and ensure timely action is taken on all future audit findings.
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