EIN: 237112449
UEI: CK6DFBUN81J3
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 14, 2023. 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 14, 2023 (1074 days ago).
What is a management decision? →During our testing, we noted the Organization did not have adequate documentation of the procedures performed to ensure vendors were not suspended or debarred. Questioned Costs: None Context: During our testing, it was noted that the Organization was not maintaining documentation of the procedures and when they were performed of reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause: The Organization was unaware that documentation of the review of the contracts to ensure they were not suspended or debarred was not being maintained. Effect: The auditor noted no instances of noncompliance with the provisions of suspension, and debarment; however, the lack of documentation over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: 2021-001 Recommendation: We recommend the Organization to maintain documentation of the procedures performed of the review of potential contractors to determine they are not suspended or debarred and to document when the procedure took place to ensure the reviews are occurring before entering into contracts. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 001 Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Centers for Independent Living Assistance Listing Number: 93.432 Federal Award Identification Number and Year: H132A37005-12 Award Period: October 1, 2021 through September 30, 2022 Type of Finding: - Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. Paraquad, Inc. (the organization) should have internal controls designed and maintain documentation to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate documentation of the procedures performed to ensure vendors were not suspended or debarred. Questioned Costs: None Context: During our testing, it was noted that the Organization was not maintaining documentation of the procedures and when they were performed of reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause: The Organization was unaware that documentation of the review of the contracts to ensure they were not suspended or debarred was not being maintained. Effect: The auditor noted no instances of noncompliance with the provisions of suspension, and debarment; however, the lack of documentation over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: 2021-001 Recommendation: We recommend the Organization to maintain documentation of the procedures performed of the review of potential contractors to determine they are not suspended or debarred and to document when the procedure took place to ensure the reviews are occurring before entering into contracts. Views of Responsible Officials: There is no disagreement with the audit finding.
Corrective Action Plan 2022 ? 001 Centers for Independent Living - Assistance Listing No. 93.432 Recommendation: We recommend the client to maintain documentation of the procedures performed of the review of potential contractors to determine they are not suspended or debarred and to document when the procedure took place to ensure the reviews are occurring before entering into contracts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A revised policy will be put in place to tighten controls. Name(s) of the contact person(s) responsible for corrective action: Gary Auch, CPA Planned completion date for corrective action plan: March 31, 2023
2021-001
FAC accepted this audit on March 7, 2022 — management decision was due September 7, 2022.
During our testing, we noted the Organization did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned costs: None Context: During our testing, it was noted that the Organization was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause: The Organization was unaware the contractors were not being reviewed to ensure they were not suspended or debarred. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: N/A Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 001 Federal agency: U.S. Department of Health and Human Services Federal program title: Centers for Independent Living CFDA Number: 93.432 Award Period: October 1, 2020 through September 30, 2021 Type of Finding: ?Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. Paraquad, Inc. (the Organization) should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned costs: None Context: During our testing, it was noted that the Organization was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause: The Organization was unaware the contractors were not being reviewed to ensure they were not suspended or debarred. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: N/A Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred. Views of responsible officials: There is no disagreement with the audit finding.
Corrective Action Plan for finding 2021-001 Below is the new policy that was adopted related to third parties being disbarred or suspended from providing services to the Federal government. The policy was distributed to all supervisor staff and the compliance clerk. Contact Gary Auch, CPA, Senior Director of Finance with any questions at 314-289-4388. Paraquad Excluded Parties Procedure for Federal Awards It shall be the policy of Paraquad, Inc and 5240, Inc. to check to see if any of the third parties? providing services under a Federal Award are disbarred or suspended for providing services to the Federal government. The check will be done on the website https://www.dol.gov/agencies/ofccp/debarred-list. The check should be done: 1. At the opening of bids or receipt of proposals if applicable. 2. Immediately before the contract is signed. 3. After awarding the contract to assure that the status of the contractor has not changed. Documentation should be maintained from the Excluded Parties List System when it is checked Therefore, it is important that you include both the date checked and the criteria used in the query. An easy way to document this is to print the results of the query from the web browser. This will show both the date stamp and the query criteria.
During our testing, we noted one transaction that was charged to the federal award which was incurred subsequent to the Organization?s fiscal year. Questioned costs: $6,139.00 Context: During our testing, it was noted that the Organization does not review costs charged to the grant to ensure the cost was incurred prior to charging to the grant. Cause: The Organization was unaware that the one transaction noted during our testing was incurred subsequent to the Organization?s fiscal year. Effect: The auditor noted one instance of noncompliance with the provisions of allowable costs. The lack of internal controls over this compliance requirement provides further opportunities for noncompliance. Repeat Finding: N/A Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review costs charged to federal awards are incurred prior to be submitting for reimbursement. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 002 Federal agency: U.S. Department of Health and Human Services Federal program title: Centers for Independent Living CFDA Number: 93.432 Award Period: October 1, 2020 through September 30, 2021 Type of Finding: ?Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of Allowable Costs. Costs must be determined in accordance with generally accepted accounting principles (GAAP). Condition: During our testing, we noted one transaction that was charged to the federal award which was incurred subsequent to the Organization?s fiscal year. Questioned costs: $6,139.00 Context: During our testing, it was noted that the Organization does not review costs charged to the grant to ensure the cost was incurred prior to charging to the grant. Cause: The Organization was unaware that the one transaction noted during our testing was incurred subsequent to the Organization?s fiscal year. Effect: The auditor noted one instance of noncompliance with the provisions of allowable costs. The lack of internal controls over this compliance requirement provides further opportunities for noncompliance. Repeat Finding: N/A Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review costs charged to federal awards are incurred prior to be submitting for reimbursement. Views of responsible officials: There is no disagreement with the audit finding.
Corrective Action Plan for Finding 2021-002 Below is the policy that was adopted related to purchases using Federal funds. The policy was distributed and discussed with the Accounting Manager and the Billing Compliance Coordinator. Contact Gary Auch, CPA, senior Director of Finance with any questions at 314-289-4388. Paraquad and Paraquad 5240 Federal Grants? Reimbursable Procedure It shall be the policy of Paraquad, Inc. and 5240, Inc. to make sure that Federal reimbursements are only filed for items whose cost have been incurred and paid for in accordance with grant requirements and Uniform Guidance (2 CFR 200) 1. The Billing Compliance Coordinator shall create the Reimbursement Form with support from the general ledger system and the appropriate invoice documenting each item requested. 2. When completed the Director of Finance will review the work of the Billing Compliance Coordinator. Once it is ascertained that it is correct the Reimbursement Form will be signed and forward to the Accounting Manager who does the accounts payable as a part of the duties. 3. The Accounting Manager will review the requested reimbursements to make sure that they are properly paid for prior to submitting the request into the Federal system.
FAC accepted this audit on June 18, 2020 — management decision was due December 18, 2020.
The Organization?s internal controls over allowable payroll expenditures states that theallocation of payroll expenditure between federal and non-federal awards are reviewed and approvedby a program supervisor.Questioned costs: No questioned costs were identified.Context: During our testing of the organizations internal controls over allowable payroll expenditures,executive payroll wages allocated to federal awards were not reviewed and approved in accordancewith the organizations internal policies. Payroll expenditures comprised approximately 61% of the totalCenter for Independent Living federal expenditures. The audit team did not identify any questionedcosts and concluded that the control failure was not indicative of fraud or illegal activities. The auditteam did not identify other compensating controls specific to the allocation of wages between federaland non-federal. Due to the lack of compensating control and significance of payroll wages to totalfederal expenditures, the engagement team concluded that the control failure was a significantdeficiency over compliance.Cause: As a result of management changes, this control did not effectively transition upon thedeparture of the control owner. As a result, the control over the review and approval of executive payrolleffort reports failed to operate as designed.Effect: The control failure could result in questioned costs and federal reimbursement of non-compliantpayroll expenditures.Recommendation: Management should consider implementing controls to ensure that all controlsrelated to federal awards are occurring on a timely basis.Views of responsible officials: There is no disagreement with the audit finding
Show full finding ▾Hide full finding ▴2019 ? 001Federal agency: Department of Health and Human ServicesFederal program title: Centers for Independent LivingCFDA Number: 93.432Award Period: October 1, 2018 - September 30, 2019Type of Finding: Significant Deficiency in Internal Control over Compliance; Other MattersCriteria or specific requirement: CFR section 200.303, requires non-Federal entities receivingFederal awards to establish and maintain internal control over the Federal awards that providesreasonable assurance that the Federal expenditures are in compliance with Federal statutes,regulations, and the terms and conditions of the Federal awards.Condition: The Organization?s internal controls over allowable payroll expenditures states that theallocation of payroll expenditure between federal and non-federal awards are reviewed and approvedby a program supervisor.Questioned costs: No questioned costs were identified.Context: During our testing of the organizations internal controls over allowable payroll expenditures,executive payroll wages allocated to federal awards were not reviewed and approved in accordancewith the organizations internal policies. Payroll expenditures comprised approximately 61% of the totalCenter for Independent Living federal expenditures. The audit team did not identify any questionedcosts and concluded that the control failure was not indicative of fraud or illegal activities. The auditteam did not identify other compensating controls specific to the allocation of wages between federaland non-federal. Due to the lack of compensating control and significance of payroll wages to totalfederal expenditures, the engagement team concluded that the control failure was a significantdeficiency over compliance.Cause: As a result of management changes, this control did not effectively transition upon thedeparture of the control owner. As a result, the control over the review and approval of executive payrolleffort reports failed to operate as designed.Effect: The control failure could result in questioned costs and federal reimbursement of non-compliantpayroll expenditures.Recommendation: Management should consider implementing controls to ensure that all controlsrelated to federal awards are occurring on a timely basis.Views of responsible officials: There is no disagreement with the audit finding
U.S. Department of Health and Human Services2019-001 Inadequate Review of Payroll Allocations Charged to Federal AwardsFederal Program Title: Centers of Independent LivingCFDA No:. 93.432Recommendation: We recommend that management review all key controls related to compliance with federal awards and ensure each key control has been assigned to the appropriate control owner. In addition, we suggest management develop a checklist of all federal award compliance specific key controls and periodically monitor the timely performance of each key control.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: For Fiscal year ending 2020, management will work to put ensure all control owners are assigned to each key control and internal reviews focused on the improving those areas identified during the course of the single audit. In addition, key control matrices will be created to communicate key controls.Name(s) of the contact person(s) responsible for corrective action: Gary AuchPlanned completion date for corrective action plan: September 30, 2020
The Organization?s internal controls over review and approval of federal drawdowns andquarterly federal fund reporting failed to operate as designed.Questioned costs: No questioned costs were identified.Context: During our testing of the organizations internal controls over cash management and reporting,it was discovered there was no review and approval of monthly drawdowns and quarterly federal fundsreporting. As a result, there was a lack of oversight of federal award drawdowns resulting in limitedsegregation of duties. The audit team did not identify any questioned costs and concluded that thecontrol failure was not indicative of fraud or illegal activities. As both of these controls failed to operateas designed and the importance for timely oversight of federal award drawdowns, the engagementteam concluded that the control failure was a significant deficiency.Cause: As a result of management changes, this control did not effectively transition upon thedeparture of the control owner. As a result, controls over the review and approval of monthlydrawdowns and quarterly reporting did not operate as designed.Effect: The control failure could result in questioned costs and non-compliant federal drawdowns.Recommendation: Management should consider implementing controls to ensure that all controlsrelated to federal awards are occurring on a timely basis.Views of responsible officials: There is no disagreement with the audit finding
Show full finding ▾Hide full finding ▴2019 ? 002Federal agency: Department of Health and Human ServicesFederal program title: Centers for Independent LivingCFDA Number: 93.432Award Period: October 1, 2018 - September 30, 2019Type of Finding: Significant Deficiency in Internal Control over Compliance; Other MattersCriteria or specific requirement: Under CFR section 200.303 requires non-Federal entities receivingFederal awards establish and maintain internal control over the Federal awards that providesreasonable assurance that the non-Federal entity is managing the Federal awards in compliance withFederal statutes, regulations, and the terms and conditions of the Federal awards.Condition: The Organization?s internal controls over review and approval of federal drawdowns andquarterly federal fund reporting failed to operate as designed.Questioned costs: No questioned costs were identified.Context: During our testing of the organizations internal controls over cash management and reporting,it was discovered there was no review and approval of monthly drawdowns and quarterly federal fundsreporting. As a result, there was a lack of oversight of federal award drawdowns resulting in limitedsegregation of duties. The audit team did not identify any questioned costs and concluded that thecontrol failure was not indicative of fraud or illegal activities. As both of these controls failed to operateas designed and the importance for timely oversight of federal award drawdowns, the engagementteam concluded that the control failure was a significant deficiency.Cause: As a result of management changes, this control did not effectively transition upon thedeparture of the control owner. As a result, controls over the review and approval of monthlydrawdowns and quarterly reporting did not operate as designed.Effect: The control failure could result in questioned costs and non-compliant federal drawdowns.Recommendation: Management should consider implementing controls to ensure that all controlsrelated to federal awards are occurring on a timely basis.Views of responsible officials: There is no disagreement with the audit finding
U.S. Department of Health and Human Services2019-002 Inadequate Controls Over Review and Approval of Federal DrawdownsFederal Program Title: Centers of Independent LivingCFDA No: 93.432Recommendation: We recommend that management review all key controls related to compliance with federal awards and ensure each key control has been assigned to the appropriate control owner. In addition, we suggest management develop a checklist of all federal award compliance specific key controls and periodically monitor the timely performance of each key control.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: For Fiscal year ending 2020, management will work to put ensure all control owners are assigned to each key control and internal reviews focused on the improving those areas identified during the course of the single audit. In addition, key control matrices will be created to communicate key controls.Name(s) of the contact person(s) responsible for corrective action: Gary AuchPlanned completion date for corrective action plan: September 30, 2020
FAC accepted this audit on March 6, 2018 — management decision was due September 6, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2016-001, 2015-001
FAC accepted this audit on March 14, 2017 — management decision was due September 14, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-001
GSA_MIGRATION
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