EIN: 271206272
UEI: V7WQXY2EDWV2
Audited by: JACOBSON JARVIS AND CO
Oversight agency: 93 [Department of Health and Human Services]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 9, 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 January 9, 2027 (128 days from today).
What is a management decision? →FAC accepted this audit on August 6, 2025 — management decision was due February 6, 2026.
Entity was not able to provide the date the verification check occurring before entering into contract with a vendor/subrecipient. Questioned Costs: None Context: During our testing, we identified instances where there was no documented dates of the verification check occurring before entering into contract with a vendor/subrecipient. Cause: The entity doesn't document the verification check prior to entering into contract with vendor/subrecipient. Effect: The entity is not in compliance with Federal Government requirements. Repeat Finding: No Recommendation: We recommend the entity evaluate its procedures and implement an additional control to document verification checks are occurring prior to entering into contract with a vendor/subrecipient. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Health and Human Services; U.S. Department of Education Federal Program Name: Continuum of Care Program; National Family Caregiver Support, Title III, Part E; Rehab Services Demonstration & Training Program Assistance Listing Number: 14.267; 93.052; 84.235 Federal Award Identification Number and Year: WA0548L0T002200-2024; DA23-1535-2024; H235F200005-2024 Pass-Through Agency: 14.267-King County Regional Homelessness Authority; 93.052-City of Seattle Pass-Through Number(s): WA0548L0T002200-2024; DA23-1535-2024 Award Period: 1/1/2024-12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Federal Government requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Entity was not able to provide the date the verification check occurring before entering into contract with a vendor/subrecipient. Questioned Costs: None Context: During our testing, we identified instances where there was no documented dates of the verification check occurring before entering into contract with a vendor/subrecipient. Cause: The entity doesn't document the verification check prior to entering into contract with vendor/subrecipient. Effect: The entity is not in compliance with Federal Government requirements. Repeat Finding: No Recommendation: We recommend the entity evaluate its procedures and implement an additional control to document verification checks are occurring prior to entering into contract with a vendor/subrecipient. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
We accept this finding that we could not provide adequate verification or documented dates when an entity is being checked through the Sam.gov system prior to entering into a contract as defined in 2 CFR section 180.995. We have taken steps to correct the issue as of June 1, 2025. All new prospective contractors will be entered into the Sam system and scanned for debarment prior to contracting with them by the Program Manager. In addition, we are in the process of updating our vendor agreements to include language so a vendor can attest they are not debarred from doing business with the federal government.
Entity does not perform formal documented reviews and approvals over indirect cost calculations and reimbursement requests prior to submission to granting agency. Questioned Costs: None Context: During our testing, we identified instances where there was no documented review and approvals over indirect cost calculations and reimbursement requests prior to submission to granting agency. Cause: The entity does not have a formal review or approval process in place. Effect: The entity is not in compliance with Federal Government requirements. Repeat Finding: No Recommendation: We recommend the entity implement procedures and a control to document review and approvals over indirect costs and cash management. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Name: Rehab Services Demonstration & Training Program Assistance Listing Number: 84.235 Federal Award Identification Number and Year: H235F200005-2024 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: 1/1/2024-12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reimbursement requests are formally reviewed by someone who did not prepare the request to verify the correct information and data is submitted. Condition: Entity does not perform formal documented reviews and approvals over indirect cost calculations and reimbursement requests prior to submission to granting agency. Questioned Costs: None Context: During our testing, we identified instances where there was no documented review and approvals over indirect cost calculations and reimbursement requests prior to submission to granting agency. Cause: The entity does not have a formal review or approval process in place. Effect: The entity is not in compliance with Federal Government requirements. Repeat Finding: No Recommendation: We recommend the entity implement procedures and a control to document review and approvals over indirect costs and cash management. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
We accept this finding as per 2 CFR 200.303, a formal documented review and approval process over the indirect cost calculations and online reimbursement requests was not reviewed or approved by someone other than the preparer prior to submittal to the grant agency. We have taken steps to correct the issue as of June 1, 2025. The Accounting Manager will send the monthly indirect cost allocation report to the Executive Director to review and approve prior to beginning any month-end billing process so if corrections are needed, they can be made prior to reimbursement requests being sent to the grant agency. We have also implemented a new month-end process as of June 1, 2025, for the Accounting Manager to provide a detailed GL report to each Program Manager to review and approve program expenses for the given month prior to any billing requests being submitted to the grant agency.
FAC accepted this audit on October 1, 2024 — management decision was due April 1, 2025.
FAC accepted this audit on July 19, 2023 — management decision was due January 19, 2024.
Finding No. 2022-002 ? Allocation of Payroll Costs to Government Grant Programs Federal Agency: Department of Education Federal Program: 84.235F Rehabilitation Services Demonstration and Training Program Type of Finding: Material Weakness in Internal Control over Compliance Material Weakness in Internal Control over Financial Reporting Finding: Internal control processes over compliance did not ensure all payroll and labor costs were allocated in a consistent manner to grant programs. Criteria: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and context: The Organization paid bonuses to employees and allocated those costs to the federal and other government grant programs based upon criteria other than time and effort for actual work performed. These costs were allocated without obtaining a certification of the bonus allocation from staff members. Internal controls were not properly designed to allocate one-time payroll costs in accordance with the requirements of the Uniform Guidance. Sample Size and Population: Sampling was not applicable to this finding. Cause: The Organization?s internal controls over bi-monthly payroll allocation were not applied to bonus allocations. Effect: Payroll cost allocations not based on actual time and effort expended can result in unallowable costs charged to federal and other government grant programs. Questioned Costs: $5,000 Recommendation: Management and those charged with governance should consider increasing the controls around the allocation of payroll costs to ensure allocation is made based upon actual time and effort expended, and that a certification of time allocations is obtained from all employees in a timely and consistent manner, including one-time payroll bonuses and any time allocated to programs which is not eligible for reimbursement. Views of Management and Corrective Action Plan: Management?s response is reported in the ?Corrective Action Plan? at the end of this report. Contact Person: Ginger Kwan, Executive Director
Show full finding ▾Hide full finding ▴Finding No. 2022-002 ? Allocation of Payroll Costs to Government Grant Programs Federal Agency: Department of Education Federal Program: 84.235F Rehabilitation Services Demonstration and Training Program Type of Finding: Material Weakness in Internal Control over Compliance Material Weakness in Internal Control over Financial Reporting Finding: Internal control processes over compliance did not ensure all payroll and labor costs were allocated in a consistent manner to grant programs. Criteria: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and context: The Organization paid bonuses to employees and allocated those costs to the federal and other government grant programs based upon criteria other than time and effort for actual work performed. These costs were allocated without obtaining a certification of the bonus allocation from staff members. Internal controls were not properly designed to allocate one-time payroll costs in accordance with the requirements of the Uniform Guidance. Sample Size and Population: Sampling was not applicable to this finding. Cause: The Organization?s internal controls over bi-monthly payroll allocation were not applied to bonus allocations. Effect: Payroll cost allocations not based on actual time and effort expended can result in unallowable costs charged to federal and other government grant programs. Questioned Costs: $5,000 Recommendation: Management and those charged with governance should consider increasing the controls around the allocation of payroll costs to ensure allocation is made based upon actual time and effort expended, and that a certification of time allocations is obtained from all employees in a timely and consistent manner, including one-time payroll bonuses and any time allocated to programs which is not eligible for reimbursement. Views of Management and Corrective Action Plan: Management?s response is reported in the ?Corrective Action Plan? at the end of this report. Contact Person: Ginger Kwan, Executive Director
We agree with this finding regarding the allocation of payroll costs for one-time bonus payments. We have taken steps to correct the issues identified and during June 2023 we modified our procedures for allocation of payroll costs to federal programs. In June 2023, we changed our payroll processing vendor. This will allow us to have better controls over our payroll processing. We will make sure all staff certify their time and effort expended for each payroll.
Finding No. 2022-003 ? Lacking Certifications for Direct Assistance Provided to Individuals Federal Agency: Department of Education Department of the Treasury Federal Program: 84.235 Rehabilitation Services Demonstration and Training Program 21.023 Emergency Rental Assistance Type of Finding: Material Weakness in Internal Control over Compliance Finding: Internal control processes of over compliance did not ensure all client certification forms for federal assistance received were signed by tenants or completed in their entirety. Criteria: Per guidance in 2 CFR 200.302: The non-federal entity?s financial management systems, including records documenting compliance with federal statutes must be sufficient to permit the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the terms and conditions of the federal award. Condition and context: The Organization did not obtain a certification of actual final rent amounts received by landlords or tenants for total rent assistance payments received under the Emergency Rental Assistance program. The rent assistance accounting forms that were used by management included a tenant signature line, which would have provided a certification of the total amount of assistance provided, but no signatures were present on any of the forms tested. The Organization also did not obtain a certification acknowledging receipt of gift card funds from 12 of 25 gift card program recipients tested for the Rehabilitation Services Demonstration and Training Program. Sample Size and Population: We selected 6 rent assistance payments out of a population of 27 payments made under the Emergency Rental Assistance program during 2022. We selected 25 of 45 gift cards funded by the Rehabilitation Services Demonstration and Training Program during 2022. Cause: The Organization?s internal controls over obtaining certifications from federal award program recipients were not designed to ensure all recipients document their attestation as to the amount and date of funds received. Effect: The lack of controls over documentation of federal funds received could result in funds being distributed to ineligible individuals for federal assistance, or fraudulent use of funds. In addition, landlords receiving assistance for multiple months? future rents could charge tenants in duplicate for certain months? rents. Questioned Costs: $357 Recommendation: Management and those charged with governance should consider increasing the controls around the disbursement of funds to clients in the form of direct assistance via gift cards or check payments, and particularly obtaining and retaining signatures or adequate similar documentation directly from recipients for each disbursement received. Views of Management and Corrective Action Plan: Management?s response is reported in the ?Corrective Action Plan? at the end of this report. Contact Person: Ginger Kwan, Executive Director
Show full finding ▾Hide full finding ▴Finding No. 2022-003 ? Lacking Certifications for Direct Assistance Provided to Individuals Federal Agency: Department of Education Department of the Treasury Federal Program: 84.235 Rehabilitation Services Demonstration and Training Program 21.023 Emergency Rental Assistance Type of Finding: Material Weakness in Internal Control over Compliance Finding: Internal control processes of over compliance did not ensure all client certification forms for federal assistance received were signed by tenants or completed in their entirety. Criteria: Per guidance in 2 CFR 200.302: The non-federal entity?s financial management systems, including records documenting compliance with federal statutes must be sufficient to permit the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the terms and conditions of the federal award. Condition and context: The Organization did not obtain a certification of actual final rent amounts received by landlords or tenants for total rent assistance payments received under the Emergency Rental Assistance program. The rent assistance accounting forms that were used by management included a tenant signature line, which would have provided a certification of the total amount of assistance provided, but no signatures were present on any of the forms tested. The Organization also did not obtain a certification acknowledging receipt of gift card funds from 12 of 25 gift card program recipients tested for the Rehabilitation Services Demonstration and Training Program. Sample Size and Population: We selected 6 rent assistance payments out of a population of 27 payments made under the Emergency Rental Assistance program during 2022. We selected 25 of 45 gift cards funded by the Rehabilitation Services Demonstration and Training Program during 2022. Cause: The Organization?s internal controls over obtaining certifications from federal award program recipients were not designed to ensure all recipients document their attestation as to the amount and date of funds received. Effect: The lack of controls over documentation of federal funds received could result in funds being distributed to ineligible individuals for federal assistance, or fraudulent use of funds. In addition, landlords receiving assistance for multiple months? future rents could charge tenants in duplicate for certain months? rents. Questioned Costs: $357 Recommendation: Management and those charged with governance should consider increasing the controls around the disbursement of funds to clients in the form of direct assistance via gift cards or check payments, and particularly obtaining and retaining signatures or adequate similar documentation directly from recipients for each disbursement received. Views of Management and Corrective Action Plan: Management?s response is reported in the ?Corrective Action Plan? at the end of this report. Contact Person: Ginger Kwan, Executive Director
We agree with this finding that certifications of direct assistance provided to individuals were not obtained. We have taken steps to correct the issues identified and during June 2023 we modified our procedures for certification of direct assistance received by clients. We will review our process and procedures for obtaining signatures from clients receiving gift cards and other forms of direct assistance, including non-financial assistance as well as rent and utility assistance, to ensure that amounts received, and dates received are attested by clients via signature or via an acceptable alternative electronic attestation.
FAC accepted this audit on June 7, 2022 — management decision was due December 7, 2022.
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