EIN: 272028308
UEI: GSA_MIGRATION
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 20, 2022. 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 20, 2022, which was (1431 days ago).
What is a management decision? →Finding Number: 2021-002 Finding Type: Federal award finding Federal Assistance Listing No.: 93.858 Program Name: National Collaboration to Support Health, Wellness and Academic Success of School-Age Children Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: n/a Grant Number: n/a Federal Award Year: 2021 Control Deficiency Type: Material weakness over compliance Instance of Noncompliance: Yes Compliance Requirement: Allowable costs Questioned Costs: None Repeat Finding: No Criteria: In accordance with Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart E ? Cost Principles, payroll costs charged to a federal award must be supported by a system of internal controls which provides reasonable assurance that time charges are accurate, allowable, and properly allocated, and support the distribution of the employee?s salary among specific activities or costs objectives, if the employee works on projects supported by more than one Federal award or a Federal award and a non-Federal award. Condition: During our testing of payroll expenses charged to the major program, we noted the organization lacked a system of internal controls to provide reasonable assurance related to the accuracy of salaries charged to the major program grant for employees working on projects supported by multiple funding sources. Cause: There is a lack of accurate timekeeping for employees who work on multiple projects, funded by both Federal and non-Federal sources. Effect: The distribution of employees? salaries among specific activities did not fully comply with the cost principles specified in the Federal Regulations. Questioned Costs: No known or likely questioned costs greater than $25,000. Audit Recommendation: We recommend that the organization implement the necessary procedures to ensure compensation costs are charged to federal awards based on a fair and equitable distribution method that is adequately documented and in accordance with Federal Regulations. Management?s Response: The organization currently does not require completion of timesheets for its exempt staff. Allocations of employee time spent on grants in general are calculated based on grant approved budgets and based on monthly discussions with project leads and calculated through a formulaic spreadsheet which was recorded against the project cost. The spreadsheet modeled all grant expenses against actuals and projections. Without proper timekeeping, the spreadsheet calculated percentages of time spent was based on reasonable assumptions. The organization will be implementing new controls and procedures to ensure accurate recording of employee time spent on federal and non-federal awards by utilizing the labor time tracking capability within the payroll system.
Finding no.: 2021-002 Contact person(s) responsible: Tracy Baird, Senior Director, Finance Corrective action planned: Management will implement new controls and procedures to ensure accurate recording of employee time spent on federal and non-federal awards by utilizing the labor time tracking capability first with recorded timesheets, then within the existing payroll system. Anticipated completion date: November 15, 2021 / April 1, 2022
Finding Number: 2021-003 Finding Type: Federal award finding Federal Assistance Listing No.: 93.858 Program Name: National Collaboration to Support Health, Wellness and Academic Success of School-Age Children Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: n/a Grant Number: n/a Federal Award Year: 2021 Control Deficiency Type: Significant deficiency over compliance Instance of Noncompliance: No Compliance Requirement: Cash management Questioned Costs: None Repeat Finding: No Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the federal agency or pass-through entity and disbursement by the non-federal entity for federal program costs. In addition, in accordance with 2 CFR 200.302(b)(6), non-federal entities must establish written procedures to implement the requirements of 2 CFR 200.305, which outlines procedures for collecting payment of federal funds either on an advance payment or reimbursement basis. Condition: During our review of cash draws from Payment Management System (PMS) for reimbursement of costs, we noted that the financial data used to determine cash draw amounts was not finalized and reviewed. In addition, amounts drawn were based on costs prepared on the accrual basis rather than based on actual cash paid. Cause: Adequate controls were not in place over federal cash management processes and procedures because the organization the organization had not established written procedures to implement the requirements of 2 CFR 200.305. Effect: While we noted no instances of noncompliance, there is a risk that federal cash on hand could exceed immediate needs, defined by PMS as cash to be disbursed within 3 business days, or the amount of reimbursement request is more than the actual cash paid for federal program costs. Audit Recommendation: We recommend that the organization establish written procedures to implement the requirements of 2 CFR 200.305. In addition, the organization should ensure that all staff in charge of cash requests of federal funds receive specialized training related to the requirements and provision of federal funding. Management?s Response: During last fiscal year, transitions within the Finance function left a period where access to the Payment Management System (PMS) was extensively delayed, resulting in the lack of timely expense calculation, and tardy payment filing. The organization is working to develop and implement internal procedure that is in accordance with 2 CFR 200.302(b)(6) and 2 CFR 200.305 to include firm controls for accuracy and timeliness in collecting payments of federal funds. The new accounting system records labor distributions and allowable costs of federal funds expended and will provide more accurate amounts for the cash draw amounts.
Finding no.: 2021-003 Contact person(s) responsible: Tracy Baird, Senior Director, Finance Corrective action planned: Management will develop and implement an internal control procedure that is consistent with 2 CFR 200.302(b)(6) and 2 CFR 200.305 to include firm controls for accuracy and timeliness in collecting payments of federal funds. In addition, a new accounting system will record labor distributions and allowable costs of federal funds expended and will provide more accurate amounts for cash draws. Anticipated completion date: December 31, 2021
Finding Number: 2021-004 Finding Type: Federal award finding Federal Assistance Listing No.: 93.858 Program Name: National Collaboration to Support Health, Wellness and Academic Success of School-Age Children Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: n/a Grant Number: n/a Federal Award Year: 2021 Control Deficiency Type: Significant deficiency over compliance Instance of Noncompliance: Yes Compliance Requirement: Procurement, suspension and debarment Questioned Costs: None Repeat Finding: No Criteria: Non-federal entities must follow procurement standards set forth in Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, sections 200.317 through 200.327. Further, they must have written procurement policies. Condition: It is our understanding that the organization did not solicit competitive pricing or rate quotations for purchases greater than the micro-purchase threshold of $10,000, nor retain documentation that such awards were reasonable based on research, experience, purchase history or other information. In addition, the organization does not have written procurement procedures. Cause: The organization has not established a policy with regard to procurement. Adequate controls were not in place over entering into procurement contracts. Effect: Failure to establish policies in compliance with, and follow, federal procurement guidelines could result in inappropriate contracts and payments as well as fraud, waste, and abuse. Audit Recommendation: We recommend that the organization adopt a written procurement policy in compliance with 2 CFR 200.317 through 200.327. Such a policy should include policies over record retention related to procurement contracts. Management?s Response: Procurement of goods and services did not exhibit a standard bidding quotation process. However, when there were contractors that were selected due to their continual work or consulted on the federal project, there was adequate communication to the federal manager to allow for a Sole Source Purchase, with documentation of request and approval. The organization is working to develop and implement internal procedure that is in accordance with 2 CFR 200.317 through 2 CFR 200.327 to include firm controls for procurement of goods and services, and clearly establishing allowable and disallowable expenses, and record retention of contracts. The new accounting system allows for document retention and communication about all expenses, and the ability to attach certain documents to the record within the system.
Finding no.: 2021-004 Contact person(s) responsible: Tracy Baird, Senior Director, Finance Corrective action planned: Management will develop and implement an internal procedure that is in accordance with 2 CFR 200.317 through 2 CFR 200.327 to include firm controls for procurement of goods and services, and clearly establish allowable and disallowable expenses, and record retention of contracts. In addition, a new accounting system will allow for document retention and communication about all expenses, and the ability to attached certain documents to the record with the system. Anticipated completion date: December 31, 2021
Finding Number: 2021-005 Finding Type: Federal award finding Federal Assistance Listing No.: 93.858 Program Name: National Collaboration to Support Health, Wellness and Academic Success of School-Age Children Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: n/a Grant Number: n/a Federal Award Year: 2021 Control Deficiency Type: Significant deficiency over compliance Instance of Noncompliance: Yes Compliance Requirement: Reporting Questioned Costs: None Repeat Finding: No Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, requires that the organization establish and maintain effective controls over the federal award that provides assurance that reports of federal awards submitted to federal agencies include all the activity of the reporting period, are supported by underlying accounting records, and are presented fairly and in accordance with program requirements. Condition: The organization is required to submit annual Federal Financial Report (FFR) (SF-425) to the funding agency to report cumulative spending status within 90 days of the end of budget period, however, the annual report due August 31, 2021 had not yet been submitted at the time of this report. In addition, for quarterly Federal Cash Transaction Reports (FCTR) filed, reports for two of the three periods tested did not include cash receipts during the period. Finally, the FCTR quarterly report due on October 30, 2020 was submitted late on November 5, 2020 and the report due on July 30, 2021 had not yet been submitted at the time of this report. Cause: Internal controls were not designed and implemented to ensure that all required reports were submitted timely and with correct information. In addition, while it is our understanding that certainly quarterly reports were prepared by more than one individual, there does not appear to be a policy for someone independent of the preparer to review reports for accuracy prior to submission. Effect: Missed filings of required reports and incorrect information reported to the federal agency prevented proper oversight and inquiry by the funding agency. Audit Recommendation: We recommend that management implement procedures to ensure all required reports are submitted properly and in a timely manner, and strengthen the organization?s review procedures related to the preparation of its FFR. At a minimum, someone independent of the preparer should review the reports and reconcile the data reported to underlying accounting records, to ensure that the information reported is complete and accurate. In addition, the organization should ensure that all staff in charge of preparing and reviewing the FFR have been provided with adequate training. Management?s Response: During last fiscal year, transitions within the Finance function resulted in extensively delayed access to the Payment Management System (PMS) and inability of timely expense calculation and tardiness of FFR (SF-425) filings. The organization is working to develop and implement controls for accuracy and timeliness in filing of all required quarterly and annual reports.
Finding no.: 2021-005 Contact person(s) responsible: Tracy Baird, Senior Director, Finance Corrective action planned: Management will develop and implement controls for the accuracy and timeliness in filing of all required quarterly and annual reports. Anticipated completion date: December 31, 2021
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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