EIN: 300180905
UEI: JDX3EJKNB6Y5
Audited by: WIPFLI LLP
Oversight agency: 64 [Department of Veterans Affairs]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 13, 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 July 13, 2026 (48 days ago).
What is a management decision? →FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.
The Organization records its transactions in a general ledger system capable of segregating revenue and expenses by grant, but we have noted there were inconsistencies in how expenses were recorded among the various active VA Supportive Services for Veteran Families (SSVF) grants that began in prior fiscal years. Due to these inconsistencies, the agency is not able to reconcile federal expenditures reported on its Federal Financial Reports (FFRs) to specific segments in the general ledger, nor accurately report expenses incurred for each individual SSVF grant on the schedule of expenditures of federal awards. Criteria: 2 CFR 200, Section 200.62 (Uniform Guidance) requires the following: Internal control over compliance requirements for Federal awards means a process implemented by a non-Federal entity designed to provide reasonable assurance regarding the achievement of the following objectives for Federal awards: (a) Transactions are properly recorded and accounted for, in order to: (1) Permit the preparation of reliable financial statements and Federal reports; (2) Maintain accountability over assets; and (3) Demonstrate compliance with Federal statutes, regulations, and the terms and conditions of the Federal award; (b) Transactions are executed in compliance with: (1) Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program; and (2) Any other Federal statutes and regulations that are identified in the Compliance Supplement; and (c) Funds, property, and other assets are safeguarded against loss from unauthorized use or disposition. Cause: Due to turnover at the Organization and its fiscal service providers, there were inconsistencies in internal controls and processes to code expenditures under the proper SSVF grant in prior years, which had a carry-over effect into this fiscal year for multi-year grants. Effect: As a result of the matter identified in the condition paragraph, a significant deficiency in the Organization’s internal controls over compliance and a non-material non-compliance exists. Recommendation: We recommend the Organization continue to implement procedures to ensure it is recording expenditures in a consistent basis to provide adequate accountability of federal funds and properly support expenditure reports submitted to the funding source. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴FFinding Number: 2024-001 Description: Reporting of major program grant expenditures Repeat Finding: Yes Type of Finding: Significant deficiency in internal controls over the allowable costs and reporting compliance requirements; non-material non-compliance Questioned Costs: None Major Program: AL # 64.033, VA Supportive Services for Veteran Families Program, 2020-OR-430-LT, 2020-OR-430-HL, 2020-OR-430-23, 2020-OR-430-SS Condition: The Organization records its transactions in a general ledger system capable of segregating revenue and expenses by grant, but we have noted there were inconsistencies in how expenses were recorded among the various active VA Supportive Services for Veteran Families (SSVF) grants that began in prior fiscal years. Due to these inconsistencies, the agency is not able to reconcile federal expenditures reported on its Federal Financial Reports (FFRs) to specific segments in the general ledger, nor accurately report expenses incurred for each individual SSVF grant on the schedule of expenditures of federal awards. Criteria: 2 CFR 200, Section 200.62 (Uniform Guidance) requires the following: Internal control over compliance requirements for Federal awards means a process implemented by a non-Federal entity designed to provide reasonable assurance regarding the achievement of the following objectives for Federal awards: (a) Transactions are properly recorded and accounted for, in order to: (1) Permit the preparation of reliable financial statements and Federal reports; (2) Maintain accountability over assets; and (3) Demonstrate compliance with Federal statutes, regulations, and the terms and conditions of the Federal award; (b) Transactions are executed in compliance with: (1) Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program; and (2) Any other Federal statutes and regulations that are identified in the Compliance Supplement; and (c) Funds, property, and other assets are safeguarded against loss from unauthorized use or disposition. Cause: Due to turnover at the Organization and its fiscal service providers, there were inconsistencies in internal controls and processes to code expenditures under the proper SSVF grant in prior years, which had a carry-over effect into this fiscal year for multi-year grants. Effect: As a result of the matter identified in the condition paragraph, a significant deficiency in the Organization’s internal controls over compliance and a non-material non-compliance exists. Recommendation: We recommend the Organization continue to implement procedures to ensure it is recording expenditures in a consistent basis to provide adequate accountability of federal funds and properly support expenditure reports submitted to the funding source. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
Corrective Action: This finding was resolved as of February 2024. The issues related to fiscal management of the SSVF (VA) grant in 2022 and 2023 meant that this finding carried over into the FY 24 audit. In October of 2023, CAPO hired a full time Finance and Grants Manager, and in February of 2024, we hired a full time SSVF Accounts Coordinator (reporting to the Finance Manager) to assume all fiscal tasks for SSVF. All invoicing, PMS draws, and overall grant tracking are provided and managed by this new fiscal team. This has significantly improved the pace of invoicing and payments to subrecipients, as well as the accuracy of coding and timeliness of fund draws. Prior to 2024, there were up to 5 separate grants flowing from the VA simultaneously, making it challenging to track draws separately, across six subrecipients. The inability to fully reconcile final grant expenditures in the SEFA was compounded by the VA’s tendency to extend (without formal contract modification) periods of program performance, meaning that grants would roll across CAPO fiscal years, unexpectedly and inconsistently. We now have just two SSVF grants, with distinct staffing for distinct purposes. We hold monthly fiscal meetings with grant subrecipients and have increased requirements on them for timely invoicing, appropriate documentation of expenditures, and overall grant management. Persons Responsible: Janet Allanach, Executive Director and Shane Melton, Finance Manager Timing for Implementation: Complete
2023-002
FAC accepted this audit on April 1, 2024 — management decision was due October 1, 2024.
The condition described in finding 2023-001 in the financial statement findings section represents a significant deficiency in internal controls over the allowable costs and reporting compliance requirements for the Organization’s major program. Criteria: 2 CFR 200, Section 200.303 (Uniform Guidance) requires the following: The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and terms and conditions of the Federal award.
Show full finding ▾Hide full finding ▴Finding Number: 2023-001 Description: Review of Account Reconciliations and Financial Statements Repeat Finding: Yes Type of Finding: Significant deficiency in internal controls over the allowable costs and reporting compliance requirements Questioned Costs: None Major Program: AL # 64.033, VA Supportive Services for Veteran Families Program, 2020-OR-430-22; 2020-OR-430-LT; 2020-OR-430-HL; 2020-OR-430-23; 2020-OR-430-SS Condition: The condition described in finding 2023-001 in the financial statement findings section represents a significant deficiency in internal controls over the allowable costs and reporting compliance requirements for the Organization’s major program. Criteria: 2 CFR 200, Section 200.303 (Uniform Guidance) requires the following: The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and terms and conditions of the Federal award.
Corrective Action: Susan Matlack Jones (SMJ) took over as CAPO’s fiscal service provider in July of 2022. The first six months were spent largely cleaning and correcting journal entries from FY22 – a significant task. CAPO did not begin to receive truly accurate and trustworthy financial statements until early in 2023. CAPO also experienced two staff losses in the finance department from March through May of 2023. In light of our growth and increased administrative needs, we revised our job posting to increase the level of fiscal skill and responsibility needed for the Finance Manager role. In September of 2023, CAPO was successful in hiring a Finance and Grants Manager with experience in federal fund accounting for Community Action and in SSVF (our major grant). Since that time, he has organized, revamped, and significantly improved internal processes to assure timely review of all finances and reconciliations and works closely with SMJ to assure overall accuracy. Person Responsible: Janet Allanach, CAPO Executive Director Timing for Implementation: Complete as of October 2023
2022-001
The Organization records its transactions in a general ledger system capable of segregating revenue and expenses by grant, but during the audit, we noted there were inconsistencies in how expenses were recorded among the various active VA Supportive Services for Veteran Families (SSVF) grants. Due to these inconsistencies, the agency is not able to reconcile federal expenditures reported on its Federal Financial Reports (FFRs) to specific segments in the general ledger, nor accurately report expenses incurred for each individual SSVF grant on the schedule of expenditures of federal awards. Criteria: 2 CFR 200, Section 200.62 (Uniform Guidance) requires the following: Internal control over compliance requirements for Federal awards means a process implemented by a non-Federal entity designed to provide reasonable assurance regarding the achievement of the following objectives for Federal awards: (a) Transactions are properly recorded and accounted for, in order to: (1) Permit the preparation of reliable financial statements and Federal reports; (2) Maintain accountability over assets; and (3) Demonstrate compliance with Federal statutes, regulations, and the terms and conditions of the Federal award; (b) Transactions are executed in compliance with: (1) Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program; and (2) Any other Federal statutes and regulations that are identified in the Compliance Supplement; and (c) Funds, property, and other assets are safeguarded against loss from unauthorized use or disposition. Cause: Due to turnover at the Organization and its fiscal service providers, there were inconsistencies in internal controls and processes to code expenditures under the proper SSVF grant. Effect: As a result of the matter identified in the condition paragraph, a significant deficiency in the Organization’s internal controls over compliance and a non-material non-compliance exists. Recommendation: We recommend the Organization implements procedures to ensure it is recording expenditures in a consistent basis to provide adequate accountability of federal funds and properly support expenditure reports submitted to the funding source. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Description: Reporting of major program grant expenditures Repeat Finding: No Type of Finding: Significant deficiency in internal controls over the allowable costs and reporting compliance requirements; non-material non-compliance Questioned Costs: None Major Program: AL # 64.033, VA Supportive Services for Veteran Families Program, 2020-OR-430-22; 2020-OR-430-LT; 2020-OR-430-HL; 2020-OR-430-23; 2020-OR-430-SS Condition: The Organization records its transactions in a general ledger system capable of segregating revenue and expenses by grant, but during the audit, we noted there were inconsistencies in how expenses were recorded among the various active VA Supportive Services for Veteran Families (SSVF) grants. Due to these inconsistencies, the agency is not able to reconcile federal expenditures reported on its Federal Financial Reports (FFRs) to specific segments in the general ledger, nor accurately report expenses incurred for each individual SSVF grant on the schedule of expenditures of federal awards. Criteria: 2 CFR 200, Section 200.62 (Uniform Guidance) requires the following: Internal control over compliance requirements for Federal awards means a process implemented by a non-Federal entity designed to provide reasonable assurance regarding the achievement of the following objectives for Federal awards: (a) Transactions are properly recorded and accounted for, in order to: (1) Permit the preparation of reliable financial statements and Federal reports; (2) Maintain accountability over assets; and (3) Demonstrate compliance with Federal statutes, regulations, and the terms and conditions of the Federal award; (b) Transactions are executed in compliance with: (1) Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program; and (2) Any other Federal statutes and regulations that are identified in the Compliance Supplement; and (c) Funds, property, and other assets are safeguarded against loss from unauthorized use or disposition. Cause: Due to turnover at the Organization and its fiscal service providers, there were inconsistencies in internal controls and processes to code expenditures under the proper SSVF grant. Effect: As a result of the matter identified in the condition paragraph, a significant deficiency in the Organization’s internal controls over compliance and a non-material non-compliance exists. Recommendation: We recommend the Organization implements procedures to ensure it is recording expenditures in a consistent basis to provide adequate accountability of federal funds and properly support expenditure reports submitted to the funding source. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
Corrective Action: The fiscal tasks and responsibilities needed to adequately manage all 5 SSVF grants in FY 23 were substantial, and without sufficient staff, it was up to the SSVF Program Manager and an administrative support staff to review invoices, approve sub payments, prepare draw requests for Executive Director approval, and manage overall grant funds. In October of 2023, CAPO hired a full time Finance and Grants Manager, and in February of 2024, we hired a full time SSVF Accounts Coordinator (reporting to the Finance Manager) to assume all fiscal tasks for SSVF. The Program Manager still approves the allowability of subrecipient expenditures, however all invoicing, PMS draws, and overall grant tracking are provided and managed by our new central office fiscal team. This has significantly improved the pace of invoicing and payments to subrecipients, as well as the accuracy of coding and timeliness of fund draws. Person Responsible: Janet Allanach, Executive Director Timing for Implementation: Complete as of February 2024
FAC accepted this audit on January 5, 2024 — management decision was due July 5, 2024.
During the year ended June 30, 2022, the Organization relied on its service provider to perform the accounting and financial reporting functions. Internal controls of the Organization are designed to ensure periodic, timely reviews by management of significant account reconciliations and interim financial statements. During the year, these timely reviews did not consistently occur. In addition, this deficiency contributed to delays in completing the audit which caused the audit package submission to the Federal Audit Clearinghouse to be late. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect misstatements in a timely manner. Cause: The service provider was unable to provide the Organization with timely reconciliations or financial statements throughout the year. The Organization did not take timely action to ensure such information was provided in accordance with their contract with the service provider and designed internal controls. Effect: As a result of the matter identified in the condition paragraph, a significant deficiency exists in the Organization’s internal controls over financial reporting. Recommendation: We recommend the Organization implements procedures to ensure its service providers are meeting the requirements of the contract and to take timely action when, and if, it becomes apparent the required financial information is not provided on a timely basis. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Description: Review of Account Reconciliations and Financial Statements Repeat Finding: No Type of Finding: Significant deficiency in internal controls over the allowable costs and reporting compliance requirements Questioned Costs: None Major Program: AL # 64.033, VA Supportive Services for Veteran Families Program, #20-OR-430 and #20-OR-430-C3 Condition: During the year ended June 30, 2022, the Organization relied on its service provider to perform the accounting and financial reporting functions. Internal controls of the Organization are designed to ensure periodic, timely reviews by management of significant account reconciliations and interim financial statements. During the year, these timely reviews did not consistently occur. In addition, this deficiency contributed to delays in completing the audit which caused the audit package submission to the Federal Audit Clearinghouse to be late. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect misstatements in a timely manner. Cause: The service provider was unable to provide the Organization with timely reconciliations or financial statements throughout the year. The Organization did not take timely action to ensure such information was provided in accordance with their contract with the service provider and designed internal controls. Effect: As a result of the matter identified in the condition paragraph, a significant deficiency exists in the Organization’s internal controls over financial reporting. Recommendation: We recommend the Organization implements procedures to ensure its service providers are meeting the requirements of the contract and to take timely action when, and if, it becomes apparent the required financial information is not provided on a timely basis. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
Corrective Action: Immediately after coming on board in May of 2022, the new Executive Director took action to move CAPO’s fiscal services contract from the current provider to a new accounting firm in Portland, Oregon – Susan Matlack Jones and Associates (SMJ) – as of July 1, 2022. SMJ works with several Community Action agencies in Oregon and their expertise is specifically in nonprofit accounting. They worked to resolve accounting issues from the latter half of FY 22 for the purposes of the audit and currently produce timely, accurate financial statements for CAPO management and Board review. As of October 2023, CAPO has also hired an in-house Finance Manager with experience in Community Action and federal fund accounting. Person Responsible: Janet Allanach, CAPO Executive Director Timing for Implementation: Complete as of July 1, 2022.
During the audit, Wipfli LLP observed one employee whose gross payroll did not correspond to the approved wage rate authorization. The discrepancy was not material to the financial statements or to reported grant expenditures. Criteria: Salaries paid to employees and expensed to the Organization’s funding sources need to be based on approved wage rate authorizations. Cause: An updated wage rate authorization was not maintained by the Organization in this employee’s personnel files. Effect: As a result of the matter identified in the condition paragraph, a significant deficiency exists in the Organization’s internal controls over payroll expense. Recommendation: We recommend the Organization implements procedures to ensure the Organization properly approves and documents changes in pay rates when such changes occur and retain the documentation in the employees’ personnel files. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Description: Review of Account Reconciliations and Financial Statements Repeat Finding: No Type of Finding: Significant deficiency in internal controls over the allowable costs and reporting compliance requirements Questioned Costs: None Major Program: AL # 64.033, VA Supportive Services for Veteran Families Program, #20-OR-430 and #20-OR-430-C3 Condition: During the audit, Wipfli LLP observed one employee whose gross payroll did not correspond to the approved wage rate authorization. The discrepancy was not material to the financial statements or to reported grant expenditures. Criteria: Salaries paid to employees and expensed to the Organization’s funding sources need to be based on approved wage rate authorizations. Cause: An updated wage rate authorization was not maintained by the Organization in this employee’s personnel files. Effect: As a result of the matter identified in the condition paragraph, a significant deficiency exists in the Organization’s internal controls over payroll expense. Recommendation: We recommend the Organization implements procedures to ensure the Organization properly approves and documents changes in pay rates when such changes occur and retain the documentation in the employees’ personnel files. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
Corrective Action: CAPO was unable to locate Board minutes from FY 22 that indicate any increase in compensation for Janet Merrell (prior Executive Director through May 2022). We have been informed by the Board that the last increase was likely prior to 2020, as she had requested additional time off in lieu of additional salary increases. The last record of an evaluation is in the minutes from a Board meeting in August of 2020. Discussion of compensation would have occurred during an Executive Session and would be in the possession of the Secretary at the time and not in CAPO files. Currently, Executive session notes are kept by the Treasurer and will be carefully retained for and accessible to future audits. Person Responsible: CAPO Board of Directors Timing for Implementation: Complete
During the year ended June 30, 2022, the Organization regularly drew down cash from the Payment Management System (PMS) for subrecipient expenditures but did not remit the related payments to the subrecipients in a timely manner. Review of supporting documentation submitted by subrecipients for their expenditures did not occur prior to drawing down the cash from PMS for the related expenditures. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity (2 CFR section 200.305(b)). Cause: The Organization did not ensure its service provider was properly managing subrecipient cash requests and disbursements throughout the year and was not consistently reviewing subrecipient expenditure requests in a timely manner. Effect: As a result of the matter identified in the condition paragraph, a material weakness in the Organization’s internal controls over compliance and a material non-compliance exist for the cash management compliance requirement. Recommendation: We recommend the Organization implements procedures to ensure it is properly managing the timing of subrecipient cash requests and disbursements to comply with the cash management requirement. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Description: Cash Management for Subrecipient Expenditures Repeat Finding: No Type of Finding: Material weakness in internal controls and material non-compliance with the cash management compliance requirement Questioned Costs: None Major Program: AL # 64.033, VA Supportive Services for Veteran Families Program, #20-OR-430 and #20-OR-430-C3. Condition: During the year ended June 30, 2022, the Organization regularly drew down cash from the Payment Management System (PMS) for subrecipient expenditures but did not remit the related payments to the subrecipients in a timely manner. Review of supporting documentation submitted by subrecipients for their expenditures did not occur prior to drawing down the cash from PMS for the related expenditures. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity (2 CFR section 200.305(b)). Cause: The Organization did not ensure its service provider was properly managing subrecipient cash requests and disbursements throughout the year and was not consistently reviewing subrecipient expenditure requests in a timely manner. Effect: As a result of the matter identified in the condition paragraph, a material weakness in the Organization’s internal controls over compliance and a material non-compliance exist for the cash management compliance requirement. Recommendation: We recommend the Organization implements procedures to ensure it is properly managing the timing of subrecipient cash requests and disbursements to comply with the cash management requirement. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
Corrective Action: The lack of timeliness in payouts to SSVF subrecipients was largely due to the transition CAPO underwent in fiscal providers in 2022, and to a lack of sufficient internal staff to adequately manage the SSVF program’s growing fiscal requirements. The amount of SSVF funding CAPO passes through has increased significantly since 2021, and existing staffing was insufficient to assure timely tracking of draws and payments. Since moving to SMJ and hiring a Finance Manager, CAPO has improved the fiscal management of this grant considerably. CAPO is also hiring an Account Specialist to be assigned directly to SSVF invoicing and accounting needs. They will be charged to the VA grant and will work with the SSVF Program Manager and CAPO’s Finance Manager to process invoices, draw funds, and issue payments. Person Responsible: Janet Allanach, Rose Bradshaw, SSVF Program Manager; Shane Melton, Finance Manager. Timing for Implementation: Partially complete/In progress until December 31st, 2023, completion.
FAC accepted this audit on August 7, 2022 — management decision was due February 7, 2023.
FAC accepted this audit on March 7, 2021 — management decision was due September 7, 2021.
FAC accepted this audit on March 8, 2020 — management decision was due September 8, 2020.
FAC accepted this audit on February 24, 2019 — management decision was due August 24, 2019.
FAC accepted this audit on February 19, 2018 — management decision was due August 19, 2018.
FAC accepted this audit on February 13, 2017 — management decision was due August 13, 2017.
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