EIN: 300191594
UEI: HJMMWSP91WE1
Audited by: Aldrich CPAs + Advisors LLP
Oversight agency: 14 [Department of Housing and Urban Development]
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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 March 26, 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 September 26, 2026 (27 days from today).
What is a management decision? →FAC accepted this audit on April 15, 2025 — management decision was due October 15, 2025.
FAC accepted this audit on April 13, 2025 — management decision was due October 13, 2025.
FAC accepted this audit on October 18, 2022 — management decision was due April 18, 2023.
FAC accepted this audit on October 10, 2021 — management decision was due April 10, 2022.
During our audit we inquired with management regarding their procurement policy noting that the procurement policy was implemented September 1, 2020. The terms of the policy state that preferred vendors are to be reviewed quarterly to ensure none are suspended or debarred. While the policy was implemented in September 2020, there was no documentation of review of the suspension or debarment until April 2021. Cause: This area was considered low risk to the Organization in the prior year as the priority and attention shifted to COVID rental assistance programs and resident safety during the fiscal year. Only one new vendor was added during the year as the result of an acquisition, and as such, was considered low risk. The current vendor relationships were long term and in good standing resulting in a low risk assessment. As a result, vendors were not reviewed for suspension and debarment until the fourth quarter. Effect: Deviation from the policy in place could result in payment to suspended or debarred entities. Recommendation: The Organization should review the policy to determine it is appropriate for the entity and amend the policy or adhere to the policy as documented. Questioned Costs: None Response: Management has reviewed the current policy and determined that quarterly review of vendors was too frequent given the low risk of vendors for noncompliance. Most vendors are either utilities, large MRO suppliers, or established long-term vendors. A modification to the policy has been drafted to change the quarterly review to no less than annually.
Show full finding ▾Hide full finding ▴2021-001 CFDA 14.181 Supportive Housing for Persons with Disabilities (Repeat Finding 2020-001) Criteria: The Uniform Guidance requires that for covered transactions the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded. Condition: During our audit we inquired with management regarding their procurement policy noting that the procurement policy was implemented September 1, 2020. The terms of the policy state that preferred vendors are to be reviewed quarterly to ensure none are suspended or debarred. While the policy was implemented in September 2020, there was no documentation of review of the suspension or debarment until April 2021. Cause: This area was considered low risk to the Organization in the prior year as the priority and attention shifted to COVID rental assistance programs and resident safety during the fiscal year. Only one new vendor was added during the year as the result of an acquisition, and as such, was considered low risk. The current vendor relationships were long term and in good standing resulting in a low risk assessment. As a result, vendors were not reviewed for suspension and debarment until the fourth quarter. Effect: Deviation from the policy in place could result in payment to suspended or debarred entities. Recommendation: The Organization should review the policy to determine it is appropriate for the entity and amend the policy or adhere to the policy as documented. Questioned Costs: None Response: Management has reviewed the current policy and determined that quarterly review of vendors was too frequent given the low risk of vendors for noncompliance. Most vendors are either utilities, large MRO suppliers, or established long-term vendors. A modification to the policy has been drafted to change the quarterly review to no less than annually.
Finding No. 2021-001 - Section 811, CFDA 14.181 Recommendation - The Organization should review the policy to determine if it is appropriate for the entity and amend the policy or adhere to the policy as documented. Planned Corrective Action - Management has reviewed the current policy and determined that quarterly review of vendors was too frequent given the low risk of vendors for noncompliance. A modification to the policy has been drafted to change the quarterly review to no less than annually.
2020-001
FAC accepted this audit on October 8, 2020 — management decision was due April 8, 2021.
During our audit we inquired with management regarding their procurement policy and identified that Pioneer Abodes, Ltd. did not have an approved, documented procurement policy in place as of July 1, 2017, which was the required date. They have a capital purchases policy in place, but it does not cover all of the required criteria in 2 CFR part 200. They also do not have a policy in place to ensure that their vendors are not suspended or debarred. Context: The procurement policy provides guidance and requirements that must be followed for all procurements, but specifically any procurements related to federal awards. Ensuring that the Organization?s vendors are not suspended or debarred should be part of the expense approval process, not just something done for new vendors. Aldrich tested a selection of expenses to determine if any of the selected vendors were suspended or debarred. None were identified in this testing. Cause: Management was not aware of the requirement to have a written policy in place for procurement or the requirement to verify that vendors were not suspended or debarred at the original implementation date. Effect: The Organization has been following their internal policies regarding procurement which are in line with the Uniform Guidance and we did not identify any instances of noncompliance related to actual purchases or suspension and debarment. They have developed a draft procurement policy, but it was not implemented as of June 30, 2020. This is a compliance finding related to procurement, suspension, and debarment. Recommendation: We recommend that the Organization implement the draft procurement policy immediately in order to be in compliance with the Uniform Grant Guidance. The Organization should also implement controls over compliance related to suspension and debarment. Questioned Costs: None Response: Management has developed a procurement policy that follows the standards outlined in 2 CRF part 200. The policy was implemented and effective September 1, 2020.
Show full finding ▾Hide full finding ▴2020-001 CFDA 14.181 Supportive Housing for Persons with Disabilities (Repeat Finding 2019-001) Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statues and the procurement requirements identified in 2 CFR part 200. The Uniform Guidance also requires that for covered transactions the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded. Condition: During our audit we inquired with management regarding their procurement policy and identified that Pioneer Abodes, Ltd. did not have an approved, documented procurement policy in place as of July 1, 2017, which was the required date. They have a capital purchases policy in place, but it does not cover all of the required criteria in 2 CFR part 200. They also do not have a policy in place to ensure that their vendors are not suspended or debarred. Context: The procurement policy provides guidance and requirements that must be followed for all procurements, but specifically any procurements related to federal awards. Ensuring that the Organization?s vendors are not suspended or debarred should be part of the expense approval process, not just something done for new vendors. Aldrich tested a selection of expenses to determine if any of the selected vendors were suspended or debarred. None were identified in this testing. Cause: Management was not aware of the requirement to have a written policy in place for procurement or the requirement to verify that vendors were not suspended or debarred at the original implementation date. Effect: The Organization has been following their internal policies regarding procurement which are in line with the Uniform Guidance and we did not identify any instances of noncompliance related to actual purchases or suspension and debarment. They have developed a draft procurement policy, but it was not implemented as of June 30, 2020. This is a compliance finding related to procurement, suspension, and debarment. Recommendation: We recommend that the Organization implement the draft procurement policy immediately in order to be in compliance with the Uniform Grant Guidance. The Organization should also implement controls over compliance related to suspension and debarment. Questioned Costs: None Response: Management has developed a procurement policy that follows the standards outlined in 2 CRF part 200. The policy was implemented and effective September 1, 2020.
Finding No. 2020-001 - Section 811, CFDA 14.181 Recommendation - The Organization implement the draft procurement policy immediately in order to be in compliance with the Uniform Grant Guidance. The Organization should also implement controls over compliance related to suspension and debarment. Planned Corrective Action ? The Organization has implemented the procurement policy that was in draft form as of 6/30/20. The procurement policy was implemented and effective September 1, 2020.
2019-001
FAC accepted this audit on September 29, 2019 — management decision was due March 29, 2020.
During our audit we inquired with management regarding their procurement policy and identified that Pioneer Abodes, Ltd. did not have an approved, documented procurement policy in place as of July 1, 2017, which was the required date. They have a capital purchases policy in place, but it does not cover all of the required criteria in 2 CFR part 200. They also do not have a policy in place to ensure that their vendors are not suspended or debarred. Context: The procurement policy provides guidance and requirements that must be followed for all procurements, but specifically any procurements related to federal awards. Ensuring that the Organization?s vendors are not suspended or debarred should be part of the expense approval process, not just something done for new vendors. Aldrich tested a selection of expenses to determine if any of the selected vendors were suspended or debarred. None were identified in this testing. Cause: Management was not aware of the requirement to have a written policy in place for procurement or the requirement to verify that vendors were not suspended or debarred. Effect: The Organization has been following their internal policies regarding procurement which are in line with the Uniform Guidance and we did not identify any instances of noncompliance related to actual purchases or suspension and debarment. This is a compliance finding related to procurement, suspension, and debarment. Recommendation: We recommend that the Organization develop, adopt and implement a procurement policy immediately in order to be in compliance with the Uniform Grant Guidance. The Organization should also implement controls over compliance related to suspension and debarment. Questioned Costs: None Response: HUD has performed numerous audits with the last one being September 2018. The Organization received 100% on that audit with no comments which included a review of the procurement policy. Management interpreted the receipt of the pass rating as the current policy in place was acceptable. The Organization will document an all-inclusive Procurement Policy that reflects HUD and UGG requirements regarding procurement. The Procurement Policy will include internal controls required to cover suspension and debarment. The Organization will educate all employees of the Procurement Policy including suspension and debarment criteria and monitor adherence to the policy.
Show full finding ▾Hide full finding ▴2019-001 CFDA 14.181 Supportive Housing for Persons with Disabilities Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statues and the procurement requirements identified in 2 CFR part 200. The Uniform Guidance also requires that for covered transactions the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded. Condition: During our audit we inquired with management regarding their procurement policy and identified that Pioneer Abodes, Ltd. did not have an approved, documented procurement policy in place as of July 1, 2017, which was the required date. They have a capital purchases policy in place, but it does not cover all of the required criteria in 2 CFR part 200. They also do not have a policy in place to ensure that their vendors are not suspended or debarred. Context: The procurement policy provides guidance and requirements that must be followed for all procurements, but specifically any procurements related to federal awards. Ensuring that the Organization?s vendors are not suspended or debarred should be part of the expense approval process, not just something done for new vendors. Aldrich tested a selection of expenses to determine if any of the selected vendors were suspended or debarred. None were identified in this testing. Cause: Management was not aware of the requirement to have a written policy in place for procurement or the requirement to verify that vendors were not suspended or debarred. Effect: The Organization has been following their internal policies regarding procurement which are in line with the Uniform Guidance and we did not identify any instances of noncompliance related to actual purchases or suspension and debarment. This is a compliance finding related to procurement, suspension, and debarment. Recommendation: We recommend that the Organization develop, adopt and implement a procurement policy immediately in order to be in compliance with the Uniform Grant Guidance. The Organization should also implement controls over compliance related to suspension and debarment. Questioned Costs: None Response: HUD has performed numerous audits with the last one being September 2018. The Organization received 100% on that audit with no comments which included a review of the procurement policy. Management interpreted the receipt of the pass rating as the current policy in place was acceptable. The Organization will document an all-inclusive Procurement Policy that reflects HUD and UGG requirements regarding procurement. The Procurement Policy will include internal controls required to cover suspension and debarment. The Organization will educate all employees of the Procurement Policy including suspension and debarment criteria and monitor adherence to the policy.
Recommendation ? The Organization should expand on the current documentation that is being followed and adopt uniform Procurement procedures and suspension and debarment procedures that are in line with HUD requirements and details the approval level requirements for purchases. Planned Corrective Action ? The Organization will document an all-inclusive Procurement Policy that reflects HUD requirements regarding procurement. The Procurement Policy will include the internal controls required to cover suspension and debarment. The company will educate all employees regarding the Procurement policy including suspension and debarment criteria and monitor adherence to the policy.
Based on our audit procedures tenant deposits and reserve funds were not held in interest bearing bank accounts. Context: Management understood this to be an optional practice not something that was mandated by the various compliance guidance. Cause: Management did not understand this to be a required compliance item. Effect: There is lost earning to the tenants on their deposits which is dependent on how long the funds have been held by the Organization. Recommendation: We recommend that the Organization review the appropriate documentation and their regulatory agreement to determine the appropriate action necessary in order to be in compliance. We also recommend that management contact HUD to determine if any additional steps need to be taken regarding past amounts. Questioned Costs: Unknown Response: HUD has performed numerous audits with the last one being September 2018. The Organization received 100% on that audit with no comments. Included was a review of the MOR Desk Review where Item #17 on the Desk Review regarding interest on security deposit accounts clearly says in the comments: ?Not in interest bearing accounts?. Management interpreted that as being acceptable. The Organization will open new interest bearing accounts and will transfer existing monies in Pioneer Abodes, Ltd. tenant deposits to the new interest-bearing accounts. The Organization will track the security deposit account interest by resident and will distribute the interest to the residents account on a monthly basis according to HUD regulations.
Show full finding ▾Hide full finding ▴2019-002 CFDA 14.181 Supportive Housing for Persons with Disabilities Criteria: According to the Regulatory Agreement section 7f security deposits must be maintained in a separate FDIC, interest-bearing account. All interest earned shall be allocated to the tenants in proportion to their deposits and paid upon move out or utilized against outstanding debt for rent or damages. According to chapter 25 of the HUD Multifamily Asset Management and Project Servicing handbook (4350.1) the residual receipts of all projects with HUD-insured mortgages should be invested with interest accruing from the investments credited to the Residual Receipt account. According to the compliance supplement for this program issued by OMB the replacement reserve funds must be deposited in federally insured interest bearing accounts and all earnings must be added to the reserve. Condition: Based on our audit procedures tenant deposits and reserve funds were not held in interest bearing bank accounts. Context: Management understood this to be an optional practice not something that was mandated by the various compliance guidance. Cause: Management did not understand this to be a required compliance item. Effect: There is lost earning to the tenants on their deposits which is dependent on how long the funds have been held by the Organization. Recommendation: We recommend that the Organization review the appropriate documentation and their regulatory agreement to determine the appropriate action necessary in order to be in compliance. We also recommend that management contact HUD to determine if any additional steps need to be taken regarding past amounts. Questioned Costs: Unknown Response: HUD has performed numerous audits with the last one being September 2018. The Organization received 100% on that audit with no comments. Included was a review of the MOR Desk Review where Item #17 on the Desk Review regarding interest on security deposit accounts clearly says in the comments: ?Not in interest bearing accounts?. Management interpreted that as being acceptable. The Organization will open new interest bearing accounts and will transfer existing monies in Pioneer Abodes, Ltd. tenant deposits to the new interest-bearing accounts. The Organization will track the security deposit account interest by resident and will distribute the interest to the residents account on a monthly basis according to HUD regulations.
Recommendation ? The Organization should open new interest-bearing bank accounts for security deposits. The interest in these accounts will be allocated to the residents impacted. Planned Corrective Action: The Organization will open new interest-bearing accounts and will transfer any existing monies in Pioneer Abodes related security and reserve account to the new interest-bearing accounts. The Organization will track the security deposit account interest by resident and will distribute the interest to the residents account on a monthly basis according to HUD regulations.
For the year ended June 30, 2018, the data collection form was not submitted within the required timeline. Context: The Organization received the audit report dated September 4, 2018, but the data collection form was not submitted until October 25, 2018. There were complications in the timing of the board meetings for final approval and submission of the report. As a result, the deadline for filing was missed. Cause: There were delays in meeting with the board of directors to approve the report and submission. Effect: This is considered a significant deficiency in controls over compliance as well as a compliance finding. This deficiency resulted in the Organization not being a low risk auditee for the next two years. Recommendation: Now that the Organization understands the timeline and required due dates, we recommend that there be a control implemented that will ensure that the data collection form is submitted timely. Response: The Organization will ensure that the audit reporting package is filed on time this year and will implement follow up checks to ensure the audit reporting package is submitted on time per the requirements of 2 CFR 200.12.
Show full finding ▾Hide full finding ▴2019-003 Criteria: The audit package and the data collection form shall be submitted 30 days after receipt of the auditors? report(s), or 9 months after the end of the fiscal year, whichever comes first. Condition: For the year ended June 30, 2018, the data collection form was not submitted within the required timeline. Context: The Organization received the audit report dated September 4, 2018, but the data collection form was not submitted until October 25, 2018. There were complications in the timing of the board meetings for final approval and submission of the report. As a result, the deadline for filing was missed. Cause: There were delays in meeting with the board of directors to approve the report and submission. Effect: This is considered a significant deficiency in controls over compliance as well as a compliance finding. This deficiency resulted in the Organization not being a low risk auditee for the next two years. Recommendation: Now that the Organization understands the timeline and required due dates, we recommend that there be a control implemented that will ensure that the data collection form is submitted timely. Response: The Organization will ensure that the audit reporting package is filed on time this year and will implement follow up checks to ensure the audit reporting package is submitted on time per the requirements of 2 CFR 200.12.
Recommendation ? The Organization should implement a control that will ensure that the audit reporting package is submitted to the Federal Clearinghouse per the requirements of 2 CFR 200.512. Planned Corrective Action ? The Organization will ensure that the audit reporting package is filed on time this year and will implement follow up checks to ensure the audit reporting package is submitted on time per the requirements of 2 CFR 200.512.
FAC accepted this audit on October 24, 2018 — management decision was due April 24, 2019.
FAC accepted this audit on September 27, 2017 — management decision was due March 27, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on September 19, 2016 — management decision was due March 19, 2017.
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