EIN: 300878820
UEI: JVUKLUBLPYK4
Audited by: CliftonLarsonAllen LLP
Oversight agency: 84 [Department of Education]
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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 February 6, 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 August 6, 2026 (32 days ago).
What is a management decision? →Verification that vendor was not suspended/debarred from receiving federal funds was not performed prior to procurement, as required for compliance with 2 CFR section 180. Questioned costs: None. Context: Management was not aware of the requirement resulting in noncompliance in 2 (of 3) selections tested. Cause: Management was not aware of the requirement at the time of procurement. Effect: Increased risk of contracting with vendors who are suspended or debarred from receiving federal funds. Repeat Finding: Yes (2024-001). Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Education Innovation and Research Assistance Listing Number: 84.411 Federal Award Identification Number and Year: Various Award Period: Various Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matter Criteria or specific requirement: 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: Verification that vendor was not suspended/debarred from receiving federal funds was not performed prior to procurement, as required for compliance with 2 CFR section 180. Questioned costs: None. Context: Management was not aware of the requirement resulting in noncompliance in 2 (of 3) selections tested. Cause: Management was not aware of the requirement at the time of procurement. Effect: Increased risk of contracting with vendors who are suspended or debarred from receiving federal funds. Repeat Finding: Yes (2024-001). Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Views of responsible officials: There is no disagreement with the audit finding.
EIR Program – Early-Phase Grants Assistance Listing No. 84.411 Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: (1) Management incorporated new proactive suspension/debarment certification clause into contractor agreements for vendors providing services on federally-funded projects. (2) Management may also supplement certification clause above with additional manual sam.gov search for select larger vendor contracts. (3) Plan to incorporate regular reminders and/or trainings re: these ongoing compliance requirements to select team members working on federally-funded projects and responsible for major purchasing, ops, and/or contracting activities. Name(s) of the contact person(s) responsible for corrective action: Trevor Bynoe, Managing Director of Finance, 571-435-4816
2024-001
FAC accepted this audit on February 12, 2025 — management decision was due August 12, 2025.
Verification that vendor was not suspended/debarred from receiving federal funds was not performed prior to procurement, as required for compliance with 2 CFR section 180. Questioned costs: None. Context: Management was not aware of the requirement resulting in noncompliance in 5 (of 5) selections tested. Cause: Management was not aware of the requirement at the time of procurement. Effect: Increased risk of contracting with vendors who are suspended or debarred from receiving federal funds. Repeat Finding: N/A. Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: EIR Program – Early-Phase Grants Assistance Listing Number: 84.411C Federal Award Identification Number and Year: S411C210073 - 2021 Award Period: 12/15/2021 – 12/15/2026 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matter Criteria or specific requirement: 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: Verification that vendor was not suspended/debarred from receiving federal funds was not performed prior to procurement, as required for compliance with 2 CFR section 180. Questioned costs: None. Context: Management was not aware of the requirement resulting in noncompliance in 5 (of 5) selections tested. Cause: Management was not aware of the requirement at the time of procurement. Effect: Increased risk of contracting with vendors who are suspended or debarred from receiving federal funds. Repeat Finding: N/A. Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Views of responsible officials: There is no disagreement with the audit finding.
EIR Program – Early-Phase Grants Assistance Listing No. 84.411C Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: (1) Management incorporated new proactive suspension/debarment certification clause into contractor agreements for vendors providing services on federally-funded projects. (2) Management may also supplement certification clause above with additional manual sam.gov search for select larger vendor contracts. (3) Plan to incorporate regular reminders and/or trainings re: these ongoing compliance requirements to select team members working on federally-funded projects and responsible for major purchasing, ops, and/or contracting activities. Name(s) of the contact person(s) responsible for corrective action: Trevor Bynoe, Managing Director of Finance, 571-435-4816
FAC accepted this audit on November 4, 2025 — management decision was due May 4, 2026.
Verification that vendor was not suspended/debarred from receiving federal funds was not performed prior to procurement, as required for compliance with 2 CFR section 180. Questioned costs: None. Context: Management was not aware of the requirement resulting in noncompliance in 5 (of 5) selections tested. Cause: Management was not aware of the requirement at the time of procurement. Effect: Increased risk of contracting with vendors who are suspended or debarred from receiving federal funds. Repeat Finding: N/A. Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: EIR Program – Early-Phase Grants Assistance Listing Number: 84.411C Federal Award Identification Number and Year: S411C210073 - 2021 Award Period: 12/15/2021 – 12/15/2026 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matter Criteria or specific requirement: 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: Verification that vendor was not suspended/debarred from receiving federal funds was not performed prior to procurement, as required for compliance with 2 CFR section 180. Questioned costs: None. Context: Management was not aware of the requirement resulting in noncompliance in 5 (of 5) selections tested. Cause: Management was not aware of the requirement at the time of procurement. Effect: Increased risk of contracting with vendors who are suspended or debarred from receiving federal funds. Repeat Finding: N/A. Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Views of responsible officials: There is no disagreement with the audit finding.
EIR Program – Early-Phase Grants Assistance Listing No. 84.411C Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: (1) Management incorporated new proactive suspension/debarment certification clause into contractor agreements for vendors providing services on federally-funded projects. (2) Management may also supplement certification clause above with additional manual sam.gov search for select larger vendor contracts. (3) Plan to incorporate regular reminders and/or trainings re: these ongoing compliance requirements to select team members working on federally-funded projects and responsible for major purchasing, ops, and/or contracting activities. Name(s) of the contact person(s) responsible for corrective action: Trevor Bynoe, Managing Director of Finance, 571-435-4816
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