EIN: 351072577
UEI: GJBAYEKFGLZ4
Audited by: Sikich CPA LLC
Oversight agency: 84 [Department of Education]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 30, 2025. 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 March 30, 2026 (162 days ago).
What is a management decision? →During our testing of federal expenditures, we noted that certain expenses were not allowable activities under the Uniform Guidance. Cause: Internal controls surrounding the review of supporting documentation of expenditures charged to grants are not properly implemented to detect and correct errors. Effect: The Organization received reimbursement for unallowable expenditures. Questioned Costs: ALN 84.215J - $18,603 Recommendation: We recommend that management of the Organization review internal controls over compliance and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2024-001- Significant Deficiency: Activities Allowed or Unallowable Costs/Cost Principles Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E. Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, 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 the terms and conditions of the Federal award. Condition: During our testing of federal expenditures, we noted that certain expenses were not allowable activities under the Uniform Guidance. Cause: Internal controls surrounding the review of supporting documentation of expenditures charged to grants are not properly implemented to detect and correct errors. Effect: The Organization received reimbursement for unallowable expenditures. Questioned Costs: ALN 84.215J - $18,603 Recommendation: We recommend that management of the Organization review internal controls over compliance and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
The purchase of the grant management system will interface directly with the organization’s accounting software, allowing for the automated extraction of financial data. This data will be systematically mapped to the corresponding budgetary lines of each grant to ensure accurate tracking and reporting. On a monthly basis, the Financial Grant Coordinator will collaborate with Senior Directors and Program Directors to review financial activity. These reviews aim to verify that expenditure aligns with the allowable costs defined by each grant, ensuring full compliance with funding requirements. Corrective: Budget vs. actual reviews are conducted with senior directors to evaluate financial performance and ensure alignment with programmatic, administrative guidelines, and funding guidelines. During these reviews, directors assess which costs are permissible and identify any expenditure that falls outside allowable parameters. Non-compliant costs are reallocated to appropriate programs that permit such expenses or to administrative accounts as necessary.
2023-003
During our audit procedures, we noted that the Organization incurred expenditures in excess of the approved amounts within certain budget categories. The reallocation of funds between these categories exceeded the allowable threshold of 10%, as stipulated in the grant agreement, without obtaining the required prior approval. Cause: The Organization’s internal controls over compliance related to the review and reconciliation of budgeted amounts against actual expenditures charged to the grant were not adequately designed or implemented to detect and prevent variances. Effect: As a result, costs submitted for reimbursement exceeded the approved budgetary limits for certain budget line items established in the grant agreement, rendering a portion of the expenditures unallowable under federal regulations. Questioned Costs: None Recommendation: We recommend that the Organization’s management evaluate and strengthen internal control over compliance procedures to ensure expenditures consistently comply with federal cost principles and remain within approved budget line items. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2024-002: Significant Deficiency: Activities Allowed or Unallowable Costs/Cost Principles Criteria: In accordance with federal regulations, expenditures charged to federal awards must comply with the allowable cost principles outlined in 2 CFR Part 200, Subpart E. Furthermore, recipients and subrecipients are required to operate within the parameters of the approved budget as specified in the grant agreement. Any budgetary revisions must receive prior written approval from the awarding federal agency or pass-through entity, pursuant to 2 CFR § 200.308. Section III: Federal Award Findings and Questioned Costs (Continued) 2024-002: Significant Deficiency: Activities Allowed or Unallowable Costs/Cost Principles (Continued) Condition: During our audit procedures, we noted that the Organization incurred expenditures in excess of the approved amounts within certain budget categories. The reallocation of funds between these categories exceeded the allowable threshold of 10%, as stipulated in the grant agreement, without obtaining the required prior approval. Cause: The Organization’s internal controls over compliance related to the review and reconciliation of budgeted amounts against actual expenditures charged to the grant were not adequately designed or implemented to detect and prevent variances. Effect: As a result, costs submitted for reimbursement exceeded the approved budgetary limits for certain budget line items established in the grant agreement, rendering a portion of the expenditures unallowable under federal regulations. Questioned Costs: None Recommendation: We recommend that the Organization’s management evaluate and strengthen internal control over compliance procedures to ensure expenditures consistently comply with federal cost principles and remain within approved budget line items. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
The purchase of the grant management system will interface directly with the organization’s accounting software, allowing for the automated extraction of financial data. This data will be systematically mapped to the corresponding budgetary lines of each grant to ensure accurate tracking and reporting. On a monthly basis, the Financial Grant Coordinator will collaborate with Senior Directors and Program Directors to review financial activity. These reviews aim to verify that expenditure aligns with the allowable costs defined by each grant, ensuring full compliance with funding requirements. Corrective: Budget vs. actual reviews are conducted with senior directors to evaluate financial performance and ensure alignment with programmatic, administrative, and funding guidelines. During these reviews, directors assess which costs are permissible and identify any expenditure that falls outside allowable parameters. Non-compliant costs are reallocated to appropriate programs that permit such expenses or to administrative accounts as necessary.
2023-004
During the audit the Organization submitted the December 31, 2023 required reporting package to the FAC 167 days past the deadline without an approved extension from the oversight agency. Cause: The Organization had not implemented policies or procedures, to the degree necessary, to ensure that the audit, data collection form, and reporting package was complete, accurate, and submitted within the required time frame. Effect: The Organization was not in compliance with federal regulations. Section III: Federal Award Findings and Questioned Costs (Continued) 2024-003: Significant Deficiency: Reporting (Continued) Recommendation: We recommend that management of the Organization implement policies, procedures, and internal controls over compliance to ensure that required federal reporting is timely and in accordance with federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2024-003: Significant Deficiency: Reporting Criteria: The Code of Federal Regulations (CFR) section 200.510 (b) states that the audit, the data collection form, and the reporting package must be submitted within 30 calendar days after the auditee receives the auditor's report(s) or nine months after the end of the audit period (whichever is earlier) to the Federal Audit Clearinghouse (FAC). Condition: During the audit the Organization submitted the December 31, 2023 required reporting package to the FAC 167 days past the deadline without an approved extension from the oversight agency. Cause: The Organization had not implemented policies or procedures, to the degree necessary, to ensure that the audit, data collection form, and reporting package was complete, accurate, and submitted within the required time frame. Effect: The Organization was not in compliance with federal regulations. Section III: Federal Award Findings and Questioned Costs (Continued) 2024-003: Significant Deficiency: Reporting (Continued) Recommendation: We recommend that management of the Organization implement policies, procedures, and internal controls over compliance to ensure that required federal reporting is timely and in accordance with federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
The Code of Federal Regulations (CFR) section 200.510 (b) states that the audit, the data collection form, and the reporting package must be submitted within 30 calendar days after the auditee receives the auditor's report(s) or nine months after the end of the audit period (whichever is earlier) to the Federal Audit Clearinghouse (FAC). Corrective: Policies, procedures, and internal controls have been implemented to ensure that all required federal reporting is submitted timely to the Federal Audit Clearinghouse (FAC), in accordance with the Code of Federal Regulations (CFR), Title 2, Section 200.510(b).
FAC accepted this audit on March 13, 2025 — management decision was due September 13, 2025.
During the audit of the December 31, 2023 Schedule of Expenditures of Federal Awards (SEFA) prepared by management, we noted that controls over the preparation of the SEFA were not properly designed, therefore did not include the required federal award information and did not report all 2023 federal awards and related expenditures. Cause: The Organization has not implemented policies or procedures, to the degree necessary, to ensure that the SEFA is reconciled at year-end and that the schedule includes all federal awards and related expenditures. Effect: Audit procedures identified additional federal award expenditures and adjustments were required to be made to the final SEFA. Recommendation: We recommend that management of the Organization implement policies, procedures, and internal controls to ensure that federal expenditures are tracked in a manner that reflects that federal funds have been used and reported in accordance with federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2023-002: Material Weakness: Preparation of Schedule of Expenditures of Federal Awards Criteria: The Code of Federal Regulations (CFR) section 200.510 (b) states that, the auditee must prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee's financial statements and must include the total federal awards expended as determined in accordance with section 200.502- Financial Management and must include at minimum the following: (1) list of individual federal programs by federal agency (2) for federal awards received as a subrecipient, the name and number of the pass-through entity (3) federal awards expended for each individual federal program and the Assistance Listings Number (4) include the total amount provided to subrecipients from each Federal program. (5) include notes that describe significant accounting policies used in preparing the schedule, loan or loan guarantee programs, and whether the auditee elected to use the 10% de minimis cost rate. Financial management section 200.502 (a) states that the auditee’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. (b) The financial management system must provide for the following: (1) identification of all federal awards received and expended (2) accurate, current, and complete disclosure of the financial results of each federal award or program (3) records that identify adequately the source and application of funds for federally-funded activities (4) effective control over, and accountability for, all funds, property, and other assets (5) comparison of expenditures with budget amounts for each Federal award (6) written procedures to implement the requirements of section 200.305 (7) written procedures for determining the allowability of costs in accordance with Subpart E and the terms and conditions of the federal award. Condition: During the audit of the December 31, 2023 Schedule of Expenditures of Federal Awards (SEFA) prepared by management, we noted that controls over the preparation of the SEFA were not properly designed, therefore did not include the required federal award information and did not report all 2023 federal awards and related expenditures. Cause: The Organization has not implemented policies or procedures, to the degree necessary, to ensure that the SEFA is reconciled at year-end and that the schedule includes all federal awards and related expenditures. Effect: Audit procedures identified additional federal award expenditures and adjustments were required to be made to the final SEFA. Recommendation: We recommend that management of the Organization implement policies, procedures, and internal controls to ensure that federal expenditures are tracked in a manner that reflects that federal funds have been used and reported in accordance with federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
A grant manager and grant-financial coordinator have been hired to work with the finance team to communicate the whole gamut of applicable elements of ASC 606. Also, we are purchasing a grant management system—not a manual Excel sheet- that can scan grants and identify conditions and restrictions.
During our testing of federal expenditures, we noted that certain expenses were not allowable activities under uniform guidance. Cause: Internal controls surrounding the review of supporting documentation of expenditures charged to grants are not properly implemented to detect and correct errors. Effect: The Organization received reimbursement for unallowable expenditures. Questioned Costs: ALN 84.287 - $938 ALN 84.215J - $620 Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2023-003- Significant Deficiency: Activities Allowed or Unallowable Costs/Cost Principles Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E. Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, 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 the terms and conditions of the Federal award. Condition: During our testing of federal expenditures, we noted that certain expenses were not allowable activities under uniform guidance. Cause: Internal controls surrounding the review of supporting documentation of expenditures charged to grants are not properly implemented to detect and correct errors. Effect: The Organization received reimbursement for unallowable expenditures. Questioned Costs: ALN 84.287 - $938 ALN 84.215J - $620 Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
The purchase of the grant management system will pull accounting data from the accounting software and the data will be mapped to the budgetary lines of the grant. Monthly, the financial grant coordinator will work with senior directors and directors to go over the financial information and ensure compliance with allowable cost to respective grants Correctively, budget vs actual reviews with senior directors take place in which directors identify permissible costs or costs that are not, and those costs are adjusted to programs that allow such cost or to admin
2022-003
During our testing, we noted that expenditures were allocated to the wrong budget category line items and did not agree to the underlying accounting records. Cause: Internal controls surrounding the review and reconciliation of supporting documentation to expenditures charged to the grant are not properly implemented to detect and correct errors. Effect: The costs submitted and reimbursed by the grantors did not agree to the budget categories set forth in the grant agreement, therefore the underlying accounting records were not consistent with what was being reported to the grantors. Questioned Costs: None Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2023-004: Significant Deficiency: Activities Allowed or Unallowable Costs/Cost Principles Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E. Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, 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 the terms and conditions of the Federal award. Condition: During our testing, we noted that expenditures were allocated to the wrong budget category line items and did not agree to the underlying accounting records. Cause: Internal controls surrounding the review and reconciliation of supporting documentation to expenditures charged to the grant are not properly implemented to detect and correct errors. Effect: The costs submitted and reimbursed by the grantors did not agree to the budget categories set forth in the grant agreement, therefore the underlying accounting records were not consistent with what was being reported to the grantors. Questioned Costs: None Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
The purchase of the grant management system will pull accounting data from the accounting software, and the data will be mapped to the budgetary lines of the grant. Monthly, the financial grant coordinator will work with senior directors and directors to go over the financial information and ensure compliance with the allowable cost to respective grants Correctively, budget vs actual reviews with senior directors take place in which directors identify permissible costs or costs that are not, and those costs are adjusted to programs that allow such cost or to admin
During our testing of payroll costs, we noted that (1) the Organization’s documentation of time and effort related to the Federal programs did not agree to personnel costs charged to the Federal program (2) the Organization did not properly review and reconcile time and effort records to payroll costs charged to the Federal grant to ensure amounts charged to the grant were allowable costs. Cause: Internal controls surrounding the tracking and review of payroll expenditures charged to Federal programs were not properly implemented to detect and correct errors. Additionally, the grant related payroll tracking was a manual process during 2023, therefore increasing the possibility of error. Effect: The Organization did not properly review and reconcile time and effort records to payroll costs charged to the Federal grant to ensure amounts charged to the grant were allowable costs. Questioned Costs: ALN 84.287 - $3,905 ALN 84.215J - $8,130 Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that time records are reviewed and reconciled to payroll expenditures being charged to the Federal program. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2023-005 - Significant Deficiency: Activities Allowed or Unallowable Costs/Cost Principles Criteria: The Organization is required to have procedures in place to ensure that federal awards are expended for allowable costs in accordance with Subpart E - Cost Principles of Uniform Guidance. The CFR section 200.303 (i) states that, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, 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 the terms and conditions of the Federal award. Condition: During our testing of payroll costs, we noted that (1) the Organization’s documentation of time and effort related to the Federal programs did not agree to personnel costs charged to the Federal program (2) the Organization did not properly review and reconcile time and effort records to payroll costs charged to the Federal grant to ensure amounts charged to the grant were allowable costs. Cause: Internal controls surrounding the tracking and review of payroll expenditures charged to Federal programs were not properly implemented to detect and correct errors. Additionally, the grant related payroll tracking was a manual process during 2023, therefore increasing the possibility of error. Effect: The Organization did not properly review and reconcile time and effort records to payroll costs charged to the Federal grant to ensure amounts charged to the grant were allowable costs. Questioned Costs: ALN 84.287 - $3,905 ALN 84.215J - $8,130 Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that time records are reviewed and reconciled to payroll expenditures being charged to the Federal program. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
In January 2024, we partnered with G&A, which provided services that automated time tracking allocations in the accounting system based on Time and Attendance records placed in the payroll system. This information applies time ratios spent on grants times actual cost from payroll and automatically comes in the accounting system based on project costing (time concerning all time spent on projects). The purchase of the grant management system will pull accounting data from the accounting software, and the data will be mapped to the budgetary lines of the grant. Monthly, the financial grant coordinator will work with senior directors and directors to go over the financial information and ensure compliance with the allowable cost to respective grants. Correctively, budget vs actual reviews with senior directors take place in which directors identify permissible costs or costs that are not, and those costs are adjusted to programs that allow such cost or to admin.
FAC accepted this audit on September 28, 2023 — management decision was due March 28, 2024.
The organization does not have a policy in place to provide reasonable assurance that financial statements are prepared in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP); therefore, the potential exists that a material misstatement of the annual financial statements could occur and not be prevented, or detected and corrected, by the organization?s internal controls. While performing audit procedures, it was noted that there were adjustments necessary to the financial statements. Criteria or specific requirement: Internal controls should be in place to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Effect: The lack of controls in place over the financial reporting function increases the risk of misstatements, fraud, or errors occurring and not being detected and corrected. Cause: The organization has not adopted a policy to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP; however, management has reviewed and approved the annual financial statements and related notes, as prepared by the audit firm, and has accepted responsibility for those financial statements. Repeat Finding: Yes ? 2021-001. Recommendation: The organization should evaluate their financial reporting processes and controls, including the expertise of its internal staff, to determine whether additional controls over the preparation of annual financial statements can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Views of responsible officials and planned corrective actions: Management will continue to rely on the audit firm to draft the financial statements and the related notes to the financial statements, and will review, approve, and accept responsibility for the annual financial statements prior to their issuance.
Show full finding ▾Hide full finding ▴2022 ? 001: Financial Statement Preparation and Adjusting Journal Entries Type of Finding: ? Significant Deficiency in Internal Control over Financial Reporting Condition: The organization does not have a policy in place to provide reasonable assurance that financial statements are prepared in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP); therefore, the potential exists that a material misstatement of the annual financial statements could occur and not be prevented, or detected and corrected, by the organization?s internal controls. While performing audit procedures, it was noted that there were adjustments necessary to the financial statements. Criteria or specific requirement: Internal controls should be in place to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Effect: The lack of controls in place over the financial reporting function increases the risk of misstatements, fraud, or errors occurring and not being detected and corrected. Cause: The organization has not adopted a policy to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP; however, management has reviewed and approved the annual financial statements and related notes, as prepared by the audit firm, and has accepted responsibility for those financial statements. Repeat Finding: Yes ? 2021-001. Recommendation: The organization should evaluate their financial reporting processes and controls, including the expertise of its internal staff, to determine whether additional controls over the preparation of annual financial statements can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Views of responsible officials and planned corrective actions: Management will continue to rely on the audit firm to draft the financial statements and the related notes to the financial statements, and will review, approve, and accept responsibility for the annual financial statements prior to their issuance.
2022-001 Financial Statement Preparation and Adjusting Journal Entries Recommendation: The organization should evaluate their financial reporting processes and controls, including the expertise of its internal staff, to determine whether additional controls over the preparation of annual financial statements can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Assemble an accounting team with designated roles including expert experience and perform policy written period ending procedures on time to assure accuracy in the financial. Name of the contact person responsible for corrective action: Sam Jones, Outsourced CFO Planned completion date for corrective action plan: 12/31/2023
2021-001
The organization does not have appropriate segregation of duties and review procedures in place to provide reasonable assurance that financial statements are prepared in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP); therefore, the potential exists that a material misstatement of the annual financial statements could occur and not be prevented, or detected and corrected, by the organization?s internal controls. Criteria or specific requirement: Internal controls should be in place to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Effect: The lack of controls and review procedures in place over the financial reporting function increases the risk of misstatements, fraud, or errors occurring and not being detected and corrected. Cause: While performing audit procedures, it was noted that due to staffing turnover and changes, management does not have appropriate segregation of duties and review procedures in place as the President/CEO is completing and overseeing a significant amount of the financial reporting function during a portion of the year. Repeat Finding: Yes ? 2021-002. Recommendation: The organization should evaluate their financial reporting processes and controls, including the segregation of duties among its internal staff (including the number of internal staff), to determine whether additional controls over the financial reporting function can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Views of responsible officials and planned corrective actions: Management will continue to rely on a third party service provider to assist with the financial reporting function and will review, approve, and accept responsibility for the work performed by the third party servicer.
Show full finding ▾Hide full finding ▴2022 ? 002: Segregation of Duties Type of Finding: ? Significant Deficiency in Internal Control over Financial Reporting Condition: The organization does not have appropriate segregation of duties and review procedures in place to provide reasonable assurance that financial statements are prepared in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP); therefore, the potential exists that a material misstatement of the annual financial statements could occur and not be prevented, or detected and corrected, by the organization?s internal controls. Criteria or specific requirement: Internal controls should be in place to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Effect: The lack of controls and review procedures in place over the financial reporting function increases the risk of misstatements, fraud, or errors occurring and not being detected and corrected. Cause: While performing audit procedures, it was noted that due to staffing turnover and changes, management does not have appropriate segregation of duties and review procedures in place as the President/CEO is completing and overseeing a significant amount of the financial reporting function during a portion of the year. Repeat Finding: Yes ? 2021-002. Recommendation: The organization should evaluate their financial reporting processes and controls, including the segregation of duties among its internal staff (including the number of internal staff), to determine whether additional controls over the financial reporting function can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Views of responsible officials and planned corrective actions: Management will continue to rely on a third party service provider to assist with the financial reporting function and will review, approve, and accept responsibility for the work performed by the third party servicer.
2022-002 Segregation of Duties Recommendation: The organization should evaluate their financial reporting processes and controls, including the segregation of duties among its internal staff (including the number of internal staff), to determine whether additional controls over the financial reporting function can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Assemble a finance team and identify finance function roles for staffing and personnel. Name of the contact person responsible for corrective action: Sam Jones, Outsourced CFO Planned completion date for corrective action plan: 12/31/2023
2021-002
While performing audit procedures, it was noted that payroll expenses for salary positions were charged to the grant program based upon an allocation and not on approved and/or certified time worked in the program. Also, it was noted that two payroll expenses (of the sixty expenses selected for testing) charged to the grant were over charged due to an error in pay rate for overtime and an employee transition to full time. Questioned costs: $948 Context: During the process of obtaining an understanding of internal controls and processing of payroll expenditures, we noted payroll was not reviewed to ensure the expense charged to the grants was accurate based upon approved actual time spent in the program and accurate pay rates. Cause: Salary figures for salaried employees were charged to the federal grant based on unapproved work actually performed for the program and inaccurate pay rates were utilized for overtime and an employee transition to full time. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and accurate approved rates are utilized for wages charged to the grant. Repeat Finding: Yes ? 2021-003. Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Also, we recommend controls be put in place to ensure all wage rates are reviewed for accuracy prior to payroll being processed and charged to the grant. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 003: Allowable Costs Federal Agency: U.S. Department of Education Federal Program Name: Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods Assistance Listing Number: 84.215J Federal Award Identification Number and Year: U215J200111 Award Period: January 1, 2022 ? December 31, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Compliance Supplement requires that compensation for personal services be charged to the federal grant based upon approved actual time worked on the program and not based on an allocation or budget. The Compliance Supplement requires that expenditures charged to the federal grant be supported by documentation as to the nature of the expenditure. Condition: While performing audit procedures, it was noted that payroll expenses for salary positions were charged to the grant program based upon an allocation and not on approved and/or certified time worked in the program. Also, it was noted that two payroll expenses (of the sixty expenses selected for testing) charged to the grant were over charged due to an error in pay rate for overtime and an employee transition to full time. Questioned costs: $948 Context: During the process of obtaining an understanding of internal controls and processing of payroll expenditures, we noted payroll was not reviewed to ensure the expense charged to the grants was accurate based upon approved actual time spent in the program and accurate pay rates. Cause: Salary figures for salaried employees were charged to the federal grant based on unapproved work actually performed for the program and inaccurate pay rates were utilized for overtime and an employee transition to full time. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and accurate approved rates are utilized for wages charged to the grant. Repeat Finding: Yes ? 2021-003. Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Also, we recommend controls be put in place to ensure all wage rates are reviewed for accuracy prior to payroll being processed and charged to the grant. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods ? Assistance Listing No. 84.215J Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Also, we recommend controls be put in place to ensure all wage rates are reviewed for accuracy prior to payroll being processed and charged to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In the interim the utilization of manual time sheets is taking place for individuals not designated 100 percent. We are also working on Implementation of Job costing for all Staff with PEO provider allowing restricted selections of projects and departments. Name of the contact person responsible for corrective action: Guadalupe Perez, HR Planned completion date for corrective action plan: 12/31/2023
2021-003
While performing audit procedures, it was noted that bi-annual performance reports for the six-month period ending March 31, 2022 was submitted June 15, 2022, were not supported by organizations records as the underlying performance reporting files were unable to be provided for testing on accuracy of reporting. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was fully supported by organizational records. Cause: During the process of obtaining an understanding of internal controls and procedures surrounding competing reporting requirements, we noted that due to significant changes in personnel the supporting Martindale Brightwood Education Zone performance reporting file was not retained to support the bi-annual report. Effect: The organization has not fully followed compliance attributes with the reporting requirements set forth by the Compliance Supplement and grant agreement. Personnel need to reinforce policies to ensure control procedures are in place to ensure accurate and timely reporting is completed and supported by organizational records. Repeat Finding: No. Recommendation: We recommend that the organization review their policies and procedures surrounding federal grants administration and ensure a review process is in place to ensure that all necessary compliance requirements are met and the organization?s records are complete to support all reporting requirements. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 004: Reporting Federal Agency: U.S. Department of Education Federal Program Name: Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods Assistance Listing Number: 84.215J Federal Award Identification Number and Year: U215J200111 Award Period: January 1, 2022 ? December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: While performing audit procedures, it was noted that bi-annual performance reports for the six-month period ending March 31, 2022 was submitted June 15, 2022, were not supported by organizations records as the underlying performance reporting files were unable to be provided for testing on accuracy of reporting. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was fully supported by organizational records. Cause: During the process of obtaining an understanding of internal controls and procedures surrounding competing reporting requirements, we noted that due to significant changes in personnel the supporting Martindale Brightwood Education Zone performance reporting file was not retained to support the bi-annual report. Effect: The organization has not fully followed compliance attributes with the reporting requirements set forth by the Compliance Supplement and grant agreement. Personnel need to reinforce policies to ensure control procedures are in place to ensure accurate and timely reporting is completed and supported by organizational records. Repeat Finding: No. Recommendation: We recommend that the organization review their policies and procedures surrounding federal grants administration and ensure a review process is in place to ensure that all necessary compliance requirements are met and the organization?s records are complete to support all reporting requirements. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods ? Assistance Listing No. 84.215J Recommendation: We recommend that the organization review their policies and procedures surrounding federal grants administration and ensure a review process is in place to ensure that all necessary compliance requirements are met and the organization?s records are complete to support all reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Grant Manager utilizes fluxx grant management system which documents all submission of grant reports and maintains documentation support. Finance as well has organized a filing system organized by department and then list accounting function as well as report assistance for grants. Name of the contact person responsible for corrective action: Anthony Conley Grant Manager / Compliance Specialist Planned completion date for corrective action plan: 12/31/2023
FAC accepted this audit on January 30, 2023 — management decision was due July 30, 2023.
The organization does not have a policy in place to provide reasonable assurance that financial statements are prepared in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP); therefore, the potential exists that a material misstatement of the annual financial statements could occur and not be prevented, or detected and corrected, by the organization?s internal controls. While performing audit procedures, it was noted that there were adjustments necessary to the financial statements due to the system not correctly closing out previous years. Criteria or specific requirement: Internal controls should be in place to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Effect: The lack of controls in place over the financial reporting function increases the risk of misstatements, fraud, or errors occurring and not being detected and corrected. Cause: The organization has not adopted a policy to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP; however, management has reviewed and approved the annual financial statements and related notes, as prepared by the audit firm, and has accepted responsibility for those financial statements. Repeat Finding: No. Recommendation: The organization should evaluate their financial reporting processes and controls, including the expertise of its internal staff, to determine whether additional controls over the preparation of annual financial statements can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Views of responsible officials and planned corrective actions: Management will continue to rely on the audit firm to draft the financial statements and the related notes to the financial statements, and will review, approve, and accept responsibility for the annual financial statements prior to their issuance.
Show full finding ▾Hide full finding ▴2021 ? 001: Financial Statement Preparation and Adjusting Journal Entries Type of Finding: ? Material Weakness in Internal Control over Financial Reporting Condition: The organization does not have a policy in place to provide reasonable assurance that financial statements are prepared in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP); therefore, the potential exists that a material misstatement of the annual financial statements could occur and not be prevented, or detected and corrected, by the organization?s internal controls. While performing audit procedures, it was noted that there were adjustments necessary to the financial statements due to the system not correctly closing out previous years. Criteria or specific requirement: Internal controls should be in place to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Effect: The lack of controls in place over the financial reporting function increases the risk of misstatements, fraud, or errors occurring and not being detected and corrected. Cause: The organization has not adopted a policy to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP; however, management has reviewed and approved the annual financial statements and related notes, as prepared by the audit firm, and has accepted responsibility for those financial statements. Repeat Finding: No. Recommendation: The organization should evaluate their financial reporting processes and controls, including the expertise of its internal staff, to determine whether additional controls over the preparation of annual financial statements can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Views of responsible officials and planned corrective actions: Management will continue to rely on the audit firm to draft the financial statements and the related notes to the financial statements, and will review, approve, and accept responsibility for the annual financial statements prior to their issuance.
2021-001 Financial Statement Preparation and Adjusting Journal Entries Recommendation: The organization should evaluate their financial reporting processes and controls, including the expertise of its internal staff, to determine whether additional controls over the preparation of annual financial statements can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Retire MIP accounting software and utilize accounting software set up and capable of closing out and roll forward balances appropriately. As a team, we have selected QuickBooks in the Interim to do such. Name of the contact person responsible for corrective action: Barato Britt, President/CEO Planned completion date for corrective action plan: 12/31/2022
The organization does not have appropriate segregation of duties and review procedures in place to provide reasonable assurance that financial statements are prepared in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP); therefore, the potential exists that a material misstatement of the annual financial statements could occur and not be prevented, or detected and corrected, by the University?s internal controls. Criteria or specific requirement: Internal controls should be in place to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Effect: The lack of controls and review procedures in place over the financial reporting function increases the risk of misstatements, fraud, or errors occurring and not being detected and corrected. Cause: While performing audit procedures, it was noted that due to staffing turnover and changes, management does not have appropriate segregation of duties and review procedures in place as the President/CEO is completing and overseeing a significant amount of the financial reporting function. Repeat Finding: No. Recommendation: The organization should evaluate their financial reporting processes and controls, including the segregation of duties among its internal staff (including the number of internal staff), to determine whether additional controls over the financial reporting function can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Views of responsible officials and planned corrective actions: Management will continue to rely on a third party service provider to assist with the financial reporting function and will review, approve, and accept responsibility for the work performed by the third party servicer.
Show full finding ▾Hide full finding ▴2021 ? 002: Segregation of Duties Type of Finding: ? Significant Deficiency in Internal Control over Financial Reporting Condition: The organization does not have appropriate segregation of duties and review procedures in place to provide reasonable assurance that financial statements are prepared in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP); therefore, the potential exists that a material misstatement of the annual financial statements could occur and not be prevented, or detected and corrected, by the University?s internal controls. Criteria or specific requirement: Internal controls should be in place to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Effect: The lack of controls and review procedures in place over the financial reporting function increases the risk of misstatements, fraud, or errors occurring and not being detected and corrected. Cause: While performing audit procedures, it was noted that due to staffing turnover and changes, management does not have appropriate segregation of duties and review procedures in place as the President/CEO is completing and overseeing a significant amount of the financial reporting function. Repeat Finding: No. Recommendation: The organization should evaluate their financial reporting processes and controls, including the segregation of duties among its internal staff (including the number of internal staff), to determine whether additional controls over the financial reporting function can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Views of responsible officials and planned corrective actions: Management will continue to rely on a third party service provider to assist with the financial reporting function and will review, approve, and accept responsibility for the work performed by the third party servicer.
2021-002 Segregation of Duties Recommendation: The organization should evaluate their financial reporting processes and controls, including the segregation of duties among its internal staff (including the number of internal staff), to determine whether additional controls over the financial reporting function can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Assemble a finance team and identify finance function roles for staffing and personnel. Name of the contact person responsible for corrective action: Barato Britt, President/CEO Planned completion date for corrective action plan: 12/31/2022
While performing audit procedures, it was noted that payroll expenses charged to the grant program were based upon an allocation and not on approved time worked in the program. Also, it was noted that two credit card expenses (of the eight expenses selected for testing) charged to the grant did not have supporting documentation retained as to the allowability of the expenditures to be charged to the grant. Questioned costs: None Context: During the process of obtaining an understanding of internal controls and processing of payroll expenditures, we noted payroll was not reviewed to ensure the expense charged to the grants was accurate based upon approved actual time spent in the program. Also, we noted that credit card charges were not supported by invoices and/or receipts for the charges that support the details of the expense charged to the grant. Cause: Salary figures were charged to the federal grant based on unapproved work actually performed for the program. Credit card charges were charged to the grant but supporting invoices and/or receipts were not retained that support the details of the expense charged to the grant. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Also, we recommend controls be put in place to ensure all invoices and/or receipts for credit card charges are submitted and done so in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 003: Allowable Costs Federal Agency: U.S. Department of Education Federal Program Name: Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods Assistance Listing Number: 84.215J Federal Award Identification Number and Year: U215J200111 Award Period: January 1, 2021 ? December 31, 2021 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Compliance Supplement requires that compensation for personal services be charged to the federal grant based upon approved actual time worked on the program and not based on an allocation or budget. The Compliance Supplement requires that expenditures charged to the federal grant be supported by documentation as to the nature of the expenditure. Condition: While performing audit procedures, it was noted that payroll expenses charged to the grant program were based upon an allocation and not on approved time worked in the program. Also, it was noted that two credit card expenses (of the eight expenses selected for testing) charged to the grant did not have supporting documentation retained as to the allowability of the expenditures to be charged to the grant. Questioned costs: None Context: During the process of obtaining an understanding of internal controls and processing of payroll expenditures, we noted payroll was not reviewed to ensure the expense charged to the grants was accurate based upon approved actual time spent in the program. Also, we noted that credit card charges were not supported by invoices and/or receipts for the charges that support the details of the expense charged to the grant. Cause: Salary figures were charged to the federal grant based on unapproved work actually performed for the program. Credit card charges were charged to the grant but supporting invoices and/or receipts were not retained that support the details of the expense charged to the grant. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Also, we recommend controls be put in place to ensure all invoices and/or receipts for credit card charges are submitted and done so in a timely manner. Views of responsible officials: There is no disagreement with the audit finding.
2021-003 Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods ? Assistance Listing No. 84.215J Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Implement Job Costing and Time Sheets for all staff with PEO provider allowing restricted selections of projects and departments. Name of the contact person responsible for corrective action: Barato Britt, President/CEO Planned completion date for corrective action plan: 12/31/2022
While performing audit procedures, it was noted that bi-annual performance report for the six-month period ending March 31, 2021 was submitted June 15, 2021, which is after the 60 day requirement per the G5 system. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Cause: During the process of obtaining an understanding of internal controls and procedures surrounding competing reporting requirements, we noted that due to significant changes in personnel the report was not filed timely. Effect: The organization has not fully followed compliance attributes with the reporting requirements set forth by the Compliance Supplement and grant agreement. Personnel need to reinforce policies to ensure control procedures are in place to ensure accurate and timely reporting is completed. Repeat Finding: No Recommendation: We recommend that the organization review their policies and procedures surrounding federal grants administration and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 004: Reporting Federal Agency: U.S. Department of Education Federal Program Name: Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods Assistance Listing Number: 84.215J Federal Award Identification Number and Year: U215J200111 Award Period: January 1, 2021 ? December 31, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: While performing audit procedures, it was noted that bi-annual performance report for the six-month period ending March 31, 2021 was submitted June 15, 2021, which is after the 60 day requirement per the G5 system. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Cause: During the process of obtaining an understanding of internal controls and procedures surrounding competing reporting requirements, we noted that due to significant changes in personnel the report was not filed timely. Effect: The organization has not fully followed compliance attributes with the reporting requirements set forth by the Compliance Supplement and grant agreement. Personnel need to reinforce policies to ensure control procedures are in place to ensure accurate and timely reporting is completed. Repeat Finding: No Recommendation: We recommend that the organization review their policies and procedures surrounding federal grants administration and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of responsible officials: There is no disagreement with the audit finding.
2021-004 Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods ? Assistance Listing No. 84.215J Recommendation: We recommend that the organization review their policies and procedures surrounding federal grants administration and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Assemble a finance team and identify finance function roles for staffing and personnel, including grant compliance management as well as utilize internal grant schedule and flux notifications for reporting deadlines and making submission completion dates within grant schedule and flux. Name of the contact person responsible for corrective action: Barato Britt, President/CEO Planned completion date for corrective action plan: 12/31/2022
FAC accepted this audit on September 15, 2021 — management decision was due March 15, 2022.
FAC accepted this audit on October 18, 2020 — management decision was due April 18, 2021.
FAC accepted this audit on July 7, 2019 — management decision was due January 7, 2020.
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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