EIN: 351126994
UEI: TQL1D6H62JQ5
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 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 August 26, 2026 (3 days from today).
What is a management decision? →The Agency failed to meet the required 20 percent non-federal share for the budget period ending May 31, 2025. Based on total federal expenditures of $4,321,594, the required match was $1,080,399 ($4,321,594 ÷ 0.08 × 0.20). The Agency documented $790,547 in allowable in-kind contributions, resulting in a shortfall of $289,852. A waiver request was not submitted until after the end of the budget period. Criteria: Under Section 640(b) of the Head Start Act and 45 CFR § 1303.4, Head Start grantees must provide a 20 percent non federal share, unless the Office of Head Start approves a waiver. Grantees are to request a waiver before the end of the budget period for which the match cannot be met. Cause: Turnover and vacancy in an executive leadership position resulted in a breakdown in internal controls over monitoring the non-federal share requirement. As a result, the Agency did not adequately track in-kind contributions during the period, and management did not identify the need for a waiver in time to submit it before the budget period ended. Context: The Agency submitted a waiver request after May 31, 2025. The review and approval of waiver requests have been delayed due to the federal government shutdown and the operational restructuring within the Head Start program. As of the date of this report, the waiver remains under federal review. Questioned Costs: $368,859: This amount represents the portion of federal expenditures unsupported by the required non-federal match. The documented match of $790,547 supports 20 percent of $3,952,735 in total program costs; therefore, $368,859 of federal expenditures is not supported by the required 20 percent match. Effect: The Agency did not meet the 20 percent non-federal match requirement and did not file for a waiver until after the budget period ended. As of the date of this report, the waiver request remains under review. If the waiver is not approved, the unmatched portion may be considered unallowable, potentially resulting in disallowed costs and repayment to the Head Start program. Recommendation: Executive management should strengthen internal controls over tracking and monitoring in-kind contributions throughout the budget period. Management should implement procedures to forecast expected non-federal share contributions and evaluate whether the 20 percent requirement will be met. When it becomes evident the requirement may not be achieved, management should submit a waiver request to the Office of Head Start before the end of the budget period. Views of Responsible Officials and Planned Corrective Actions: The corrective action outlined under Finding 2025-001 addresses both the internal control deficiency and the compliance requirement related to matching, level of effort, and earmarking. Through enhanced monthly monitoring, quarterly projections, strengthened governance oversight, formalized written procedures, and additional fiscal training, the Agency has implemented corrective measures designed to ensure ongoing compliance with federal non-federal share requirements under the Head Start program.
Show full finding ▾Hide full finding ▴Condition: The Agency failed to meet the required 20 percent non-federal share for the budget period ending May 31, 2025. Based on total federal expenditures of $4,321,594, the required match was $1,080,399 ($4,321,594 ÷ 0.08 × 0.20). The Agency documented $790,547 in allowable in-kind contributions, resulting in a shortfall of $289,852. A waiver request was not submitted until after the end of the budget period. Criteria: Under Section 640(b) of the Head Start Act and 45 CFR § 1303.4, Head Start grantees must provide a 20 percent non federal share, unless the Office of Head Start approves a waiver. Grantees are to request a waiver before the end of the budget period for which the match cannot be met. Cause: Turnover and vacancy in an executive leadership position resulted in a breakdown in internal controls over monitoring the non-federal share requirement. As a result, the Agency did not adequately track in-kind contributions during the period, and management did not identify the need for a waiver in time to submit it before the budget period ended. Context: The Agency submitted a waiver request after May 31, 2025. The review and approval of waiver requests have been delayed due to the federal government shutdown and the operational restructuring within the Head Start program. As of the date of this report, the waiver remains under federal review. Questioned Costs: $368,859: This amount represents the portion of federal expenditures unsupported by the required non-federal match. The documented match of $790,547 supports 20 percent of $3,952,735 in total program costs; therefore, $368,859 of federal expenditures is not supported by the required 20 percent match. Effect: The Agency did not meet the 20 percent non-federal match requirement and did not file for a waiver until after the budget period ended. As of the date of this report, the waiver request remains under review. If the waiver is not approved, the unmatched portion may be considered unallowable, potentially resulting in disallowed costs and repayment to the Head Start program. Recommendation: Executive management should strengthen internal controls over tracking and monitoring in-kind contributions throughout the budget period. Management should implement procedures to forecast expected non-federal share contributions and evaluate whether the 20 percent requirement will be met. When it becomes evident the requirement may not be achieved, management should submit a waiver request to the Office of Head Start before the end of the budget period. Views of Responsible Officials and Planned Corrective Actions: The corrective action outlined under Finding 2025-001 addresses both the internal control deficiency and the compliance requirement related to matching, level of effort, and earmarking. Through enhanced monthly monitoring, quarterly projections, strengthened governance oversight, formalized written procedures, and additional fiscal training, the Agency has implemented corrective measures designed to ensure ongoing compliance with federal non-federal share requirements under the Head Start program.
Management acknowledges that the Agency did not meet the required 20 percent non-federal share for the budget period ended May 31, 2025, and that the waiver request was submitted after the close of the budget period. While allowable in-kind contributions were tracked throughout the year, communication from OHS provided differing guidance regarding the timing of submission for a Non-Federal Share waiver, which contributed to the delay. To address this matter, the Agency has implemented the following corrective actions: 1. A formal monthly Non-Federal Share Monitoring Report has been implemented and is reviewed by the Director and CFO. This report calculates the required match based on cumulative federal expenditures and compares it to documented in-kind contributions to ensure ongoing compliance. 2. Quarterly match projections are now prepared to identify potential shortfalls in advance of the budget period end. If projections indicate a deficit, corrective measures will be initiated immediately, including intensified in-kind collection efforts or submission of a waiver request prior to the end of the budget period. 3. The Governing Board and Policy Council will receive quarterly updates on non-federal share status to strengthen governance oversight and ensure transparency. 4. Written internal procedures for in-kind documentation, valuation, and monitoring have been formalized and incorporated into the Agency's fiscal policies and procedures manual. 5. The CFO has received additional training regarding federal matching requirements under 45 CFR §75 and Head Start Program Performance Standards to reinforce compliance expectations and ensure timely action in future budget periods. Management believes these corrective actions will strengthen internal controls, improve monitoring, and prevent recurrence in future budget periods.
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