EIN: 356076798
UEI: KLBYLBQ8BH26
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 27, 2024. 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 27, 2024 (699 days ago).
What is a management decision? →For the views of responsible officials, refer to the Corrective Action Plan that is part of this report
Show full finding ▾Hide full finding ▴For the views of responsible officials, refer to the Corrective Action Plan that is part of this report
FINDING DETAILS: AN EFFECTIVE INTERNAL CONTROL SYSTEM WAS NOT IN PLACE TO ENSURE THAT THE AGENCY GENERAL LEDGER ACCOUNTING WAS DOUBLE-CHECKED TO BE SURE THE EXPENSE ACCOUNT NUMBERS POSTED WERE THE SAME AS THE ACTUAL/BUDGER FOR HEAD START. RECOMMENDATION: WE RECOMMEND THAT PALADIN INC.'S MANAGEMENT REVISE A SYSTEM OF INTERNAL CONTROLS TO ENSURE COMPLIANCE WITH THE GRANT AGREEMENT AND THE SPECIAL TESTS AND PROVISIONS PRINCIPLES COMPLIANCE REQUIREMENTS. TAKEN OR TO BE TAKEN: THE HS FISCAL REVIEW POLICY AND THE ACCOUNTS PAYABLE & DRAW REVIEW PROCEDURE UPDATE WAS MADE TO THE REVIEW OF DRAWS/ACCOUNTS PAYABLE PROCEDURE ALREADY IN PLACE TO ASSURE THAT ACCOUNT OR DEPARTMENT CHANGES MADE ARE IN THE FINAL REVIEW. IF ALREADY TAKEN, DATE OF COMPLETION: PALADIN HAS REVISED DETAILED PROCEDURES FOR PROCESSES INVOLVED WITH THE HEAD START GRANT. STAFF ARE IN PLACE TO DO THIS REVIEW. REVISED PROCEDURE COMPLETED 11-3-2023. ACCOUNTING STAFF ARE REVIEWING DRAWS AND ACCOUNTS POSTED FROM JULY 1, 2023 TO CURRENT DATE TO BE SURE THAT DRAWS FROM THE GRANT WERE CORRECTLY POSTED AND DRAWN AND ARE CAPTURED ON THE AGENCY SYSTEM. ADDITIONAL COMMENTS: PALADIN CFO STATED THAT PALADIN DID HAVE A PROCEDURE IN PLACE FOR REVIEW. HOWEVER, IT DID NOT HAVE A SECONDARY PROCEDURE IN PLACE TO REVIEW CHANGES MADE BY STAFF INVOLVED. ANY CHANGES MADE TO THE HEAD START BUDGET/ACTUAL WILL BE CHANGED IN THE AGENCY ACCOUNTING SYSTEM TO REFLECT THE SAME ACCOUNTS. PALADIN CONTACT PERSON(S) RESPONSIBLE FOR FINDINGS NAME & TITLE: EVELYN MARVEL, FINANCIAL OFFICER
FAC accepted this audit on December 23, 2022 — management decision was due June 23, 2023.
An effective internal control system was not in place at Paladin, Inc. in order to ensure compliance with requirements related to theCost Principles/compliance requirements. Paladin, Inc. had not designed an adequate policy or procedure to ensure that the mileage rate used for reimbursement matched Paladin?s rate. Context: The lack of sufficient internal controls was an isolated issue involving two employees sporadically during the audit period Criteria: 2 CFR 200.475(a) states in part: ?Travel costs are the expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of the non-Federal entity. Such costs may be charged on an actual cost basis, on a per diem or mileage basis? provided the method used results in charges consistent with those normally allowed in like circumstances in the non-Federal entity?s non-federally-funded activities and in accordance with non-Federal entity?s written travel reimbursement policies?? Cause: Management of Paladin, Inc. had not developed or implemented a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed Paladin, Inc. at risk of noncompliance with the compliance requirements listed above. A lack of consistent oversight within an internal control system could have also allowed noncompliance with the compliance requirements and could have allowed the mismanagement of Federal funds and assets by lacking proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Recommendation: We recommend Paladin Inc.?s management establish a system of internal controls to ensure compliance with thecost Principles compliance requirements. Views of Responsible Officials: For the views of responsible officials, refer to the Corrective Action Plan that is part of this report
Show full finding ▾Hide full finding ▴FINDING 2022-001 Subject: Headstart Cluster ? Allowable Costs/Cost Principles Federal Agency: Department of Health and Human Services Federal Program: Headstart CFDA Number: 93.600 Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Significant Deficiency Condition: An effective internal control system was not in place at Paladin, Inc. in order to ensure compliance with requirements related to theCost Principles/compliance requirements. Paladin, Inc. had not designed an adequate policy or procedure to ensure that the mileage rate used for reimbursement matched Paladin?s rate. Context: The lack of sufficient internal controls was an isolated issue involving two employees sporadically during the audit period Criteria: 2 CFR 200.475(a) states in part: ?Travel costs are the expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of the non-Federal entity. Such costs may be charged on an actual cost basis, on a per diem or mileage basis? provided the method used results in charges consistent with those normally allowed in like circumstances in the non-Federal entity?s non-federally-funded activities and in accordance with non-Federal entity?s written travel reimbursement policies?? Cause: Management of Paladin, Inc. had not developed or implemented a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed Paladin, Inc. at risk of noncompliance with the compliance requirements listed above. A lack of consistent oversight within an internal control system could have also allowed noncompliance with the compliance requirements and could have allowed the mismanagement of Federal funds and assets by lacking proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Recommendation: We recommend Paladin Inc.?s management establish a system of internal controls to ensure compliance with thecost Principles compliance requirements. Views of Responsible Officials: For the views of responsible officials, refer to the Corrective Action Plan that is part of this report
Audit Finding Number: 2022-01 Finding Details: An effective internal control system was not in place to ensure compliance with the requirements related to the Cost Principles/compliance requirements. Recommendation: We recommend that Paladin Inc.?s management revise a system of internal controls to ensure compliance with the grant agreement and the Special Tests and Provisions Principles compliance requirements. Taken or to be Taken: Revision of the Paladin Travel Reimbursement procedure was made to the procedure already in place. If already taken, date of completion: Paladin has revised detailed procedures for processes involved with the Head Start grant. Staffing processes have been modified to accommodate the additional review of travel reimbursement prior to draws from the grant. If to be taken, estimated date of completion: Revised procedure completed 11-1-2022. Accounting staff completed a review of Head Start draws for travel reimbursement back to 7/1/22 (FY23) to be sure that draws from the grant were correct. Additional Comments: Paladin CFO stated that Paladin did have a procedure in place for processing travel reimbursements; however, it did not have a secondary procedure review in place prior to draws from the federal grant. Paladin contact person(s) responsible for findings. Name and title: Evelyn Marvel, Financial Officer
FAC accepted this audit on April 11, 2022 — management decision was due October 11, 2022.
An effective internal control system was not in place at Paladin, Inc. in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions Principles compliance requirements. Paladin, Inc. had not designed or implemented adequate policies or procedures to ensure that accurate and regular financial information was shared with the governing body and the policy council, including monthly financial statements, including credit card expenditures and the financial audit. Context: The lack of sufficient internal controls was a systemic issue throughout the audit period. The lack of sufficient evidential documentation to support the disbursements was limited to vendor transactions. Criteria: 2 CFR 200.303 states in part: ?The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in `Standards for Internal Control in Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?? 42 USC 9837(d)(2)(A)and(E) states: A HSA must share accurate and regular financial information with the governing body and the policy council, including monthly financial statements, including credit card expenditures and the financial audit. Cause: Management of Paladin, Inc. had not developed or implemented a system of internal controls to ensure compliance with the grant agreement and the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed Paladin, Inc. at risk of noncompliance with the grant agreement and the compliance requirements listed above. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and could have allowed the misuse and mismanagement of Federal funds and assets by lacking proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Recommendation: We recommend Paladin Inc.?s management establish a system of internal controls to ensure compliance with the grant agreement and the Special Tests and Provisions Principles compliance requirements. Views of Responsible Officials: For the views of responsible officials, refer to the Corrective Action Plan that is part of this report
Show full finding ▾Hide full finding ▴FINDING 2021-01 Subject: Headstart Cluster ? Special Tests and Provisions (Program Governance) Federal Agency: Department of Health and Human Services Federal Program: Headstart CFDA Number: 93.600 Compliance Requirement: Special Tests and Provisions (Program Governance) Audit Findings: Material Weakness Condition: An effective internal control system was not in place at Paladin, Inc. in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions Principles compliance requirements. Paladin, Inc. had not designed or implemented adequate policies or procedures to ensure that accurate and regular financial information was shared with the governing body and the policy council, including monthly financial statements, including credit card expenditures and the financial audit. Context: The lack of sufficient internal controls was a systemic issue throughout the audit period. The lack of sufficient evidential documentation to support the disbursements was limited to vendor transactions. Criteria: 2 CFR 200.303 states in part: ?The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in `Standards for Internal Control in Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?? 42 USC 9837(d)(2)(A)and(E) states: A HSA must share accurate and regular financial information with the governing body and the policy council, including monthly financial statements, including credit card expenditures and the financial audit. Cause: Management of Paladin, Inc. had not developed or implemented a system of internal controls to ensure compliance with the grant agreement and the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed Paladin, Inc. at risk of noncompliance with the grant agreement and the compliance requirements listed above. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and could have allowed the misuse and mismanagement of Federal funds and assets by lacking proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Recommendation: We recommend Paladin Inc.?s management establish a system of internal controls to ensure compliance with the grant agreement and the Special Tests and Provisions Principles compliance requirements. Views of Responsible Officials: For the views of responsible officials, refer to the Corrective Action Plan that is part of this report
Paladin, Inc. began correcting this issue for the 2021 fiscal year. Paladin, Inc. acquired CCC in 2020 and due to the CCC audit delay the 2020 financial statements issuance. As a result this finding was not corrected until the 2022 fiscal years. Completed in first quarter of fiscal year 2022 Paladin has detailed procedures for all processes involved with the Head Start grant. Staffing has been modified to accommodate the segregation of duties to properly monitor control of the funds received. In addition, a Fiscal Specialist was hired to monitor grant spending at the program level and to communicate with the Office of Head Start when questions/concerns arise or need for clarification of policies was needed. Expenses & draw of funds is monitored by both the program level Fiscal Specialist and the accounting staff at Paladin?s main office. The Accounting Manager randomly checks draw expenses and backup for these costs. A cost allocation plan has been developed specifically for the Head Start program monitoring. The Board of Directors receives monthly reports specifically relating to the requirements of Head Start for their review. The Head Start Policy Committee has began meeting monthly and they are receiving the information as shown is 42 USC 9837(d)(2)(A) and (E). The Policy Council meeting minutes are completed by the Head Start Compliance Officer.
2020-001
FAC accepted this audit on March 27, 2022 — management decision was due September 27, 2022.
An effective internal control system was not in place at Paladin, Inc. in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions Principles compliance requirements. Paladin, Inc. had not designed or implemented adequate policies or procedures to ensure that accurate and regular financial information was shared with the governing body and the policy council, including monthly financial statements, including credit card expenditures and the financial audit. Context: The lack of sufficient internal controls was a systemic issue throughout the audit period. The lack of sufficient evidential documentation to support the disbursements was limited to vendor transactions. Criteria: 2 CFR 200.303 states in part: ?The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in `Standards for Internal Control in Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?? 42 USC 9837(d)(2)(A)and(E) states: A HSA must share accurate and regular financial information with the governing body and the policy council, including monthly financial statements, including credit card expenditures and the financial audit. Cause: Management of Paladin, Inc. had not developed or implemented a system of internal controls to ensure compliance with the grant agreement and the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed Paladin, Inc. at risk of noncompliance with the grant agreement and the compliance requirements listed above. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and could have allowed the misuse and mismanagement of Federal funds and assets by lacking proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Recommendation: We recommend Paladin Inc.?s management establish a system of internal controls to ensure compliance with the grant agreement and the Special Tests and Provisions Principles compliance requirements. Views of Responsible Officials: For the views of responsible officials, refer to the Corrective Action Plan that is part of this report
Show full finding ▾Hide full finding ▴FINDING 2020-001 Subject: Headstart Cluster ? Special Tests and Provisions (Program Governance) Federal Agency: Department of Health and Human Services Federal Program: Headstart CFDA Number: 93.600 Compliance Requirement: Special Tests and Provisions (Program Governance) Audit Findings: Material Weakness Condition: An effective internal control system was not in place at Paladin, Inc. in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions Principles compliance requirements. Paladin, Inc. had not designed or implemented adequate policies or procedures to ensure that accurate and regular financial information was shared with the governing body and the policy council, including monthly financial statements, including credit card expenditures and the financial audit. Context: The lack of sufficient internal controls was a systemic issue throughout the audit period. The lack of sufficient evidential documentation to support the disbursements was limited to vendor transactions. Criteria: 2 CFR 200.303 states in part: ?The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in `Standards for Internal Control in Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?? 42 USC 9837(d)(2)(A)and(E) states: A HSA must share accurate and regular financial information with the governing body and the policy council, including monthly financial statements, including credit card expenditures and the financial audit. Cause: Management of Paladin, Inc. had not developed or implemented a system of internal controls to ensure compliance with the grant agreement and the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed Paladin, Inc. at risk of noncompliance with the grant agreement and the compliance requirements listed above. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and could have allowed the misuse and mismanagement of Federal funds and assets by lacking proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Recommendation: We recommend Paladin Inc.?s management establish a system of internal controls to ensure compliance with the grant agreement and the Special Tests and Provisions Principles compliance requirements. Views of Responsible Officials: For the views of responsible officials, refer to the Corrective Action Plan that is part of this report
See Corrective Action Plan for chart/table. Paladin, Inc. began correcting this issue for the 2021 fiscal year. Paladin, Inc. acquired CCC in 2020 and due to the CCC audit delay the 2020 financial statements issuance. As a result this finding was not corrected until the 2022 fiscal years. Completed in first quarter of fiscal year 2022 Paladin has detailed procedures for all processes involved with the Head Start grant. Staffing has been modified to accommodate the segregation of duties to properly monitor control of the funds received. In addition, a Fiscal Specialist was hired to monitor grant spending at the program level and to communicate with the Office of Head Start when questions/concerns arise or need for clarification of policies was needed. Expenses & draw of funds is monitored by both the program level Fiscal Specialist and the accounting staff at Paladin?s main office. The Accounting Manager randomly checks draw expenses and backup for these costs. A cost allocation plan has been developed specifically for the Head Start program monitoring. The Board of Directors receives monthly reports specifically relating to the requirements of Head Start for their review. The Head Start Policy Committee has began meeting monthly and they are receiving the information as shown is 42 USC 9837(d)(2)(A) and (E). The Policy Council meeting minutes are completed by the Head Start Compliance Officer.
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.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and compliance status.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
