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Children's Place AssociationNon-Profit

EIN: 363641017

UEI: K6TMLHKR6ZU8

Audited by: Shiekh Oster & Scott CPAs & Advisors

Oversight agency: 93 [Department of Health and Human Services]

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Data as of August 28, 2026

Children's Place Association9 audit years17 findings12 repeat
9
Audit Years
17
Total Findings
12
Repeat Findings
$1.5M
Federal Awards Expended (FY 2024)

FY 2024-06-30

GOING CONCERN$1,468,359 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 17, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 17, 2026 (18 days from today).

What is a management decision? →
2024-002
Reporting
MATERIAL WEAKNESSREPEAT OF 2023-002OTHER MATTERS

Reporting Major, Program - Head Start

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Reporting Major, Program - Head Start

Corrective Action Plan

To address this finding and prevent future delays, CPA has implemented the following corrective actions: 1. Centralized Grant Reporting & Billing Tracker CPA has developed and implemented a centralized Master Grant Reporting and Billing Tracker to monitor all grant-related submissions. The tracker captures, at a minimum: o Required financial, programmatic, and performance reports o Grantor and pass-through entity reporting requirements o Reporting frequency (monthly, quarterly, and annual) o Internal preparation and review deadlines o Final grantor submission due dates 2. Defined Roles and Accountability The Finance Department is responsible for maintaining the tracker and monitoring compliance with all reporting deadlines. Program Leadership is responsible for providing timely programmatic and supporting documentation to Finance in accordance with established internal deadlines. 3. Ongoing Monitoring and Oversight The Master Grant Reporting and Billing Tracker is reviewed on a regular basis by Finance and shared with Program Leadership and Executive Management to ensure visibility, accountability, and timely escalation of potential delays. 4. Preventive Controls Internal deadlines have been established in advance of external due dates to allow adequate time for review, reconciliation, and approval prior to submission. These corrective actions strengthen CPA’s internal controls over grant reporting and billing, will improve coordination between Finance and Program teams, and are expected to ensure timely submission of all required reports and billings going forward.

Prior Finding References

2023-002

About Reporting →
2024-003
Cost Allowability
MATERIAL WEAKNESSOTHER MATTERS

Allowable Costs, Cost Principles; Payroll Documentation, Program - Head Start

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Allowable Costs, Cost Principles; Payroll Documentation, Program - Head Start

Corrective Action Plan

Management recognizes that the payroll software transition and the absence of formally documented procedures governing payroll data preservation and time-and-effort reporting resulted in gaps in compliance. Specifically, legacy payroll and timesheet data were not fully preserved prior to system migration, and payroll allocations were, for a period, based on budgeted estimates rather than actual time worked. Management started implementing corrective actions to address both the immediate documentation gaps and the underlying internal control weaknesses. 1. Time-and-Effort Documentation System CPA transitioned to a new standardized payroll and time-reporting system in early 2024, which requires all employees whose compensation is charged in whole or in part to federal awards to document actual time worked, as follows: o Currently employees record time by department and program activity. o In December 2025, management is configuring the payroll system to allow employee time allocations down to the individual contract level. o Time reporting will be based on actual hours worked, not budgeted or estimated percentages and replace prior budget-based allocation methodologies. o Timesheets are reviewed and approved by supervisors on a bi-weekly basis and are maintained as part of CPA’s official payroll and accounting records. Management will establish guidelines and document formal procedures to ensure full data preservation prior to any future system migrations, including payroll, HR, or financial systems. These procedures include: o A mandatory pre-migration data inventory and archival checklist, approved by Finance and IT leadership o Secure retention of legacy payroll, timesheet, and personnel records in accordance with CPA’s record-retention policy o Verification testing to confirm data completeness and accessibility before decommissioning any legacy system o Written approval by the Chief Financial Officer prior to system cutover

About Allowable Costs / Cost Principles →
2024-004
Special Tests & Provisions
MATERIAL WEAKNESSOTHER MATTERS

Special Tests & Provisions – Program Governance, Program - Head Start

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Special Tests & Provisions – Program Governance, Program - Head Start

Corrective Action Plan

Management acknowledge the auditors findings and is working with the Start Early Policy Council to incorporate the required oversight activities into the meetings.

About Special Tests and Provisions →

FY 2023-06-30

$1,482,127 federal awards expended

FAC accepted this audit on December 17, 2024 — management decision was due June 17, 2025.

2023-002
Reporting
MATERIAL WEAKNESSREPEAT OF 2022-002OTHER MATTERS

Reporting Major Program – Head Start Assistance Listing Number – 93.600 Federal Agency – U.S. Department of Health and Human Services Pass-Through Entity – Start Early Grant Numbers – 05CH011953/03, 05CH011953 Award Periods – January 1, 2022 through December 31, 2023, and January 1, 2023 through December 31, 2024 Criteria or Specific Requirement – The Association has reporting requirements under its contract with the pass-through grantor, where the pass-through grantor requires reports to be submitted within 15 days of month end. Condition – In testing the contract reporting requirements between the Association and the pass-through entity, we noted that the required reports were not completed and submitted in accordance with the required due dates or that the submission date of the reports were not available for review. Context – 3 reports were selected for testing and 2 of the reports were submitted beyond the fifteen-day requirement. The November 2022 report was due December 15, 2022, and was submitted December 27, 2022. The May 2023 report was due June 15, 2023, and was submitted June 28, 2023. A nonstatistical sampling methodology was used to select the sample. Questioned Costs – None. Effect – Reporting requirements were not met in accordance with the requirements stipulated under the Association’s contract with the pass-through grantor. Cause – Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding – Yes; 2017-004, 2018-004, 2019-003, 2020-003, 2021-003, 2022-002 Recommendation – We recommend that the Association implement policies and procedures to ensure compliance with all reporting due dates and other requirements. Views of Responsible Officials and Planned Corrective Actions – Concur. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of the reports.

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Reporting Major Program – Head Start Assistance Listing Number – 93.600 Federal Agency – U.S. Department of Health and Human Services Pass-Through Entity – Start Early Grant Numbers – 05CH011953/03, 05CH011953 Award Periods – January 1, 2022 through December 31, 2023, and January 1, 2023 through December 31, 2024 Criteria or Specific Requirement – The Association has reporting requirements under its contract with the pass-through grantor, where the pass-through grantor requires reports to be submitted within 15 days of month end. Condition – In testing the contract reporting requirements between the Association and the pass-through entity, we noted that the required reports were not completed and submitted in accordance with the required due dates or that the submission date of the reports were not available for review. Context – 3 reports were selected for testing and 2 of the reports were submitted beyond the fifteen-day requirement. The November 2022 report was due December 15, 2022, and was submitted December 27, 2022. The May 2023 report was due June 15, 2023, and was submitted June 28, 2023. A nonstatistical sampling methodology was used to select the sample. Questioned Costs – None. Effect – Reporting requirements were not met in accordance with the requirements stipulated under the Association’s contract with the pass-through grantor. Cause – Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding – Yes; 2017-004, 2018-004, 2019-003, 2020-003, 2021-003, 2022-002 Recommendation – We recommend that the Association implement policies and procedures to ensure compliance with all reporting due dates and other requirements. Views of Responsible Officials and Planned Corrective Actions – Concur. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of the reports.

Corrective Action Plan

Reporting – The Association agrees that certain monthly reports were not submitted in accordance with due dates. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of monthly reports. Anticipated Completion Date - December 31, 2024; Responsible Contact Person for Planned Corrective Action - LaToyia Neal, CFO

Prior Finding References

2022-002

About Reporting →

FY 2022-06-30

$1,420,869 federal awards expended

FAC accepted this audit on December 22, 2023 — management decision was due June 22, 2024.

2022-002
Reporting
MATERIAL WEAKNESSREPEAT OF 2021-003OTHER MATTERS

Reporting Major Program – Head Start Assistance Listing Number – 93.600 Federal Agency – U.S. Department of Health and Human Services Pass-Through Entity – Start Early Grant Numbers – 05CH011953/01, 05CH8456/06, 05HE001067-01-01, 05HE00106701 Award Periods – January 1, 2021 through December 31, 2022, and January 1, 2022 through December 31, 2023 Criteria or Specific Requirement – The Association has reporting requirements under its contract with the pass-through grantor, where the pass-through grantor requires reports to be submitted within 20 days of month end. Condition – In testing the contract reporting requirements between the Association and the pass-through entity, we noted that the required reports were not completed and submitted in accordance with the required due dates or that the submission date of the reports were not available for review. Context – 6 reports were selected for testing and 2 of the reports were submitted beyond the twenty-day requirement. The other 4 selected for testing did not have evidence of when the reports were submitted and were unable to determine if they were submitted on time. A nonstatistical sampling methodology was used to select the sample. Questioned Costs – None. Effect – Reporting requirements were not met in accordance with the requirements stipulated under the Association’s contract with the pass-through grantor. Cause – Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding – Yes; 2017-004, 2018-004, 2019-003, 2020-003, 2021-003 Recommendation – We recommend that the Association implement policies and procedures to ensure compliance with all reporting due dates and other requirements. The Association should also retain copies of all reports including the formal sign off and review. Views of Responsible Officials and Planned Corrective Actions – Concur. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of the reports, including implementing procedures to ensure the final reports with the documented review and approval are retained.

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Full finding narrative

Reporting Major Program – Head Start Assistance Listing Number – 93.600 Federal Agency – U.S. Department of Health and Human Services Pass-Through Entity – Start Early Grant Numbers – 05CH011953/01, 05CH8456/06, 05HE001067-01-01, 05HE00106701 Award Periods – January 1, 2021 through December 31, 2022, and January 1, 2022 through December 31, 2023 Criteria or Specific Requirement – The Association has reporting requirements under its contract with the pass-through grantor, where the pass-through grantor requires reports to be submitted within 20 days of month end. Condition – In testing the contract reporting requirements between the Association and the pass-through entity, we noted that the required reports were not completed and submitted in accordance with the required due dates or that the submission date of the reports were not available for review. Context – 6 reports were selected for testing and 2 of the reports were submitted beyond the twenty-day requirement. The other 4 selected for testing did not have evidence of when the reports were submitted and were unable to determine if they were submitted on time. A nonstatistical sampling methodology was used to select the sample. Questioned Costs – None. Effect – Reporting requirements were not met in accordance with the requirements stipulated under the Association’s contract with the pass-through grantor. Cause – Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding – Yes; 2017-004, 2018-004, 2019-003, 2020-003, 2021-003 Recommendation – We recommend that the Association implement policies and procedures to ensure compliance with all reporting due dates and other requirements. The Association should also retain copies of all reports including the formal sign off and review. Views of Responsible Officials and Planned Corrective Actions – Concur. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of the reports, including implementing procedures to ensure the final reports with the documented review and approval are retained.

Corrective Action Plan

2022-001, Account Reconciliations and Journal Entries – Management concurs that certain areas were not reconciled in a timely manner and audit adjustments were identified. The Association has hired a new Chief Financial Officer who reviewed the performance of the department, and replaced staff where needed. The Association added another Accountant to increase the capacity of the department. Anticipated Completion Date - December 30, 2023; Responsible Contact Person for Planned Corrective Action - LaToyia Neal, CFO

Prior Finding References

2021-003

About Reporting →

FY 2021-06-30

$1,657,077 federal awards expended

FAC accepted this audit on December 19, 2022 — management decision was due June 19, 2023.

2021-002
Cost Allowability
MATERIAL WEAKNESSREPEAT OF 2020-002OTHER MATTERS

2021-002 Cost Allocation Process Major Program ? Head Start Assistance Listing Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Ounce of Prevention Grant Numbers ? 05CH011953/01 and 05CH8456/06 Award Periods ? January 1, 2019 through December 31, 2020, and January 1, 2020 through December 31, 2021 Criteria or Specific Requirement ? An organization?s system of internal control should include policies and procedures to ensure that charges to federal awards are allowable and properly incurred as part of the federal program. Condition ? Management establishes a cost allocation plan for certain indirect and administrative personnel costs based upon anticipated time to be incurred by the federal program. Throughout the grant period, actual time incurred is reviewed by management and adjustments to the grant will be made if needed. In testing personnel salary and wage expense charged to the program we were unable to examine documentation of a formal review and approval by management of the process taking place as evidenced by management signature. Questioned Costs ? None. Context ?The Association prepares monthly spreadsheets that includes the detail and the allocation of expenses. The spreadsheet is reviewed and signed off each month by the Chief Financial Officer. For 3 of the 5 months selected for testing, the signed copies were not available for review. These months were in the first part of the fiscal year. This resulted in for 14 of 60 disbursements selected for testing, the employee?s time or the nonpayroll invoice was allocated and we were unable to examine documentation of performance of the review and approval process. A nonstatistical sampling methodology was used to select the sample. Effect ? Certain costs may not have been reasonably allocated and the grant may have been charged for unauthorized costs. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2018-002, 2019-002, 2020-002 Recommendation ? We recommend that management fully document performance of employee activity by a knowledgeable supervisor on a monthly basis. Monthly reports should be properly signed and retained for evidence of the review. Views of Responsible Officials and Planned Corrective Actions ? Concur. The new CFO is reviewing all allocations and applying the approved methodology to the current year budget in the accounting system.

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2021-002 Cost Allocation Process Major Program ? Head Start Assistance Listing Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Ounce of Prevention Grant Numbers ? 05CH011953/01 and 05CH8456/06 Award Periods ? January 1, 2019 through December 31, 2020, and January 1, 2020 through December 31, 2021 Criteria or Specific Requirement ? An organization?s system of internal control should include policies and procedures to ensure that charges to federal awards are allowable and properly incurred as part of the federal program. Condition ? Management establishes a cost allocation plan for certain indirect and administrative personnel costs based upon anticipated time to be incurred by the federal program. Throughout the grant period, actual time incurred is reviewed by management and adjustments to the grant will be made if needed. In testing personnel salary and wage expense charged to the program we were unable to examine documentation of a formal review and approval by management of the process taking place as evidenced by management signature. Questioned Costs ? None. Context ?The Association prepares monthly spreadsheets that includes the detail and the allocation of expenses. The spreadsheet is reviewed and signed off each month by the Chief Financial Officer. For 3 of the 5 months selected for testing, the signed copies were not available for review. These months were in the first part of the fiscal year. This resulted in for 14 of 60 disbursements selected for testing, the employee?s time or the nonpayroll invoice was allocated and we were unable to examine documentation of performance of the review and approval process. A nonstatistical sampling methodology was used to select the sample. Effect ? Certain costs may not have been reasonably allocated and the grant may have been charged for unauthorized costs. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2018-002, 2019-002, 2020-002 Recommendation ? We recommend that management fully document performance of employee activity by a knowledgeable supervisor on a monthly basis. Monthly reports should be properly signed and retained for evidence of the review. Views of Responsible Officials and Planned Corrective Actions ? Concur. The new CFO is reviewing all allocations and applying the approved methodology to the current year budget in the accounting system.

Corrective Action Plan

Cost Allocation - Management concurs that management review of the salary allocations is not properly documented. The new CFO is reviewing all allocations and applying the approved methodology to the current year budget in the accounting system. Management also developed system to ensure all reports and monthly signoffs are approved and retained. Anticipated Completion Date - December 30, 2022; Responsible Contact Person for Planned Corrective Action: LaToyia Neal, CFO.

Prior Finding References

2020-002

About Allowable Costs / Cost Principles →
2021-003
Reporting
MATERIAL WEAKNESSREPEAT OF 2020-003OTHER MATTERS

2020-003 Reporting Major Program ? Head Start Assistance Listing Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Ounce of Prevention Grant Numbers ? 05CH011953/01 and 05CH8456/06 Award Periods ? January 1, 2019 through December 31, 2020, and January 1, 2020 through December 31, 2021 Criteria or Specific Requirement ? The Association has reporting requirements under its contract with the pass-through grantor, where the pass-through grantor requires reports to be submitted within 20 days of month end. Condition ? In testing the contract reporting requirements between the Association and the pass-through entity, we noted that the required reports were not completed and submitted in accordance with the required due dates or that the submission date of the reports were not available for review. Context ? 6 reports were selected for testing and 2 of the reports were submitted beyond the twenty day requirement. The other 4 selected for testing did not have evidence of when the reports were submitted and were unable to determine if they were submitted on time. A nonstatistical sampling methodology was used to select the sample. Questioned Costs ? None. Effect ? Reporting requirements were not met in accordance with the requirements stipulated under the Association?s contract with the pass-through grantor. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2017-004, 2018-004, 2019-003, 2020-003 Recommendation ? We recommend that the Association implement policies and procedures to ensure compliance with all reporting due dates and other requirements. The Association should also retain copies of all reports including the formal sign off and review. Views of Responsible Officials and Planned Corrective Actions ? Concur. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of the reports, including implementing procedures to ensure the final reports with the documented review and approval are retained.

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2020-003 Reporting Major Program ? Head Start Assistance Listing Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Ounce of Prevention Grant Numbers ? 05CH011953/01 and 05CH8456/06 Award Periods ? January 1, 2019 through December 31, 2020, and January 1, 2020 through December 31, 2021 Criteria or Specific Requirement ? The Association has reporting requirements under its contract with the pass-through grantor, where the pass-through grantor requires reports to be submitted within 20 days of month end. Condition ? In testing the contract reporting requirements between the Association and the pass-through entity, we noted that the required reports were not completed and submitted in accordance with the required due dates or that the submission date of the reports were not available for review. Context ? 6 reports were selected for testing and 2 of the reports were submitted beyond the twenty day requirement. The other 4 selected for testing did not have evidence of when the reports were submitted and were unable to determine if they were submitted on time. A nonstatistical sampling methodology was used to select the sample. Questioned Costs ? None. Effect ? Reporting requirements were not met in accordance with the requirements stipulated under the Association?s contract with the pass-through grantor. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2017-004, 2018-004, 2019-003, 2020-003 Recommendation ? We recommend that the Association implement policies and procedures to ensure compliance with all reporting due dates and other requirements. The Association should also retain copies of all reports including the formal sign off and review. Views of Responsible Officials and Planned Corrective Actions ? Concur. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of the reports, including implementing procedures to ensure the final reports with the documented review and approval are retained.

Corrective Action Plan

Reporting ? The Association agrees that certain monthly reports were not submitted in accordance with due dates. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of monthly reports. Anticipated Completion Date - December 30, 2022; Responsible Contact Person for Planned Corrective Action: LaToyia Neal, CFO.

Prior Finding References

2020-003

About Reporting →

FY 2020-06-30

$1,616,003 federal awards expended

FAC accepted this audit on November 30, 2021 — management decision was due May 30, 2022.

2020-002
Cost Allowability
MATERIAL WEAKNESSREPEAT OF 2019-002OTHER MATTERS

2020-002 ? Cost Allocation Process Major Program ? Head Start Assistance Listing Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Ounce of Prevention Grant Numbers ? 05CH8456-04 and 05CH8456-05 Award Periods ? January 1, 2018 through December 31, 2019, and January 1, 2019 through December 31, 2020 Criteria or Specific Requirement ? An organization?s system of internal control should include policies and procedures to ensure that charges to federal awards are allowable and properly incurred as part of the federal program. Condition ? Management establishes a cost allocation plan for certain indirect and administrative personnel costs based upon anticipated time to be incurred by the federal program. Throughout the grant period, actual time incurred is reviewed by management and adjustments to the grant will be made if needed. In testing personnel salary and wage expense charged to the program we were unable to examine documentation of a formal review and approval by management of the process taking place as evidenced by management signature. Questioned Costs ? None. Context ? For 12 of 40 disbursements selected for testing, the employee?s time was allocated and we were unable to examine documentation of performance of the review and approval process. A nonstatistical sampling methodology was used to select the sample. Effect ? Certain costs may not have been reasonably allocated and the grant may have been charged for unauthorized costs. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2018-002, 2019-002 Recommendation ? We recommend that management fully document performance of employee activity by a knowledgeable supervisor on a monthly basis. Views of Responsible Officials and Planned Corrective Actions ? Concur. The new CFO is reviewing all allocations and applying the approved methodology to the current year budget in the accounting system.

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2020-002 ? Cost Allocation Process Major Program ? Head Start Assistance Listing Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Ounce of Prevention Grant Numbers ? 05CH8456-04 and 05CH8456-05 Award Periods ? January 1, 2018 through December 31, 2019, and January 1, 2019 through December 31, 2020 Criteria or Specific Requirement ? An organization?s system of internal control should include policies and procedures to ensure that charges to federal awards are allowable and properly incurred as part of the federal program. Condition ? Management establishes a cost allocation plan for certain indirect and administrative personnel costs based upon anticipated time to be incurred by the federal program. Throughout the grant period, actual time incurred is reviewed by management and adjustments to the grant will be made if needed. In testing personnel salary and wage expense charged to the program we were unable to examine documentation of a formal review and approval by management of the process taking place as evidenced by management signature. Questioned Costs ? None. Context ? For 12 of 40 disbursements selected for testing, the employee?s time was allocated and we were unable to examine documentation of performance of the review and approval process. A nonstatistical sampling methodology was used to select the sample. Effect ? Certain costs may not have been reasonably allocated and the grant may have been charged for unauthorized costs. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2018-002, 2019-002 Recommendation ? We recommend that management fully document performance of employee activity by a knowledgeable supervisor on a monthly basis. Views of Responsible Officials and Planned Corrective Actions ? Concur. The new CFO is reviewing all allocations and applying the approved methodology to the current year budget in the accounting system.

Corrective Action Plan

Management concurs that management review of the salary allocations is not properly documented. The new CFO is reviewing all allocations and applying the approved methodology to the current year budget in the accounting system. Anticipated completion date - November 30, 2021; Responsible Contact - LaToyia Neal, CFO.

Prior Finding References

2019-002

About Allowable Costs / Cost Principles →
2020-003
Reporting
MATERIAL WEAKNESSREPEAT OF 2019-003OTHER MATTERS

2020-003 ? Reporting Major Program ? Head Start Assistance Listing Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Ounce of Prevention Grant Numbers ? 05CH8456-04 and 05CH8456-05 Award Periods ? January 1, 2019 through December 31, 2020, and January 1, 2020 through December 31, 2021 Criteria or Specific Requirement ? The Association has reporting requirements under its contract with the pass-through grantor, where the pass-through grantor requires reports to be submitted within 20 days of month end. Condition ? In testing the contract reporting requirements between the Association and the pass-through entity, we noted that the required quarterly and monthly reports were not completed and submitted in accordance with the required due dates. Questioned Costs ? None. Context ? We noted that for 4 monthly reports out of 4 selected for testing were not submitted by the required due dates. The reports were properly supported and completed but after the due date established by the pass-through grantor. A nonstatistical sampling methodology was used to select the sample. Effect ? Reporting requirements were not met in accordance with the requirements stipulated under the Association?s contract with the pass-through grantor. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2017-004, 2018-004, 2019-003 Recommendation ? We recommend that the Association implement policies and procedures to ensure compliance with all reporting due dates and other requirements. Views of Responsible Officials and Planned Corrective Actions ? Concur. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of monthly reports.

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Full finding narrative

2020-003 ? Reporting Major Program ? Head Start Assistance Listing Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through Entity ? Ounce of Prevention Grant Numbers ? 05CH8456-04 and 05CH8456-05 Award Periods ? January 1, 2019 through December 31, 2020, and January 1, 2020 through December 31, 2021 Criteria or Specific Requirement ? The Association has reporting requirements under its contract with the pass-through grantor, where the pass-through grantor requires reports to be submitted within 20 days of month end. Condition ? In testing the contract reporting requirements between the Association and the pass-through entity, we noted that the required quarterly and monthly reports were not completed and submitted in accordance with the required due dates. Questioned Costs ? None. Context ? We noted that for 4 monthly reports out of 4 selected for testing were not submitted by the required due dates. The reports were properly supported and completed but after the due date established by the pass-through grantor. A nonstatistical sampling methodology was used to select the sample. Effect ? Reporting requirements were not met in accordance with the requirements stipulated under the Association?s contract with the pass-through grantor. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2017-004, 2018-004, 2019-003 Recommendation ? We recommend that the Association implement policies and procedures to ensure compliance with all reporting due dates and other requirements. Views of Responsible Officials and Planned Corrective Actions ? Concur. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of monthly reports.

Corrective Action Plan

The Association agrees that certain monthly reports were not submitted in accordance with due dates. The Association has hired a Grant Administrator whose responsibility is to ensure timely submission of monthly reports. Anticipated completion date - November 30, 2021; Responsible Contact - LaToyia Neal, CFO.

Prior Finding References

2019-003

About Reporting →

FY 2019-06-30

$1,478,842 federal awards expended

FAC accepted this audit on November 30, 2020 — management decision was due May 30, 2021.

2019-002
Cost Allowability
MATERIAL WEAKNESSREPEAT OF 2018-002OTHER MATTERS

2019-002 ? Cost Allocation Process Major Program ? Head Start CFDA Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through entity ? Ounce of Prevention Grant Number ? 05CH8456-04 and 05CH8456-05 Award Period ? January 1, 2018 through December 31, 2019 and January 1, 2019 through December 31, 2020 Criteria or specific requirement ? An organization?s system of internal control should include policies and procedures to ensure that charges to federal awards are allowable and properly incurred as part of the federal program. Condition ? Management establishes a cost allocation plan for certain indirect and administrative personnel costs based upon anticipated time to be incurred by the federal program. Throughout the grant period, actual time incurred is reviewed by management and adjustments to the grant will be made if needed. In testing personnel salary and wage expense charged to the program we were unable to examine documentation of a formal review and approval by management of the process taking place as evidenced by management signature. Questioned costs ? None. Context ? For 13 of 40 disbursements selected for testing, the employee?s time was allocated and we were unable to examine documentation of performance of the review and approval process. A non-statistical sampling methodology was used to select the sample. Effect ? Certain costs may not have been charged to the federal program. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2018-002 Recommendation ? We recommend that management fully document performance of their after-the-fact determination of employee activity by a knowledgeable supervisor on a monthly basis. Views of responsible officials and planned corrective actions ? Concur. The Association will engage a consultant that is an expert on cost allocation compliance for federal funding for a recommendation of what is necessary for indirect salary and recording.

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Full finding narrative

2019-002 ? Cost Allocation Process Major Program ? Head Start CFDA Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through entity ? Ounce of Prevention Grant Number ? 05CH8456-04 and 05CH8456-05 Award Period ? January 1, 2018 through December 31, 2019 and January 1, 2019 through December 31, 2020 Criteria or specific requirement ? An organization?s system of internal control should include policies and procedures to ensure that charges to federal awards are allowable and properly incurred as part of the federal program. Condition ? Management establishes a cost allocation plan for certain indirect and administrative personnel costs based upon anticipated time to be incurred by the federal program. Throughout the grant period, actual time incurred is reviewed by management and adjustments to the grant will be made if needed. In testing personnel salary and wage expense charged to the program we were unable to examine documentation of a formal review and approval by management of the process taking place as evidenced by management signature. Questioned costs ? None. Context ? For 13 of 40 disbursements selected for testing, the employee?s time was allocated and we were unable to examine documentation of performance of the review and approval process. A non-statistical sampling methodology was used to select the sample. Effect ? Certain costs may not have been charged to the federal program. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2018-002 Recommendation ? We recommend that management fully document performance of their after-the-fact determination of employee activity by a knowledgeable supervisor on a monthly basis. Views of responsible officials and planned corrective actions ? Concur. The Association will engage a consultant that is an expert on cost allocation compliance for federal funding for a recommendation of what is necessary for indirect salary and recording.

Corrective Action Plan

Cost Allocation - Management concurs that management review of the salary allocations is not properly documented. The Association will engage a consultant that is an expert on cost allocation compliance for federal funding for a recommendation of what is necessary for indirect salary and recording. Anticipated Complete Date - 12/31/20; Responsible Contact Person for Planned Corrective Action - Farland Jenkins, CFO

Prior Finding References

2018-002

About Allowable Costs / Cost Principles →
2019-003
Reporting
MATERIAL WEAKNESSREPEAT OF 2018-004OTHER MATTERS

2019-003 ? Reporting Major Program ? Head Start CFDA Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through entity ? Ounce of Prevention Grant Number ? 05CH8456-04 and 05CH8456-05 Award Period ? January 1, 2018 through December 31, 2019 and January 1, 2019 through December 31, 2020 Criteria or specific requirement ? The Association has reporting requirements under its contract with the pass-through grantor, where the pass-through grantor requires reports to be submitted within 20 days of month end. Condition ? In testing the contract reporting requirements between the Association and the pass-through entity, we noted that the required quarterly and monthly reports were not completed and submitted in accordance with the required due dates. Questioned costs ? None. Context ? We noted that four out of the four monthly reports selected for testing were not submitted by the required due dates. The reports were properly supported and completed but after the due date established by the pass-through grantor. A non-statistical sampling methodology was used to select the sample. Effect ? Reporting requirements were not met in accordance with the requirements stipulated under the Association?s contract with the pass-through grantor. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2017-004, 2018-004 Recommendation ? We recommend that the Association implement policies and procedures to ensure compliance with all reporting due dates and other requirements. Views of responsible officials and planned corrective actions ? Concur. The Association has hired a Grant Controller whose responsibility is to ensure timely submission of monthly reports.

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2019-003 ? Reporting Major Program ? Head Start CFDA Number ? 93.600 Federal Agency ? U.S. Department of Health and Human Services Pass-Through entity ? Ounce of Prevention Grant Number ? 05CH8456-04 and 05CH8456-05 Award Period ? January 1, 2018 through December 31, 2019 and January 1, 2019 through December 31, 2020 Criteria or specific requirement ? The Association has reporting requirements under its contract with the pass-through grantor, where the pass-through grantor requires reports to be submitted within 20 days of month end. Condition ? In testing the contract reporting requirements between the Association and the pass-through entity, we noted that the required quarterly and monthly reports were not completed and submitted in accordance with the required due dates. Questioned costs ? None. Context ? We noted that four out of the four monthly reports selected for testing were not submitted by the required due dates. The reports were properly supported and completed but after the due date established by the pass-through grantor. A non-statistical sampling methodology was used to select the sample. Effect ? Reporting requirements were not met in accordance with the requirements stipulated under the Association?s contract with the pass-through grantor. Cause ? Staff turnover and lack of formal policies and procedures resulted in the issue noted above. Repeat Finding ? Yes; 2017-004, 2018-004 Recommendation ? We recommend that the Association implement policies and procedures to ensure compliance with all reporting due dates and other requirements. Views of responsible officials and planned corrective actions ? Concur. The Association has hired a Grant Controller whose responsibility is to ensure timely submission of monthly reports.

Corrective Action Plan

Reporting ? The Association agrees that certain monthly reports were not submitted in accordance with due dates. The Association has hired a Grant Controller whose responsibility is to ensure timely submission of monthly reports. Anticipated Completion Date - 12/31/20; Responsible Contact Person for Planned Corrective Action - Farland Jenkins, CFO

Prior Finding References

2018-004

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FY 2018-06-30

$1,428,744 federal awards expended

FAC accepted this audit on March 28, 2019 — management decision was due September 28, 2019.

2018-002
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-003
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-004
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2017-004OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-004

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FY 2017-06-30

$1,264,892 federal awards expended

FAC accepted this audit on March 26, 2018 — management decision was due September 26, 2018.

2017-004
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2016-003OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-003

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FY 2016-06-30

$1,274,801 federal awards expended

FAC accepted this audit on January 3, 2017 — management decision was due July 3, 2017.

2016-002
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-003
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2015-004

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-004

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