EIN: 364483980
UEI: G5SCMGLFKDA8
Audited by: Schneider Downs & Co.
Oversight agency: 19 [Department of State]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 28, 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 28, 2026 (24 days from today).
What is a management decision? →During the audit, it was identified that cash received from federal granting agencies under cost-reimbursement grants prior to year-end were appropriately recorded as refundable advances; however, reimbursable expenditures incurred prior to year-end were not fully recognized as contribution revenue and federal expenditures in the appropriate fiscal year. As a result, audit adjustments were required to recognize contribution revenue and federal expenditures related to costs incurred prior to year-end and to update the SEFA to reflect the corrected expenditures. The updated SEFA resulted in an additional federal program being identified as a major program subject to audit. Cause: Internal controls were not sufficiently designed to ensure that reimbursement requests submitted to federal granting agencies were evaluated and incorporated into the revenue recognition and SEFA preparation process. Specifically, while cash received in advance was properly recorded as refundable advances, management did not have a control in place to identify reimbursable expenditures incurred prior to year-end and convert refundable advances to contribution revenue and federal expenditures in the appropriate fiscal period. Effect: Failure to recognize reimbursable grant revenue and federal expenditures in the proper fiscal year resulted in the understatement of contribution revenue and federal expenditures, including amounts reported on the SEFA, prior to audit adjustments. This condition affected the determination of major programs and increased the risk that federal awards may not be accurately reported for audit purposes. Questioned Costs: None. Recommendation: We recommend that management strengthen internal controls over cost-reimbursement grant accounting by implementing procedures to ensure that reimbursable expenditures are identified, reviewed, and recorded in the appropriate fiscal year. This should include reconciliation of reimbursement requests, refundable advances, recorded revenue, and amounts reported on the SEFA, along with documented supervisory review of year-end cutoff procedures. Views of Responsible Officials: Management acknowledges the above finding and will continue to enhance its year-end grant review and reconciliation procedures. During the year ended June 30, 2025, management implemented enhanced grant accounting practices, including engaging an outsourced accounting firm. Management also clarified roles and responsibilities related to federal reporting requirements and implemented additional oversight and training. Management remains committed to the ongoing improvement of internal controls over federal grant reporting and compliance.
Show full finding ▾Hide full finding ▴Criteria: Management is responsible for the preparation and fair presentation of the financial statements in accordance with U.S. generally accepted accounting principles (GAAP), including the proper timing of revenue recognition for costreimbursement grants in accordance with Accounting Standards Codification (ASC) 958. In addition, 2 CFR 200.303 – Internal Controls requires nonfederal entities to establish and maintain effective internal control over financial reporting and compliance to provide reasonable assurance that transactions are recorded in the proper accounting period. Further, 2 CFR 200.510(b) requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) that accurately reflects federal expenditures for the fiscal year. Condition: During the audit, it was identified that cash received from federal granting agencies under cost-reimbursement grants prior to year-end were appropriately recorded as refundable advances; however, reimbursable expenditures incurred prior to year-end were not fully recognized as contribution revenue and federal expenditures in the appropriate fiscal year. As a result, audit adjustments were required to recognize contribution revenue and federal expenditures related to costs incurred prior to year-end and to update the SEFA to reflect the corrected expenditures. The updated SEFA resulted in an additional federal program being identified as a major program subject to audit. Cause: Internal controls were not sufficiently designed to ensure that reimbursement requests submitted to federal granting agencies were evaluated and incorporated into the revenue recognition and SEFA preparation process. Specifically, while cash received in advance was properly recorded as refundable advances, management did not have a control in place to identify reimbursable expenditures incurred prior to year-end and convert refundable advances to contribution revenue and federal expenditures in the appropriate fiscal period. Effect: Failure to recognize reimbursable grant revenue and federal expenditures in the proper fiscal year resulted in the understatement of contribution revenue and federal expenditures, including amounts reported on the SEFA, prior to audit adjustments. This condition affected the determination of major programs and increased the risk that federal awards may not be accurately reported for audit purposes. Questioned Costs: None. Recommendation: We recommend that management strengthen internal controls over cost-reimbursement grant accounting by implementing procedures to ensure that reimbursable expenditures are identified, reviewed, and recorded in the appropriate fiscal year. This should include reconciliation of reimbursement requests, refundable advances, recorded revenue, and amounts reported on the SEFA, along with documented supervisory review of year-end cutoff procedures. Views of Responsible Officials: Management acknowledges the above finding and will continue to enhance its year-end grant review and reconciliation procedures. During the year ended June 30, 2025, management implemented enhanced grant accounting practices, including engaging an outsourced accounting firm. Management also clarified roles and responsibilities related to federal reporting requirements and implemented additional oversight and training. Management remains committed to the ongoing improvement of internal controls over federal grant reporting and compliance.
Finding: 2025-001 Reimbursable federal grant revenue Responsible Person: Cecilia Frerotte Title: Contract CFO Phone Number: 617-261-8186 Anticipated Completion Date: June 30, 2026 Corrective Action: Management will enhance grant review and reconciliation procedures to ensure that reimbursable expenditures incurred under cost-reimbursement grants are properly recognized as contribution revenue and federal expenditures in the appropriate period. These procedures will include a grant-by-grant reconciliation of reimbursement requests, refundable advances, award terms, general ledger balances, amounts reported on the Schedule of Expenditures of Federal Awards (SEFA) and amounts reported in all other grant-related compliance reports, as applicable. Management will also formalize and expand supervisory review and approval controls over all grant compliance reporting and year end financial reporting, including the SEFA. In addition, the Board plans to increase the size of the Audit Committee to include members with substantial experience in auditing and grant program oversight. The Audit Committee will meet regularly with both the external auditors and the outsourced accounting firm to provide enhanced governance and oversight of grant accounting and compliance matters.
FAC accepted this audit on June 17, 2026 — management decision was due December 17, 2026.
During the audit, it was identified that cash received from federal granting agencies under cost-reimbursement grants prior to year-end were appropriately recorded as refundable advances; however, reimbursable expenditures incurred prior to year-end were not fully recognized as contribution revenue and federal expenditures in the appropriate fiscal year. As a result, audit adjustments were required to recognize contribution revenue and federal expenditures related to costs incurred prior to year-end and to update the SEFA to reflect the corrected expenditures. The updated SEFA resulted in an additional federal program being identified as a major program subject to audit. Cause: Internal controls were not sufficiently designed to ensure that reimbursement requests submitted to federal granting agencies were evaluated and incorporated into the revenue recognition and SEFA preparation process. Specifically, while cash received in advance was properly recorded as refundable advances, management did not have a control in place to identify reimbursable expenditures incurred prior to year-end and convert refundable advances to contribution revenue and federal expenditures in the appropriate fiscal period. Effect: Failure to recognize reimbursable grant revenue and federal expenditures in the proper fiscal year resulted in the understatement of contribution revenue and federal expenditures, including amounts reported on the SEFA, prior to audit adjustments. This condition affected the determination of major programs and increased the risk that federal awards may not be accurately reported for audit purposes. Questioned Costs: None. Recommendation: We recommend that management strengthen internal controls over cost-reimbursement grant accounting by implementing procedures to ensure that reimbursable expenditures are identified, reviewed, and recorded in the appropriate fiscal year. This should include reconciliation of reimbursement requests, refundable advances, recorded revenue, and amounts reported on the SEFA, along with documented supervisory review of year-end cutoff procedures. Views of Responsible Officials: Management acknowledges the above finding and will continue to enhance its year-end grant review and reconciliation procedures. During the year ended June 30, 2025, management implemented enhanced grant accounting practices, including engaging an outsourced accounting firm. Management also clarified roles and responsibilities related to federal reporting requirements and implemented additional oversight and training. Management remains committed to the ongoing improvement of internal controls over federal grant reporting and compliance.
Show full finding ▾Hide full finding ▴Criteria: Management is responsible for the preparation and fair presentation of the financial statements in accordance with U.S. generally accepted accounting principles (GAAP), including the proper timing of revenue recognition for costreimbursement grants in accordance with Accounting Standards Codification (ASC) 958. In addition, 2 CFR 200.303 – Internal Controls requires nonfederal entities to establish and maintain effective internal control over financial reporting and compliance to provide reasonable assurance that transactions are recorded in the proper accounting period. Further, 2 CFR 200.510(b) requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) that accurately reflects federal expenditures for the fiscal year. Condition: During the audit, it was identified that cash received from federal granting agencies under cost-reimbursement grants prior to year-end were appropriately recorded as refundable advances; however, reimbursable expenditures incurred prior to year-end were not fully recognized as contribution revenue and federal expenditures in the appropriate fiscal year. As a result, audit adjustments were required to recognize contribution revenue and federal expenditures related to costs incurred prior to year-end and to update the SEFA to reflect the corrected expenditures. The updated SEFA resulted in an additional federal program being identified as a major program subject to audit. Cause: Internal controls were not sufficiently designed to ensure that reimbursement requests submitted to federal granting agencies were evaluated and incorporated into the revenue recognition and SEFA preparation process. Specifically, while cash received in advance was properly recorded as refundable advances, management did not have a control in place to identify reimbursable expenditures incurred prior to year-end and convert refundable advances to contribution revenue and federal expenditures in the appropriate fiscal period. Effect: Failure to recognize reimbursable grant revenue and federal expenditures in the proper fiscal year resulted in the understatement of contribution revenue and federal expenditures, including amounts reported on the SEFA, prior to audit adjustments. This condition affected the determination of major programs and increased the risk that federal awards may not be accurately reported for audit purposes. Questioned Costs: None. Recommendation: We recommend that management strengthen internal controls over cost-reimbursement grant accounting by implementing procedures to ensure that reimbursable expenditures are identified, reviewed, and recorded in the appropriate fiscal year. This should include reconciliation of reimbursement requests, refundable advances, recorded revenue, and amounts reported on the SEFA, along with documented supervisory review of year-end cutoff procedures. Views of Responsible Officials: Management acknowledges the above finding and will continue to enhance its year-end grant review and reconciliation procedures. During the year ended June 30, 2025, management implemented enhanced grant accounting practices, including engaging an outsourced accounting firm. Management also clarified roles and responsibilities related to federal reporting requirements and implemented additional oversight and training. Management remains committed to the ongoing improvement of internal controls over federal grant reporting and compliance.
Finding: 2025-001 Reimbursable federal grant revenue Responsible Person: Cecilia Frerotte Title: Contract CFO Phone Number: 617-261-8186 Anticipated Completion Date: June 30, 2026 Corrective Action: Management will enhance grant review and reconciliation procedures to ensure that reimbursable expenditures incurred under cost-reimbursement grants are properly recognized as contribution revenue and federal expenditures in the appropriate period. These procedures will include a grant-by-grant reconciliation of reimbursement requests, refundable advances, award terms, general ledger balances, amounts reported on the Schedule of Expenditures of Federal Awards (SEFA) and amounts reported in all other grant-related compliance reports, as applicable. Management will also formalize and expand supervisory review and approval controls over all grant compliance reporting and year end financial reporting, including the SEFA. In addition, the Board plans to increase the size of the Audit Committee to include members with substantial experience in auditing and grant program oversight. The Audit Committee will meet regularly with both the external auditors and the outsourced accounting firm to provide enhanced governance and oversight of grant accounting and compliance matters.
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
During the audit, we noted that Asian University for Women (AUW) Support Foundation has not documented its evaluation of the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Subrecipient risk assessments are not being performed and the frequency and magnitude of monitoring procedures are not determined based on results of these risk assessments as required by Uniform Guidance 2 CFR 200. Context: Our testing of subrecipient grants awarded found no evidence that risk assessment had been performed. Cause: No risk assessment policies established with the requirements under the Uniform Guidance in accordance with 2 CFR 200.332(b). Effect: Absence of well-documented risk assessment and monitoring plans related to subrecipients may increase the risk of unallowable costs are claimed by the subrecipients and are not prevented or detected by internal controls. Recommendation: We recommend that the management implement procedures to comply with the Uniform Guidance’s requirements related to the documentation of subrecipients’ risk assessment and monitoring procedures. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan
Show full finding ▾Hide full finding ▴Finding 2024-002: Subrecipient Monitoring - Risk Assessment Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: In accordance with 2 CFR 200.332(b), Asian University for Women (AUW) Support Foundation should evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraph (e) of this section, which may include consideration of such factors as: (1) the subrecipient’s prior experience with the same or similar subawards; (2) the results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) whether the subrecipient has new personnel or new or substantially changed systems; and (4) the extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition: During the audit, we noted that Asian University for Women (AUW) Support Foundation has not documented its evaluation of the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Subrecipient risk assessments are not being performed and the frequency and magnitude of monitoring procedures are not determined based on results of these risk assessments as required by Uniform Guidance 2 CFR 200. Context: Our testing of subrecipient grants awarded found no evidence that risk assessment had been performed. Cause: No risk assessment policies established with the requirements under the Uniform Guidance in accordance with 2 CFR 200.332(b). Effect: Absence of well-documented risk assessment and monitoring plans related to subrecipients may increase the risk of unallowable costs are claimed by the subrecipients and are not prevented or detected by internal controls. Recommendation: We recommend that the management implement procedures to comply with the Uniform Guidance’s requirements related to the documentation of subrecipients’ risk assessment and monitoring procedures. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan
Finding 2024-002: Subrecipient Monitoring – Risk Assessment Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management does not agree that there is a material weakness related to compliance with the grant. Management would like to note the following points: 1) There are two organizations, The Asian University for Woman (AUW), and the Asian University for Woman Support Foundation (AUWSF). These are separate organizations, but AUWSF exists solely to support AUW, and AUWSF is constantly monitoring AUW. 2) The US State Department has emailed that AUW is NOT a subrecipient of AUWSF. This email was forwarded to the auditors. 3) The US State Department has been substantially involved in helping AUWSF carry out this grant work, since 2022, and has not provided any feedback that the AUWSF should be carrying out additional risk assessment procedures on AUW. 4) AUWSF had a fiscal year 2023 single audit, done by the same auditors here, with substantially the same grants and there was no material weakness related to compliance noted during that audit. 5) A variety of information about the AUW and AUWSF including their clean audited financial statements, internal control policies, and other information is documented and publicly available on the AUW and AUWSF’s joint website. 6) AUWSF notes that it actively monitors and reviews the expenditures of the funds they provide to AUW. The funds are paid in installments and only upon satisfactory receipt of documentation of funds expended are subsequent installments sent. AUWSF receives monthly financial statements and bank statements from AUW to further reconfirm the AUW expenditures. Nonetheless, AUWSF takes any potential significant deficiency in internal control very seriously and will seek guidance from the US State Department to clarify this item and implement any necessary changes.
During our testing of the subrecipient for the major program, we concluded management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during our testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Cause: Asian University for Women (AUW) Support Foundation did not comply with FFATA reporting requirements. Effect: Failure to comply with the FFATA requirement may put the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings are immediately filed. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan
Show full finding ▾Hide full finding ▴Finding 2024-003: Reporting Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: The Federal Funding Accountability and Transparency Act, as codified in 2 CFR Part 170, requires prime awardees awarded a federal grant to file a Federal Funding Accountability and Transparency Act (FFATA) report when the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: During our testing of the subrecipient for the major program, we concluded management did not address the FFATA reporting requirements as part of its subrecipient monitoring policies. Questioned Costs: No questioned costs identified. Context: This is a condition identified during our testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Cause: Asian University for Women (AUW) Support Foundation did not comply with FFATA reporting requirements. Effect: Failure to comply with the FFATA requirement may put the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its training to its program personnel to ensure FFATA requirements are clearly and accurately addressed; and any necessary FFATA filings are immediately filed. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan
Finding 2024-003: Subrecipient Monitoring Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management notes the items on finding 2024-002 also applies to this item. Nonetheless the management will implement training on relevant Asian University for Women (AUW) program personnel in the area of Federal Funding Accountability and Transparency Act (FFATA). All such training of relevant personnel is planned to be completed by December 31, 2025.
We tested subrecipient awards and found that there were no official subrecipient grant letters identifying the award and its applicable requirements. Questioned Costs: No questioned costs identified. Context: This is a condition identified during our testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Cause: Asian University for Women (AUW) identifying the award and applicable requirements and described in 2 CFR section 200.332 Effect: Failure to comply with the 2 CFR section 200.332 requirements may put the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its procedures to provide subrecipients with official grant letters that include the requirements under 2 CFR section 200.332. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan
Show full finding ▾Hide full finding ▴Finding 2024-004: Identifying the Award and Applicable Requirements Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: As codified in 2 CFR Part 200.332, requires prime awardees awarded a federal grant to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (2) all requirements imposed by the pass-through entity (PTE) on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award. Condition: We tested subrecipient awards and found that there were no official subrecipient grant letters identifying the award and its applicable requirements. Questioned Costs: No questioned costs identified. Context: This is a condition identified during our testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Cause: Asian University for Women (AUW) identifying the award and applicable requirements and described in 2 CFR section 200.332 Effect: Failure to comply with the 2 CFR section 200.332 requirements may put the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its procedures to provide subrecipients with official grant letters that include the requirements under 2 CFR section 200.332. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan
Finding 2024-004: Identifying the Award and Applicable Requirements Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management notes the items on finding 2024-002 also applies to this item. Nonetheless, AUWSF takes any potential significant deficiency in internal control very seriously and will seek guidance from the US State Department to clarify this item and implement any necessary changes.
FAC accepted this audit on March 30, 2024 — management decision was due September 30, 2024.
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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