EIN: 381359193
UEI: LB2MPMC4BQS4
Audited by: Rehmann Robson LLC
Oversight agency: 21 [Department of the Treasury]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 10, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 10, 2026 (81 days ago).
What is a management decision? →Lack of Independent Review and Approval of Reporting Finding Type. Immaterial Noncompliance. Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Condition. The Organization is required to submit quarterly reports on the grant expenditures, and we noted that these reports are not subjected to an independent review and approval process. Cause. This condition was caused by the lack of understanding by program staff of the specific requirements of reporting. Effect. The Organization was exposed to an increased risk that the reports filed could contain errors and not be detected and corrected on a timely basis. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the Organization review its procedures for compiling financial data for external reporting purposes and develop an independent review process before report submission. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Lack of Independent Review and Approval of Reporting Finding Type. Immaterial Noncompliance. Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Condition. The Organization is required to submit quarterly reports on the grant expenditures, and we noted that these reports are not subjected to an independent review and approval process. Cause. This condition was caused by the lack of understanding by program staff of the specific requirements of reporting. Effect. The Organization was exposed to an increased risk that the reports filed could contain errors and not be detected and corrected on a timely basis. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the Organization review its procedures for compiling financial data for external reporting purposes and develop an independent review process before report submission. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
This was a finding last year. Audit findings were issued in December 2024. There was not time to implement a review process for 2025. Management has agreed upon and developed a review process. Management will implement a formal process requiring an independent review of all federal quarterly grant expenditure reports before submission. The designated reviewer will be a senior staff member or an individual independent of the preparation and approval process. This person will have sufficient expertise in grant management and financial reporting. The reviewer will carefully verify the accuracy of the data, confirm that all expenditures are correctly categorized, ensure compliance with grant terms, and validate calculations.
2024-004
Failure to Implement Required Written Policies Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management and Allowable Costs/Cost Principles). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. There are no written policies in place covering payments, procurement, allowability of costs charged to federal programs, compensation, or travel costs. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance. Questioned Costs. No costs are required to be questioned as a result of this finding. Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Failure to Implement Required Written Policies Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management and Allowable Costs/Cost Principles). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. There are no written policies in place covering payments, procurement, allowability of costs charged to federal programs, compensation, or travel costs. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance. Questioned Costs. No costs are required to be questioned as a result of this finding. Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Management developed and formalized written policies covering payments, procurement, allowability of costs, compensation, and travel costs. These policies clearly outline procedures and approval processes to ensure compliance with Uniform Guidance. They address key areas such as payment processing, procurement protocols, criteria for allowable costs on federal programs, compensation guidelines, and travel reimbursement rules, ensuring consistency and adherence to federal regulations.
2024-005
FAC accepted this audit on December 23, 2024 — management decision was due June 23, 2025.
2024-003 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. There is no procedure in place to determine whether vendors are suspended or debarred. Cause. The Organization did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors or subrecipients involved were actually suspended or debarred. Recommendation. We recommend that the Organization review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-003 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. There is no procedure in place to determine whether vendors are suspended or debarred. Cause. The Organization did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors or subrecipients involved were actually suspended or debarred. Recommendation. We recommend that the Organization review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. During our single audit testing, it was determined that there was no process in place to verify that vendors with transactions in excess of $25,000 were not suspended or debarred. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Auditor Recommendation. We recommend that the Organization review its policies over suspension and debarment review to ensure that they are contracting with allowable vendors. Corrective Action. For Federal grants, management will implement a system for verifying that all vendors or subrecipients with transactions exceeding $25,000 are not suspended or debarred by the federal government, ensuring full compliance with federal regulations and minimizing the risk of using prohibited vendors. A mandatory check against the System for Award Management (SAM) database for suspension and debarment status will occur, with a printout or screenshot of the results maintained. Responsible Person. Chris Sargent, President & Executive Officer Anticipated Completion Date. January 31, 2025
2024-004 – Lack of Independent Review and Approval of Reporting Finding Type. Immaterial Noncompliance. Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Condition. The Organization is required to submit quarterly reports on the grant expenditures, and we noted that these reports are not subjected to an independent review and approval process. Cause. This condition was caused by the lack of understanding by program staff of the specific requirements of reporting. Effect. As a result of this condition, the Organization did not comply fully with the reporting requirements under this federal award. In addition, the Organization was exposed to an increased risk that the reports filed could contain errors and not be detected and corrected on a timely basis. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the Organization review its procedures for compiling financial data for external reporting purposes and develop an independent review process before report submission. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-004 – Lack of Independent Review and Approval of Reporting Finding Type. Immaterial Noncompliance. Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Condition. The Organization is required to submit quarterly reports on the grant expenditures, and we noted that these reports are not subjected to an independent review and approval process. Cause. This condition was caused by the lack of understanding by program staff of the specific requirements of reporting. Effect. As a result of this condition, the Organization did not comply fully with the reporting requirements under this federal award. In addition, the Organization was exposed to an increased risk that the reports filed could contain errors and not be detected and corrected on a timely basis. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the Organization review its procedures for compiling financial data for external reporting purposes and develop an independent review process before report submission. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. During our testing we noted that there was not an independent review performed on quarterly grant expenditure reports before submission. This can cause an increased risk that reports filed could contain errors and not be detected and corrected on a timely basis. Auditor Recommendation. We recommend that the Organization review its procedures for compiling financial data for external reporting purposes and develop an independent review process before report submission. Corrective Action. Management will implement a formal process requiring an independent review of all federal quarterly grant expenditure reports before submission. The designated reviewer will be a senior staff member or an individual independent of the preparation and approval process. This person will have sufficient expertise in grant management and financial reporting. The reviewer will carefully verify the accuracy of the data, confirm that all expenditures are correctly categorized, ensure compliance with grant terms, and validate calculations. Responsible Person. Chris Sargent, President & Executive Officer Anticipated Completion Date. January 31, 2025
2024-005 – Failure to Implement Required Written Policies Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management and Allowable Costs/Cost Principles). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. There are no written policies in place covering payments, procurement, allowability of costs charged to federal programs, compensation, or travel costs. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance. Questioned Costs. No costs are required to be questioned as a result of this finding. Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-005 – Failure to Implement Required Written Policies Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management and Allowable Costs/Cost Principles). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. There are no written policies in place covering payments, procurement, allowability of costs charged to federal programs, compensation, or travel costs. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance. Questioned Costs. No costs are required to be questioned as a result of this finding. Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. There are no written policies in place covering payments, procurement, allowability of costs charged to federal programs, compensation, or travel costs, leading to noncompliance with Uniform Guidance. Auditor Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements. Corrective Action. Management will develop and formalize written policies covering payments, procurement, allowability of costs, compensation, and travel costs. These policies will clearly outline procedures and approval processes to ensure compliance with Uniform Guidance. They will address key areas such as payment processing, procurement protocols, criteria for allowable costs on federal programs, compensation guidelines, and travel reimbursement rules, ensuring consistency and adherence to federal regulations. Responsible Person. Chris Sargent, President & Executive Officer Anticipated Completion Date. March 31, 2025
2024-006– Lack of Independent Review and Approval of Journal Entries in Federal Grant Programs Finding Type. Immaterial Noncompliance. Significant Deficiency in Internal Control over Compliance (Allowable Activities). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. According to 2 CFR 200.303(a), non-Federal entities 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. Condition. The Organization does not have a formal review process in place for journal entries related to its federal grant programs. Journal entries are posted without independent review or approval, increasing the risk of errors or misstatements in the financial records. Cause. The lack of a review process is due to insufficient staffing and inadequate segregation of duties within the accounting department. Effect. Without a review process, there is an increased risk of inaccurate financial reporting and potential non-compliance with federal regulations. This could lead to questioned costs, audit findings, and potential loss of federal funding. Questioned Costs. No costs are required to be questioned as a result of this finding, in as much as no unallowable expenditures were noted. Recommendation. The Organization should implement a formal review and approval process for all journal entries related to federal grant programs. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-006– Lack of Independent Review and Approval of Journal Entries in Federal Grant Programs Finding Type. Immaterial Noncompliance. Significant Deficiency in Internal Control over Compliance (Allowable Activities). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. According to 2 CFR 200.303(a), non-Federal entities 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. Condition. The Organization does not have a formal review process in place for journal entries related to its federal grant programs. Journal entries are posted without independent review or approval, increasing the risk of errors or misstatements in the financial records. Cause. The lack of a review process is due to insufficient staffing and inadequate segregation of duties within the accounting department. Effect. Without a review process, there is an increased risk of inaccurate financial reporting and potential non-compliance with federal regulations. This could lead to questioned costs, audit findings, and potential loss of federal funding. Questioned Costs. No costs are required to be questioned as a result of this finding, in as much as no unallowable expenditures were noted. Recommendation. The Organization should implement a formal review and approval process for all journal entries related to federal grant programs. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. During our testing we noted that there was not an independent review performed on journal entries related to their federal grant program. Without a review process, there is an increased risk of inaccurate financial reporting and potential noncompliance. Auditor Recommendation. We recommend that the Organization implement a formal review and approval process for all journal entries related to federal grant programs. Corrective Action. Management will implement an independent monthly review of all journal entries, including those related to the federal grant programs. The designated reviewer will be a senior accounting team member or equivalent who does not have the ability to create or approve journal entries in the general ledger system. The designated reviewer will compare the entries to ensure proper documentation, accurate amounts, correct coding, and compliance with the applicable federal grant regulations. Any discrepancies or issues identified during the review will be documented, and corrective actions will be taken immediately. The reviewer will sign off on the entries, confirming that all journal entries meet required standards. Responsible Person. Chris Sargent, President & Executive Officer Anticipated Completion Date. March 31, 2025
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