EIN: 391445792
UEI: GSA_MIGRATION
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 9, 2022. 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 February 9, 2023, which was (1289 days ago).
What is a management decision? →2019-001 Condition: Management is responsible for the design, installation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. During our audit, we noted that the Organization did not have adequate segregation of duties between processing transactions, recording transactions and preparing the financial statements during 2019. During 2019, the accountant, CEO, and accounting firm that processes the general ledger resigned. Criteria: Segregation of duties is an internal control intended to prevent or decrease the occurrence of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Cause: The lack of segregation of duties is due to the size of the Organization?s operations including the limited number of employees in the finance department and the key role in which the CFO position serves in maintaining the Organization?s general ledger after the accountant, CEO and accounting firm resigned. Recommendation: We recommend that management establish adequate segregation of duties over financial reporting, ensure accounts are independently reviewed and reconciled, and another finance person is added. Views of Responsible Officials and Planned Corrective Actions: Due to the limited staffing, the Organization will contract with an outside management company to complete the general ledger and they will also review a draft of the financial statements.
Views of Responsible Officials and Planned Corrective Actions: Due to the limited staffing, the Organization will contract with an outside management company to complete the general ledger and they will also review a draft of the financial statements.
2019-002 Condition: During our audit, we noted that the internal control system does not include a process for preparing the annual audited financial statements and the related disclosures in accordance with GAAP. Criteria: Management is responsible for maintaining internal controls and for the fair presentation of the financial statements in accordance with U.S. Generally Accepted Accounting Principles (GAAP). Effect: Although the auditors are preparing the financial statements and related footnotes, management of the Organization thoroughly reviews them and accepts responsibility for them. Cause: Management requested that the auditors assist in preparing a draft of the audited financial statements, including the related footnote disclosures. The outsourcing is a result of management?s cost/benefit decision to use our accounting expertise rather than incurring its internal resource cost. Recommendation: We recommend that management continues to make this decision on a cost/benefit basis. Views of Responsible Officials and Planned Corrective Actions: Due to the limited staffing, the Organization will continue to contract with the outside audit firm to complete the statements, but will also work with an outside management company to review a draft of the financial statements.
Views of Responsible Officials and Planned Corrective Actions: Due to the limited staffing, the Organization will continue to contract with the outside audit firm to complete the statements, but will also work with an outside management company to review a draft of the financial statements.
2018-001
2019-003 Condition: During our audit, it was necessary to record multiple material audit adjustments to the trial balance. Criteria: Management is responsible for maintaining accounts and records to enable the preparation of financial statements that are in conformity with U.S. Generally Accepted Accounting Principles (GAAP). Effect: Numerous adjustments were recorded. Cause: The application of GAAP is complex and continues to get even more complicated as new accounting standards updates are issued. As is typical of entities that are the size of the Organization, accounting personnel and management may not possess the technical expertise that enables them to evaluate and record complex transactions in accordance with GAAP. Recommendation: Management applicable staff should consider attending or taking continuing professional education courses to more familiarize themselves with accounting standards or hire an outside management firm to prepare monthly transactions. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will consider the recommendation.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will consider the recommendation.
Section III ? Federal Award Findings and Questioned Costs Finding: COMINGLING OF FUNDS (2019-004) Condition During the year, lump sum deposits were transferred to a related party randomly throughout the year and Project expenses were paid by a related party. This is considered comingling of funds and requires HUD?s approval. Criteria All rents and other receipts of the Project shall be deposited in the name of the Project in a financial institution, whose deposits are insured by an agency of the Federal Government. Such funds shall be withdrawn only in accordance with the Regulatory Agreement with HUD for expenses of the project or for distributions of surplus cash. Effect The Project comingled funds during the year. Recommendation The Project must deposit all receipts and pay all expenses from a bank account in the Project?s name. Advances made for reasonable and necessary operating expenses may be paid from Surplus Cash at the end of the fiscal year. Management?s Response The related party receivables and payables will be paid back. The Project will use its own bank account in the future for all deposits and withdrawals.
Management?s Response The related party receivables and payables will be paid back. The Project will use its own bank account in the future for all deposits and withdrawals.
Section III ? Federal Award Findings and Questioned Costs - Continued Finding: REPORTING (2019-005) Condition The single audit report was not submitted to the Office of Budget and Management in accordance with the reporting requirement. Criteria An Internal Control Framework defining control activities as ?policies and procedures that help ensure Management?s directives are carried out? should be established. This would include preparation of the Schedule of Expenditures of Federal Awards in a timely manner. Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) states that the audit shall be completed and the data collection form shall be submitted within the earlier of 30 days after the receipt of the auditor?s report, or nine months after the end of the audit period. Effect The failure to file required reports reduces transparency on the use of program funds hindering monitoring by the awarding agency. Recommendation We believe that the year-end audit could proceed more quickly by adhering to a schedule and maintaining timely account reconciliations with support attached. The closing schedules should include a list indicating who is responsible to perform each procedure and when completion of each procedure is due and accomplished. The timing of specific procedures should be coordinated with the timing of the need for the information. Progress should be monitored by management to determine that due dates are being met. We recommend that Management review current staffing to determine the sufficiency of resources to adequately close the books at year-end and prepare the financial statements in a timely manner in accordance with requirements. Management?s Response Management believes that this year was an unusual year because of the turnover. It is confident that the preparation of the financial statements will be completed on a timely basis in the future.
Management?s Response Management believes that this year was an unusual year because of the turnover. It is confident that the preparation of the financial statements will be completed on a timely basis in the future.
Section III ? Federal Award Findings and Questioned Costs - Continued Finding: SPECIAL TESTS AND PROVISIONS ? RESIDUAL RECEIPTS (2019-006) Condition During previous years, it was noted that the required deposit to the residual receipts reserve account was not being made timely. The June 30, 2018 deposit has not been made yet. Criteria Deposits to the residual receipts reserve account must be made per the Regulatory Agreement within 60 days of the end of each fiscal year there is surplus cash. Effect The Project did not make the minimum required payment to the residual receipts reserve account timely, which is a breach of the HUD Regulatory Agreement. Recommendation The Project must make the required payment to the residual receipts reserve account in accordance with the HUD Regulatory Agreement. Management?s Response The Project will make the required deposit to the residual receipts reserve account per the HUD Regulatory Agreement.
Management?s Response The Project will make the required deposit to the residual receipts reserve account per the HUD Regulatory Agreement.
2018-003
Section III ? Federal Award Findings and Questioned Costs - Continued Finding: REPORTING (2019-007) Condition The HUD audit report was not submitted to the U.S. Department of Housing and Urban Development Public Indian Housing ? Real Estate Assessment Center (PIC-REAC) in accordance with the reporting requirement. Criteria An Internal Control Framework defining control activities as ?policies and procedures that help ensure Management?s directives are carried out? should be established. This would include preparation of the Supporting Data required by HUD in a timely manner. Uniform Financial Reporting Standards issued by the U.S. Department of Housing and Urban Development, Office of Inspector General, states that the audit shall be completed and electronic submission shall be submitted within 90 days after the end of the fiscal year. Effect The failure to file required reports reduces transparency on the use of program funds hindering monitoring by the awarding agency. Recommendation We believe that the year-end audit could proceed more quickly by adhering to a schedule and maintaining timely account reconciliations with support attached. The closing schedules should include a list indicating who is responsible to perform each procedure and when completion of each procedure is due and accomplished. The timing of specific procedures should be coordinated with the timing of the need for the information. Progress should be monitored by management to determine that due dates are being met. We recommend that Management review current staffing to determine the sufficiency of resources to adequately close the books at year-end and prepare the financial statements in a timely manner in accordance with requirements. Management?s Response Management believes that this year was an unusual year because of the turnover. It is confident that the preparation of the financial statements will be completed on a timely basis in the future.
Management?s Response Management believes that this year was an unusual year because of the turnover. It is confident that the preparation of the financial statements will be completed on a timely basis in the future.
Section III ? Federal Award Findings and Questioned Costs - Continued Finding: UNAUTHORIZED DISTRIBUTIONS (2019-008) Condition The Project disbursed funds for expenses not related to the Project. During the year, Management transferred $147,451 of funds to a related party which are listed as accounts receivable in the financial statements. This related party has an accounts receivable due from the Project of $86,973 from salaries and benefits which were paid on behalf of the Project and a management fee receivable of $7,860. The net amount of $52,618 are funds that were disbursed to the related party but not related to the Project. The Project?s regulatory agreement with HUD stipulates, among other things, that the Project will not make distributions of assets or income to anyone unless first approved by HUD. Criteria The Project?s regulatory agreement with HUD stipulates, among other things, that the Project will not make distributions of assets or income to anyone unless first approved by HUD. Effect The unauthorized distribution of funds prevents the use of those funds for Project purposes. This could also result in the Project losing future funding or require funding on a reimbursable basis. Recommendation The outside entity must repay the Project immediately. Management?s Response The Project should design and implement internal controls over monitoring of cash management, pay back the amount owed to the Project, and ensure personnel have adequate knowledge of cash management requirements.
Management?s Response The Project should design and implement internal controls over monitoring of cash management, pay back the amount owed to the Project, and ensure personnel have adequate knowledge of cash management requirements.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2019. 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 30, 2019, which was (2517 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2017-001
GSA_MIGRATION
GSA_MIGRATION
2017-004
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 17, 2019. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 17, 2019, which was (2561 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2016-001
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 19, 2017. 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 19, 2017, which was (3258 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
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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