EIN: 411287770
UEI: ZLJEV644D6M9
Audited by: Abdo, LLP
Oversight agency: 84 [Department of Education]
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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 January 7, 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 July 7, 2026 (53 days ago).
What is a management decision? →FAC accepted this audit on November 7, 2024 — management decision was due May 7, 2025.
FAC accepted this audit on November 1, 2023 — management decision was due May 1, 2024.
FAC accepted this audit on November 8, 2022 — management decision was due May 8, 2023.
During our audit, we reviewed procedures within each of the ECSU?s major transaction cycles and found the ECSU to have limited segregation of duties in those transaction cycles. Criteria: There are four general categories of duties: authorization, custody of assets, record keeping and reconciliation. In an ideal system, different employees perform each of these four major functions. In other words, no one person has control of two or more of these responsibilities. Cause: The ECSU has a limited number of staff to properly segregate duties in each of the major transaction cycles. Effect: The effectiveness of the internal control system relies on enforcement by management. The effect of deficiencies in segregation of duties and internal controls can result in undetected errors or misappropriation of assets of the ECSU. Recommendation: While we recognize staff is not large enough to eliminate these deficiencies, we believe the risk can be reduced with sufficient monitoring. The ESCU should evaluate their internal controls on a yearly basis and implement procedures they deem appropriate to reduce the risks involved with this finding. It is important that the Executive Committee is aware of this condition and monitor all financial information. Management Response: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed including review of journal entries and implemented to reduce the risk of fraud and misstatement of financial records. 89
Show full finding ▾Hide full finding ▴2022-001 Limited Segregation of Duties Condition: During our audit, we reviewed procedures within each of the ECSU?s major transaction cycles and found the ECSU to have limited segregation of duties in those transaction cycles. Criteria: There are four general categories of duties: authorization, custody of assets, record keeping and reconciliation. In an ideal system, different employees perform each of these four major functions. In other words, no one person has control of two or more of these responsibilities. Cause: The ECSU has a limited number of staff to properly segregate duties in each of the major transaction cycles. Effect: The effectiveness of the internal control system relies on enforcement by management. The effect of deficiencies in segregation of duties and internal controls can result in undetected errors or misappropriation of assets of the ECSU. Recommendation: While we recognize staff is not large enough to eliminate these deficiencies, we believe the risk can be reduced with sufficient monitoring. The ESCU should evaluate their internal controls on a yearly basis and implement procedures they deem appropriate to reduce the risks involved with this finding. It is important that the Executive Committee is aware of this condition and monitor all financial information. Management Response: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed including review of journal entries and implemented to reduce the risk of fraud and misstatement of financial records. 89
Following is our response to findings in the audit as of June 30, 2022: FINDING 2022-001: Limited Segregation of Duties Our study and evaluation disclosed that because of the limited size of the office staff, the ECSU has limited segregation of duties. CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. 2. Action Planned in Response to Finding: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records. 3. Office Responsible for Ensuring CAP: John Schultz, Executive Director 4. Planned Completion Date for CAP: Not applicable 5. Plan to Monitor Completion of CAP: Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records.
2021-001
FAC accepted this audit on November 17, 2021 — management decision was due May 17, 2022.
During our audit, we reviewed procedures within each of the ECSU?s major transaction cycles and found the ECSU to have limited segregation of duties in those transaction cycles. Criteria: There are four general categories of duties: authorization, custody of assets, record keeping and reconciliation. In an ideal system, different employees perform each of these four major functions. In other words, no one person has control of two or more of these responsibilities. Cause: The ECSU has a limited number of staff to properly segregate duties in each of the major transaction cycles. Effect: The effectiveness of the internal control system relies on enforcement by management. The effect of deficiencies in segregation of duties and internal controls can result in undetected errors or misappropriation of assets of the ECSU. Recommendation: While we recognize staff is not large enough to eliminate these deficiencies, we believe the risk can be reduced with sufficient monitoring. The ESCU should evaluate their internal controls on a yearly basis and implement procedures they deem appropriate to reduce the risks involved with this finding. It is important that the Executive Committee is aware of this condition and monitor all financial information. Management Response: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records.
Show full finding ▾Hide full finding ▴2021-001 Limited Segregation of Duties Condition: During our audit, we reviewed procedures within each of the ECSU?s major transaction cycles and found the ECSU to have limited segregation of duties in those transaction cycles. Criteria: There are four general categories of duties: authorization, custody of assets, record keeping and reconciliation. In an ideal system, different employees perform each of these four major functions. In other words, no one person has control of two or more of these responsibilities. Cause: The ECSU has a limited number of staff to properly segregate duties in each of the major transaction cycles. Effect: The effectiveness of the internal control system relies on enforcement by management. The effect of deficiencies in segregation of duties and internal controls can result in undetected errors or misappropriation of assets of the ECSU. Recommendation: While we recognize staff is not large enough to eliminate these deficiencies, we believe the risk can be reduced with sufficient monitoring. The ESCU should evaluate their internal controls on a yearly basis and implement procedures they deem appropriate to reduce the risks involved with this finding. It is important that the Executive Committee is aware of this condition and monitor all financial information. Management Response: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records.
Following is our response to findings in the audit as of June 30, 2021: FINDING 2021-001: Limited Segregation of Duties Our study and evaluation disclosed that because of the limited size of the office staff, the ECSU has limited segregation of duties. CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. 2. Action Planned in Response to Finding: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records. 3. Office Responsible for Ensuring CAP: Julie Frame, Executive Director 4. Planned Completion Date for CAP: Not applicable 5. Plan to Monitor Completion of CAP: Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records.
2020-001
FAC accepted this audit on November 18, 2020 — management decision was due May 18, 2021.
During our audit, we reviewed procedures within each of the ECSU?s major transaction cycles and found the ECSU to have limited segregation of duties in those transaction cycles. Criteria: There are four general categories of duties: authorization, custody of assets, record keeping and reconciliation. In an ideal system, different employees perform each of these four major functions. In other words, no one person has control of two or more of these responsibilities. Cause: The ECSU has a limited number of staff to properly segregate duties in each of the major transaction cycles. Effect: The effectiveness of the internal control system relies on enforcement by management. The effect of deficiencies in segregation of duties and internal controls can result in undetected errors or misappropriation of assets of the ECSU. Recommendation: While we recognize staff is not large enough to eliminate these deficiencies, we believe the risk can be reduced with sufficient monitoring. The ESCU should evaluate their internal controls on a yearly basis and implement procedures they deem appropriate to reduce the risks involved with this finding. It is important that the Executive Committee is aware of this condition and monitor all financial information. Management Response: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records.
Show full finding ▾Hide full finding ▴2020-001 Limited Segregation of Duties Condition: During our audit, we reviewed procedures within each of the ECSU?s major transaction cycles and found the ECSU to have limited segregation of duties in those transaction cycles. Criteria: There are four general categories of duties: authorization, custody of assets, record keeping and reconciliation. In an ideal system, different employees perform each of these four major functions. In other words, no one person has control of two or more of these responsibilities. Cause: The ECSU has a limited number of staff to properly segregate duties in each of the major transaction cycles. Effect: The effectiveness of the internal control system relies on enforcement by management. The effect of deficiencies in segregation of duties and internal controls can result in undetected errors or misappropriation of assets of the ECSU. Recommendation: While we recognize staff is not large enough to eliminate these deficiencies, we believe the risk can be reduced with sufficient monitoring. The ESCU should evaluate their internal controls on a yearly basis and implement procedures they deem appropriate to reduce the risks involved with this finding. It is important that the Executive Committee is aware of this condition and monitor all financial information. Management Response: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records.
2020-001 Limited Segregation of Duties Condition: During our audit, we reviewed procedures within each of the ECSU?s major transaction cycles and found the ECSU to have limited segregation of duties in those transaction cycles. Criteria: There are four general categories of duties: authorization, custody of assets, record keeping and reconciliation. In an ideal system, different employees perform each of these four major functions. In other words, no one person has control of two or more of these responsibilities. Cause: The ECSU has a limited number of staff to properly segregate duties in each of the major transaction cycles. Effect: The effectiveness of the internal control system relies on enforcement by management. The effect of deficiencies in segregation of duties and internal controls can result in undetected errors or misappropriation of assets of the ECSU. Recommendation: While we recognize staff is not large enough to eliminate these deficiencies, we believe the risk can be reduced with sufficient monitoring. The ESCU should evaluate their internal controls on a yearly basis and implement procedures they deem appropriate to reduce the risks involved with this finding. It is important that the Executive Committee is aware of this condition and monitor all financial information. Management Response: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records.
2019-001
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
During our audit, we reviewed procedures within each of the ECSU?s major transaction cycles and found the ECSU to have limited segregation of duties in those transaction cycles. Criteria: There are four general categories of duties: authorization, custody of assets, record keeping and reconciliation. In an ideal system, different employees perform each of these four major functions. In other words, no one person has control of two or more of these responsibilities. Cause: The ECSU has a limited number of staff to properly segregate duties in each of the major transaction cycles. Effect: The effectiveness of the internal control system relies on enforcement by management. The effect of deficiencies in segregation of duties and internal controls can result in undetected errors or misappropriation of assets of the ECSU. Recommendation: While we recognize staff is not large enough to eliminate these deficiencies, we believe the risk can be reduced with sufficient monitoring. The ESCU should evaluate their internal controls on a yearly basis and implement procedures they deem appropriate to reduce the risks involved with this finding. It is important that the Executive Committee is aware of this condition and monitor all financial information. Management Response: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records.
Show full finding ▾Hide full finding ▴2019-001 Limited Segregation of Duties Condition: During our audit, we reviewed procedures within each of the ECSU?s major transaction cycles and found the ECSU to have limited segregation of duties in those transaction cycles. Criteria: There are four general categories of duties: authorization, custody of assets, record keeping and reconciliation. In an ideal system, different employees perform each of these four major functions. In other words, no one person has control of two or more of these responsibilities. Cause: The ECSU has a limited number of staff to properly segregate duties in each of the major transaction cycles. Effect: The effectiveness of the internal control system relies on enforcement by management. The effect of deficiencies in segregation of duties and internal controls can result in undetected errors or misappropriation of assets of the ECSU. Recommendation: While we recognize staff is not large enough to eliminate these deficiencies, we believe the risk can be reduced with sufficient monitoring. The ESCU should evaluate their internal controls on a yearly basis and implement procedures they deem appropriate to reduce the risks involved with this finding. It is important that the Executive Committee is aware of this condition and monitor all financial information. Management Response: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records.
Following is our response to findings in the audit as of June 30, 2019: FINDING 2019-001: Our study and evaluation disclosed that because of the limited size of the office staff, the ECSU has limited segregation of duties. CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. 2. Action Planned in Response to Finding: Management recognizes the deficiency but determines that it is not economically feasible to correct this finding. Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records. 3. Office Responsible for Ensuring CAP: Julie Frame, Executive Director 4. Planned Completion Date for CAP: Not applicable 5. Plan to Monitor Completion of CAP: Additional internal controls will be developed and implemented to reduce the risk of fraud and misstatement of financial records.
2018-001
FAC accepted this audit on December 10, 2018 — management decision was due June 10, 2019.
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2017-001
FAC accepted this audit on January 22, 2018 — management decision was due July 22, 2018.
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2016-001
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FAC accepted this audit on December 21, 2016 — management decision was due June 21, 2017.
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