EIN: 452137574
UEI: NDXQK346AAH6
Data as of August 19, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 3, 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 3, 2026, which was (78 days ago).
What is a management decision? →Finding 2024-001 Significant Deficiency: Subrecipient Monitoring - Compliance and Control Finding ALN 11.307 – Economic Development Cluster Federal Agency: U.S. Department of Commerce Pass-Through Entity: N/A Criteria Or Specific Requirement: 2 CFR Part 332 requires direct recipients of grants to monitor subrecipients as necessary to ensure that the subaward is used forauthorized purposes. Condition: Audit procedures revealed that a subrecipient submitted an expense reimbursement request for an amount greater than the grant expenses that had beenincurred to date. Cause: Files used to track the subrecipient’s expenses contained formula errors that led to misallocations of funds to charge to the grant. Additionally, controls over subrecipient monitoring were not designed effectively to identify this error. Effect: Instances of noncompliance were not detected by management in a timely manner. Context: Of the 15 subrecipient reimbursement requests we tested, one of them contained an error whereby the reimbursement requested exceeded the actual expenses incurred. The subrecipient has acknowledged the error and will deduct this overcharge from its next reimbursement request in 2025. Questioned Costs: Known questioned costs associated with this error are $6,590. If this error is extrapolated over the entire population of 2024 subrecipient reimbursements, this results in projected likely questioned costs of $31,790. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review all documents used to track subrecipient expense to ensure they are accurate and free of error, and have undergoine with proper review and approval prior to submission. Views Of Responsible Officials: In 2025, BioSTL Grant Management and Finance leadership implemented a comprehensive post-award grant process, including extensive policies and procedures for subrecipient management and monitoring. Additionally, early in 2025, internal policies concerning subrecipient invoicing procedures were enhanced to require additional documentation and review for all subrecipient submissions of grant funds. These improvements have proven effective in identifying and rectifying errors prior to submission. Refer to the accompanying corrective action plan for more detail on the processes implemented.
The audit identified that a subrecipient submitted an expense reimbursement request exceeding the incurred grant expenses through the submission date. This issue resulted from a misinterpretation by the subrecipient team regarding the correct procedures for completing the expense recording worksheet. Priorto FY 2025, existing controls over subrecipient monitoring were not effectively designed to detect this error. In 2025, BioSTL Grant Management and Finance leadership implemented a comprehensive post-award grant process, including extensive policies and procedures for subrecipient management and monitoring. Additionally, early in 2025, internal policies concerning subrecipient invoicing procedures were enhanced to require additional documentation and review for all subrecipient submissions of grant funds. These improvements have proven effective in identifying and rectifying errors prior to submission. To support these initiatives, BioSTL has conducted training sessions, reviewed implementation procedures, and held regular meetings to ensure that all BioSTL personnel and subrecipient staff fully understand the requirements and have ample opportunities for communication regarding grant draws. Furthermore, to align BioSTL Policies and Procedures, a comprehensive handbook has been developed for all virtual and on-site monitoring activities. These revised procedures mandate at least one virtual monitoring session every six months and at least one on-site monitoring session per participant throughout the grant period, with additional monitoring based on risk assessment outcomes. This schedule more closely aligns with CFR requirements and ensures oversight activities are conducted thoroughly and without lapses. On-site monitoring will be completed for all subrecipients before the end of the fiscal year, which closes on December 31, 2025.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 18, 2024. 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 18, 2025, which was (428 days ago).
What is a management decision? →Finding 2023-001 Significant Deficiency: Reporting - Compliance and Control Finding ALN 11.307 – Economic Development Cluster Federal Agency: U.S. Department of Commerce Pass-Through Entity: N/A Criteria Or Specific Requirement: 2 CFR Part 170 requires direct recipients of grants to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the agreement was made. Additionally, proper controls must be in place surrounding review and approval of the report prior to submission to FSRS. Condition: Audit procedures revealed that the FFATA reports were not properly or timely submitted. Cause: Management was not aware FFATA reports were an applicable requirement of the federal program. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Context: Reports for subrecipients who were awarded over $30,000 in federal funding were not compiled, reviewed or submitted by last day of the month following the month in which the agreement was made. Questioned Costs: None. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management compile and submit FFATA report timely for all subrecipient agreements for greater than $30,000 in federal funding with proper review and approval prior to submission. Views Of Responsible Officials: BioSTL has implemented an Airtable-based compliance reminder system to automate notifications related to FFATA form submissions. Automated reminders will be sent to both pass-through partners and relevant program staff, reminding them to complete the annual FFATA form submission. Notifications will be issued on September 1st as a 30-day advance notice and again on September 15th, with a final submission deadline to BioSTL set for September 30th of each year. These reminders ensure proactive follow-up and help maintain annual compliance.
Personnel Responsible For Corrective Action: Mike Higgins, Vice President of Development, Taylor McCabe, Director of Grants Management, and Finance Lead, Tia Newcom Anticipated Completion Date: Expected completion by December 31, 2024Corrective Action Plan: The audit identified that FFATA (Federal Funding Accountability and Transparency Act) subaward reports were not submitted properly or on time for first-tier subawards of $30,000 or more. The deficiency was attributed to a lack of awareness of this requirement and the absence of specific internal controls to ensure timely reporting to the Federal Subaward Reporting System (FSRS). To address this finding and establish compliance with 2 CFR Part 170, BioSTL has implemented additional measures and expanded policies and procedures to ensure timely reporting to the FSRS. To ensure the highest compliance, BioSTL has incorporated the standard federal FFATA form as an exhibit within the subawardee contracts, ensuring timely collection of necessary data. This incorporation not only enables the direct gathering of general information within the contract but also includes the requirement for subawardees to complete and sign the standard FFATA form. This approach is paired with additional training and education for both BioSTL’s Grant Management personnel, Program Directors, and the leadership team within subawardee organizations, ensuring that all parties are fully aware of the initial and any ongoing reporting requirements. Through the formalized contractual process, BioSTL has implemented enhanced internal controls by requiring supervisory review and approval at multiple levels. Submitted FFATA documentation will undergo review by the Program Director managing the grant, the Director of Grants Management, and the Vice President of Development, ensuring thorough oversight and compliance at each step. To support this process, BioSTL has implemented an Airtable-based compliance reminder system to automate notifications related to FFATA form submissions. Automated reminders will be sent to both pass-through partners and relevant program staff, reminding them to complete the annual FFATA form submission. Notifications will be issued on September 1st as a 30-day advance notice and again on September 15th, with a final submission deadline to BioSTL set for September 30th of each year. These reminders ensure proactive follow-up and help maintain annual compliance. BioSTL will also ensure that both Program Directors and the Grants Department thoroughly review all submitted FFATA documents, reinforcing accuracy and adherence to reporting timelines.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 20, 2023. 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 May 20, 2024, which was (822 days ago).
What is a management decision? →Finding 2022-001 Significant Deficiency: Reporting - Compliance and Control Finding ALN 11.307 – Economic Development Cluster Federal Agency: U.S. Department of Commerce Pass-Through Entity: N/A - Direct Award Criteria Or Specific Requirement: The agreement for the federal award requiresseveral reports be submitted, including a Progress Report that is due within 30 days of the report period end. Condition: The Organization did not submit the required Progress Report by the required due date. Cause: The Organization’s internal control in place (review of reports by a supervisory employee) failed to ensure that the Progress Report was submitted by the applicable deadline. Effect: The Progress Report was not submitted by the applicable deadline. Context: Of the six reports selected for testing, one report was not submitted by the applicable deadline. The report was submitted 7 days after the deadline. Questioned Costs: None. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management evaluate their existing internal control for the review of reports, and consider enhancing it to ensure that all reports are submitted by applicable deadlines. Views Of Responsible Officials: With the subsequent establishment of the dedicated Grants Coordinator position, improved controls came into place: 1) dual supervisory review of reports between the direct supervisor of the Grants Coordinator position and the legacy supervisory role of the Senior Vice President Programs; 2) a clearer timeline of reporting was established with project management systems and document repositories with additional reminders in place to ensure adequate notice is provided to individuals responsible for providing information; and 3) there is a structured follow-up process, at periodic intervals, for report review to ensure deadlines are met.
Finding No. 2022-001 Significant Deficiency Personnel Responsible For Corrective Action: Mike Higgins, VP of Development; Ben Johnson, SVP of Programs; and Grant Manager, to be hired Anticipated Completion Date: Completed Corrective Action Plan: Of the six reports selected for testing, the specific grant report found to be 7 days after the deadline fell at a time of employee transition – when a prior employee with responsibility for report filing moved on to another role at another company and a newly created Grants Coordinator position was filled to take over responsibility. Given the timing of the on-boarding process and education around EDA processing, the report was submitted 7 days late. It should be noted that all subsequent reports were submitted timely. With the establishment of the dedicated Grants Coordinator position (the timing of which coincided with the timing of the cited report), improved controls came into place – namely: 1) dual supervisory review of reports between the direct supervisor of theGrants Coordinator position and the legacy supervisory role of the Senior Vice President Programs; 2) a clearer timeline of reporting was established with project management systems and document repositories (e.g., Salesforce, Asana, and Box) with additional reminders in place to ensure adequate notice is provided to individuals responsible for providing information; and 3) there is a structured follow-up process, at periodic intervals, for report review to ensure deadlines are met. Additionally, in 2023, BioSTL created another new position to ensure internal programmatic and financial control for grants – initiating the hiring of a new Grants Manager role that has already been posted to our website and recruiting has begun. This role will have more dedicated time and responsibility for internal controls and be responsible for timeliness on all reporting and to monitor against all compliance requirements – above and beyond existing and previous supervisory review from the VP, Development and SVP, Programs.
Finding 2022-002 Significant Deficiency: Procurement and Suspension and Debarment – Compliance and Control Finding ALN 11.020 – Economic Development Administration Federal Agency: U.S. Department of Commerce Pass-Through Entity: N/A - Direct Award Criteria Or Specific Requirement: The Uniform Guidance requires the Organization to adhere to federal procurement requirements when expending federal funds under the project. The Organization also must adhere to federal requirements to ensure that its contractors have not been suspended or debarred from receiving federal funds. Condition: The Organization procured services with one vendor in an amount in excess of the $10,000 micropurchase threshold where the procurement process was not followed. Additionally, the Organization did not ensure that its contractors have not been suspended or debarred from receiving federal funds by either including appropriate language to this effect within the contract or determining that the contractors were not included within the suspension and debarment listing within the EPLS database. Cause: The Organization’s internal control in place (review of reports by a supervisory employee) failed to ensure that procurement and suspension and debarment procedures were followed. Effect: The Organization could contract with a contractor who is either not the most qualified and/or lowest cost provider, or who is suspended or debarred. Context: Of three contracts selected for procurement testing, one contract had not gone through the procurement process. Additionally, none of the three contracts had been subjected to procedures to ensure the contractor was not suspended or debarred. Questioned Costs: None. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management evaluate their existing internal control for the review of reports, and consider enhancing it to ensure that all reports are submitted by applicable deadlines. Views Of Responsible Officials: Along with strengthening of reporting, the hiring of the dedicated Grants Coordinator position additionally improved controls related to procurement. Updated internal forms to document purchasing and classify procurement requirements were established and integrated with project management tools; new procurement templates were established; and improved repositories for cataloguing procurement materials and invoices were established. Additionally, moving forward, the suspension and disbarment language will now be included specifically in all contracts and has been added into the contract template.
Finding No. 2022-002 Significant Deficiency Personnel Responsible For Corrective Action: Mike Higgins, Vice President of Development, Christina Green, Vice President of Finance and Human Resources, Procurement and Compliance Officer, to be hired, Grant Manager, to be hired Anticipated Completion Date: Completed Corrective Action Plan: Along with strengthening of reporting, the hiring of the dedicated Grants Coordinator position additionally improved controls related to procurement. Updated internal forms to document purchasing and classify procurement requirements were established and integrated with project management tools; new procurement templates were established; and improved repositories for cataloguing procurement materials and invoices were established. Additionally, in 2023, as noted above, BioSTL created a new position to ensure internal programmatic and financial control for grants – initiating the hiring of a new Grants Manager role that has already been posted to our website and recruiting has begun. This role will have more dedicated time and responsibility for internal controls and be responsible for oversight and effectiveness of all internal controls – above and beyond existing and previous supervisory review from the VP, Development and SVP, Programs. In 2024, a Procurement and Compliance Officer role is being added to further ensure internal controls for all contracts are adhered to and to provide further structure around the processes. The required language provided by the EDA is included in all BioSTL contracts as specifically noted by the EDA. There is not a call out specifically to suspension and disbarment, however, the language provided by the EDA entails these aspects. Moving forward, the suspension and disbarment language will now be included specifically in all contracts and has been added into the contract template.
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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