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ACCOUNTABILITY LAB, INC.Non-Profit

EIN: 454613016

UEI: GFCELH8JBJF7

Audited by: Han Group LLC

Oversight agency: 19 [Department of State]

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Data as of September 2, 2026

ACCOUNTABILITY LAB, INC.5 audit years6 findings1 repeat
5
Audit Years
6
Total Findings
1
Repeat Findings
$4.8M
Federal Awards Expended (FY 2024)

FY 2024-12-31

LOW-RISK AUDITEE$4,838,371 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on September 26, 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 March 26, 2026 (161 days ago).

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2024-003
Reporting
SIGNIFICANT DEFICIENCY

During the review of reporting compliance for the major programs, it was determined that the Organization did not file the FFATA reports for program 98.001 within the required timeframe. Specifically, there were two modifications during the year under audit that increased the Federal funding obligation of the subaward by $30,000 or more, and both reports were filed after the month following the month in which the modifications were made, contrary to FFATA requirements. We examined two of the four required federal financial reports and all required FFATA filings, and the only exceptions identified were in the FFATA filings. Cause: Internal controls over financial reporting were not operating effectively to ensure FFATA reports were filed in a timely manner. In addition, management was not fully aware of the specific FFATA reporting requirements applicable to prime awardees. Effect: Failure to submit the FFATA report by the end of the month following the obligation of a subaward of $30,000 or more results in noncompliance with 2 CFR §170. Perspective Information: None. Questioned Costs: None. Repeat Finding: None. Recommendations: We recommend that management and relevant staff participate in training specifically on FFATA reporting requirements to ensure a clear understanding of obligations and deadlines. In addition, management should formalize and document procedures for FFATA reporting, such as maintaining a calendar of due dates, assigning responsibility for preparation and review, and implementing a sign-off process to confirm timely submission. The previous audit firm did not find this to be an issue, and we were told that reporting to FFATA was needed once a year for the previous year’s disbursements and that is what we have done. Now we will report every time we pass the $30,000 disbursement to a subrecipient.

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Full finding narrative

Criteria or Specific Requirements: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) subaward report by the end of the month following the month in which the prime awardee obligates any subaward equal to or greater than $30,000. This requirement also applies when a modification increases the Federal funding obligation of a subaward to an amount that equals or exceeds $30,000. Further, the Organization is subject to financial reporting requirements. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) must be submitted at the frequency required by the terms and conditions of the award. Condition: During the review of reporting compliance for the major programs, it was determined that the Organization did not file the FFATA reports for program 98.001 within the required timeframe. Specifically, there were two modifications during the year under audit that increased the Federal funding obligation of the subaward by $30,000 or more, and both reports were filed after the month following the month in which the modifications were made, contrary to FFATA requirements. We examined two of the four required federal financial reports and all required FFATA filings, and the only exceptions identified were in the FFATA filings. Cause: Internal controls over financial reporting were not operating effectively to ensure FFATA reports were filed in a timely manner. In addition, management was not fully aware of the specific FFATA reporting requirements applicable to prime awardees. Effect: Failure to submit the FFATA report by the end of the month following the obligation of a subaward of $30,000 or more results in noncompliance with 2 CFR §170. Perspective Information: None. Questioned Costs: None. Repeat Finding: None. Recommendations: We recommend that management and relevant staff participate in training specifically on FFATA reporting requirements to ensure a clear understanding of obligations and deadlines. In addition, management should formalize and document procedures for FFATA reporting, such as maintaining a calendar of due dates, assigning responsibility for preparation and review, and implementing a sign-off process to confirm timely submission. The previous audit firm did not find this to be an issue, and we were told that reporting to FFATA was needed once a year for the previous year’s disbursements and that is what we have done. Now we will report every time we pass the $30,000 disbursement to a subrecipient.

Corrective Action Plan

The previous audit firm did not find this to be an issue, we were told that reporting to FFATA was needed once a year for the previous year’s disbursements and that is what we have done. Now we will report every time we pass the $30,000 disbursement to a subrecipient.

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FY 2023-12-31

$4,378,795 federal awards expended

FAC accepted this audit on July 29, 2024 — management decision was due January 29, 2025.

2023-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.

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Full finding narrative

Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements, which must include the total Federal awards expended. Additionally, in accordance with CFR 200.303, the non- Federal entity 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: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions: In 2024 during the SEFA analysis and in discussion with auditors it was determined that a USG-funded contract, attached to a grant, was incorrectly left off the SEFA. This was amended as soon as the mistake was noted. AL is required to submit financial statements to a non-US Government donor by June of each calendar year. To comply with this grant stipulation AL starts pre-audit document checks in early January and full fieldwork in mid-February following our financial year close on December 31. While the majority of our annual financial statement is complete by mid-January we have one outstanding USG grant which only reports at the end of February for an end-of-January quarter close. As a result, we are only able to provide a preliminary SEFA when the auditors request the first document checks in January. For FY 2025 we will request that the auditors start with a basic audit of Financial Statements and then submit the SEFA once all the quarterly reports have been submitted to USG. Anticipated Completion Date: Already decided for FY 2024 audit. Responsible Officials: Chief Innovation and Operations Officer and Finance Manager.

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2023-002
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

We were unable to determine whether Accountability Lab performed procedures to verify whether or not its subrecipients were subject to a compliance audit in accordance with 2 CFR 200 Subpart F. Cause: Accountability Lab does not have a formal/regularized process in place to monitor subrecipient audit requirements. Effect: Accountability Lab's current practices do not provide sufficient documentation to demonstrate its compliance with the requirements to obtain and review subrecipient audit reports. Questioned Costs: None noted. Context: Our audit work included three subrecipients across two major programs. For two out of the three subrecipients tested, we were not able to verify whether or not Accountability Lab obtained and reviewed the subrecipient audit reports. Identification as a Repeat Finding: Not applicable. Recommendation: Accountability Lab should implement a "Review of Subrecipient Audit" form, to be completed annually for each subrecipient that receives U.S. Government funding. The form should document a) the subrecipient's name; b) the annual amount of U.S. Government funds expended by the subrecipient; c) whether the subrecipient was subject to a U.S. Government compliance audit under 2 CFR 200 Subpart F; and d) Accountability Lab's formal review of the audit report as well as its conclusions and follow up on any reported findings, if applicable.

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Full finding narrative

Finding 2023-002: Subrecipient Monitoring - Review of Audit Reports Information on the Federal Program: Assistance Listing Numbers 19.705 and 19.345 Criteria: As stated in 2 CFR 200.332(f), all pass-through entities must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold for triggering such an audit. Condition: We were unable to determine whether Accountability Lab performed procedures to verify whether or not its subrecipients were subject to a compliance audit in accordance with 2 CFR 200 Subpart F. Cause: Accountability Lab does not have a formal/regularized process in place to monitor subrecipient audit requirements. Effect: Accountability Lab's current practices do not provide sufficient documentation to demonstrate its compliance with the requirements to obtain and review subrecipient audit reports. Questioned Costs: None noted. Context: Our audit work included three subrecipients across two major programs. For two out of the three subrecipients tested, we were not able to verify whether or not Accountability Lab obtained and reviewed the subrecipient audit reports. Identification as a Repeat Finding: Not applicable. Recommendation: Accountability Lab should implement a "Review of Subrecipient Audit" form, to be completed annually for each subrecipient that receives U.S. Government funding. The form should document a) the subrecipient's name; b) the annual amount of U.S. Government funds expended by the subrecipient; c) whether the subrecipient was subject to a U.S. Government compliance audit under 2 CFR 200 Subpart F; and d) Accountability Lab's formal review of the audit report as well as its conclusions and follow up on any reported findings, if applicable.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions: AL has a long-standing preassessment Questionnaire (sample attached) that we require each potential subgrantee to complete before they can receive any financial remuneration from us. In response to this finding, we will require all subgrantees to complete this questionnaire on an annual basis. In addition we have included the following questions to the questionnaire:  Does the organization perform an annual audit of financial statements?  Annual amount of US Government Funds received?  Is the organization subject to a US compliance audit under 2 CFR 200 Subpart F?  If the organization is subject to a compliance audit under 2 CFR 200 Subpart F, please provide a copy of your most recent 2 CFR 200 Subpart F audit report. Anticipated Completion Date: We will submit the questionnaire to all subgrantees during the month of June 2024 and then perform it annually. Responsible Officials: Chief Innovation and Operations Officer and Finance Manager.

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FY 2022-12-31

$2,493,386 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 6, 2023 — management decision was due December 6, 2023.

FY 2021-12-31

NON-GAAP BASIS$1,700,877 federal awards expended

FAC accepted this audit on September 27, 2022 — management decision was due March 27, 2023.

2021-001
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2020-001OTHER MATTERS

During our audit, we performed a review of Accountability Lab?s payroll processes and the related documentation and noted areas which we believe should be improved in order to ensure that payroll charges to donor projects are sufficiently supported. These areas included absent documentation of review and approval of the payroll registers, timesheets which were not submitted timely and lacked review and approval signatures, occasional inconsistencies between the allocations of employee time as per the timesheets and the resulting allocation of costs within the accounting system, and certain personnel file documentation not available for our review during the audit. Cause: Accountability Lab is relatively small organization and new to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Accordingly, during 2021, they had not yet fully implemented internal control processes consistent with those requirements. Effect or Potential Effect: Inadequate controls over payroll expenditures and allocations may result in inaccurate financial reporting and the disallowance of costs. Questioned Costs: Undetermined. Context: Based on our audit testwork, the issues noted appear to be pervasive. Identification as a Repeat Finding, if Applicable: Repeat of Finding 2020-001. Recommendation: In view of the significance of payroll related expenditures in administering programs, as well as strict donor rules and expectations concerning the allocations of payroll costs to projects, we suggest that management of Accountability Lab work to enhance its internal controls over payroll by implementing a means to document review of the post-run payroll registers, enforcing deadlines for submission of timesheets, ensuring that all timesheets are reviewed and approved by an appropriate supervisor (and that this review is documented), and that payroll allocation calculations be carefully checked to ensure that all allocations of payroll expense accurately reflect the allocation of time documented in the timesheets.

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Finding 2021-001: Payroll Documentation Information on the Federal Programs: Cooperative Agreement 72061320CA00002 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Title 2 CFR 200 Section 200.303 ?Internal Controls? requires recipients of federal funds to establish internal controls that should be in compliance with guidance in the ?Integrated Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our audit, we performed a review of Accountability Lab?s payroll processes and the related documentation and noted areas which we believe should be improved in order to ensure that payroll charges to donor projects are sufficiently supported. These areas included absent documentation of review and approval of the payroll registers, timesheets which were not submitted timely and lacked review and approval signatures, occasional inconsistencies between the allocations of employee time as per the timesheets and the resulting allocation of costs within the accounting system, and certain personnel file documentation not available for our review during the audit. Cause: Accountability Lab is relatively small organization and new to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Accordingly, during 2021, they had not yet fully implemented internal control processes consistent with those requirements. Effect or Potential Effect: Inadequate controls over payroll expenditures and allocations may result in inaccurate financial reporting and the disallowance of costs. Questioned Costs: Undetermined. Context: Based on our audit testwork, the issues noted appear to be pervasive. Identification as a Repeat Finding, if Applicable: Repeat of Finding 2020-001. Recommendation: In view of the significance of payroll related expenditures in administering programs, as well as strict donor rules and expectations concerning the allocations of payroll costs to projects, we suggest that management of Accountability Lab work to enhance its internal controls over payroll by implementing a means to document review of the post-run payroll registers, enforcing deadlines for submission of timesheets, ensuring that all timesheets are reviewed and approved by an appropriate supervisor (and that this review is documented), and that payroll allocation calculations be carefully checked to ensure that all allocations of payroll expense accurately reflect the allocation of time documented in the timesheets.

Corrective Action Plan

Views of Responsible Officials: All personnel folders are kept in electronic format and they contain W4, state forms and I9. As of 2022 we started using an electronic system for timesheets (Clockify), we have set up supervisors as approvers. Each employee has until the end of the week following the end of each month to finalize and submit their timesheets. Reports are generated and sent to the accountant for allocation of payroll.

Prior Finding References

2020-001

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FY 2020-12-31

NON-GAAP BASIS$903,283 federal awards expended

FAC accepted this audit on September 15, 2022 — management decision was due March 15, 2023.

2020-001
Other
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our audit, we performed a review of Accountability Lab?s payroll processes and the related documentation and noted areas which we believe should be improved in order to ensure that payroll charges to donor projects are sufficiently supported. These areas included absent documentation of review and approval of the payroll registers, timesheets which were not submitted timely and lacked review and approval signatures, occasional inconsistencies between the allocations of employee time as per the timesheets and the resulting allocation of costs within the accounting system, and certain personnel file documentation not available for our review during the audit. Cause: Accountability Lab is relatively small organization and new to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Accordingly, during 2020 they had not yet fully implemented internal control processes consistent with those requirements. Effect or Potential Effect: Inadequate controls over payroll expenditures and allocations may result in inaccurate financial reporting and the disallowance of costs. Questioned Costs: Undetermined Context: Based on our audit testwork, the issues noted appear to be pervasive. Identification as a Repeat Finding, if Applicable: N/A Recommendation: In view of the significance of payroll related expenditures in administering programs, as well as strict donor rules and expectations concerning the allocations of payroll costs to projects, we suggest that management of Accountability Lab work to enhance its internal controls over payroll by implementing a means to document review of the post-run payroll registers, enforcing deadlines for submission of timesheets, ensuring that all timesheets are reviewed and approved by an appropriate supervisor (and that this review is documented), and that payroll allocation calculations be carefully checked to ensure that all allocations of payroll expense accurately reflect the allocation of time documented in the timesheets.

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Full finding narrative

Information on the Federal Programs: Cooperative Agreement 72061320CA00002 Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Title 2 CFR 200 Section 200.303 ?Internal Controls? requires recipients of Federal funds to establish internal controls that should be in compliance with guidance in the ?Integrated Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our audit, we performed a review of Accountability Lab?s payroll processes and the related documentation and noted areas which we believe should be improved in order to ensure that payroll charges to donor projects are sufficiently supported. These areas included absent documentation of review and approval of the payroll registers, timesheets which were not submitted timely and lacked review and approval signatures, occasional inconsistencies between the allocations of employee time as per the timesheets and the resulting allocation of costs within the accounting system, and certain personnel file documentation not available for our review during the audit. Cause: Accountability Lab is relatively small organization and new to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Accordingly, during 2020 they had not yet fully implemented internal control processes consistent with those requirements. Effect or Potential Effect: Inadequate controls over payroll expenditures and allocations may result in inaccurate financial reporting and the disallowance of costs. Questioned Costs: Undetermined Context: Based on our audit testwork, the issues noted appear to be pervasive. Identification as a Repeat Finding, if Applicable: N/A Recommendation: In view of the significance of payroll related expenditures in administering programs, as well as strict donor rules and expectations concerning the allocations of payroll costs to projects, we suggest that management of Accountability Lab work to enhance its internal controls over payroll by implementing a means to document review of the post-run payroll registers, enforcing deadlines for submission of timesheets, ensuring that all timesheets are reviewed and approved by an appropriate supervisor (and that this review is documented), and that payroll allocation calculations be carefully checked to ensure that all allocations of payroll expense accurately reflect the allocation of time documented in the timesheets.

Corrective Action Plan

Views of Responsible Officials: We have improved for 2021, by enforcing the timesheet submission, revision and approval. For 2022 we will use a web-based product. We have reviewed and every employee file has all the forms for withholding, I9 and conflict of interest signed.

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2020-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

During the course of our audit, we inquired with management of Accountability Lab as to whether they had completed the subaward reporting for 2 awards made to subrecipient organizations in Zimbabwe, and were informed that the reporting had not been completed. Cause: Accountability Lab was not aware of the requirements of FFATA. Effect or Potential Effect: Failure to report subawards as required may result in administrative delays and penalties including suspension or discontinuance of federal award funding. Questioned Costs: None Context: Accountability Lab issued two subawards under the major program during 2020, neither of which was reported in the Federal Subaward Reporting System. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the subaward reporting be completed as required, and that management remain cognizant of the subaward reporting requirements for any future subawards under U.S. Federal grants

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Full finding narrative

Information on the Federal Programs: Cooperative Agreement 72061320CA00002 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): The Federal Funding Accountability and Transparency Act (FFATA) requires certain information about Federal award spending to be made publicly available. Beginning in October of 2010, prime grant recipients awarded a new Federal grant are required to submit data regarding first-tier subawards for any subaward valued at greater than or equal to $30,000 to the FFATA Subaward Reporting System (FSRS) by the end of the month following the month in which the subaward is made. Condition: During the course of our audit, we inquired with management of Accountability Lab as to whether they had completed the subaward reporting for 2 awards made to subrecipient organizations in Zimbabwe, and were informed that the reporting had not been completed. Cause: Accountability Lab was not aware of the requirements of FFATA. Effect or Potential Effect: Failure to report subawards as required may result in administrative delays and penalties including suspension or discontinuance of federal award funding. Questioned Costs: None Context: Accountability Lab issued two subawards under the major program during 2020, neither of which was reported in the Federal Subaward Reporting System. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the subaward reporting be completed as required, and that management remain cognizant of the subaward reporting requirements for any future subawards under U.S. Federal grants

Corrective Action Plan

Views of Responsible Officials: We have subsequently updated the FFATA with subaward amounts and will continue to do so going forward.

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