EIN: 510151095
UEI: JRMJJVYLTPM4
Audited by: KKDLY LLC
Oversight agency: 17 [Department of Labor]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 28, 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 April 28, 2026 (128 days ago).
What is a management decision? →FAC accepted this audit on November 25, 2024 — management decision was due May 25, 2025.
FAC accepted this audit on January 12, 2024 — management decision was due July 12, 2024.
FAC accepted this audit on November 20, 2022 — management decision was due May 20, 2023.
FAC accepted this audit on February 8, 2022 — management decision was due August 8, 2022.
Significant Deficiency Finding 2021-002 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Labor Native American Employment and Training AB-33758-19-60-A-15 / AB-34934-20-60-A-15 CFDA No. 17.265 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.430), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provide reasonable assurance that charges are accurate and allowable, and be incorporated into the official records of the non-federal entity. Condition We selected 40 payroll transactions for testing and noted 20 instances involving 6 employees where employees were not paid at their authorized pay rates for the pay period tested due to the exclusion of approved retroactive payroll adjustments. For these 20 instances, the difference between the amount that should have been paid using the authorized pay rates and the actual amount paid to the employees aggregated to $11,863. We noted that for all 20 instances involving all 6 employees, the retroactive adjustments were made during the fiscal year ended June 30, 2021; however, for 12 instances involving 3 employees, the retroactive adjustments paid to the employees were incorrectly calculated. Management has determined that the difference between the correct amount of retroactive pay and the actual amount paid to the 3 employees aggregated to an underpayment of $2,465. Cause There were numerous pay rate changes not processed in a timely manner. For example, a pay rate change effective August 21, 2019 was not processed until May 2021. Further, there was no process to review the retroactive pay calculations prior to these amounts being entered into the payroll system. Effect For the pay periods tested, employees were underpaid by $11,863. In addition, the incorrectly calculated retroactive adjustments made subsequent to the pay periods tested aggregated to an underpayment of $2,465. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit reported as Finding 2020-003. Recommendation We recommend that the Organization correct all outstanding errors identified in our testing and review all retroactive payment calculations not identified in our testing for any errors. We recommend that the Organization process pay changes in a timely manner. Additionally, we recommend the Organization establish policies and procedures requiring the review of retroactive payment calculations by an individual other than the preparer prior to these amounts being entered into the payroll system.
Show full finding ▾Hide full finding ▴Significant Deficiency Finding 2021-002 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Labor Native American Employment and Training AB-33758-19-60-A-15 / AB-34934-20-60-A-15 CFDA No. 17.265 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.430), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provide reasonable assurance that charges are accurate and allowable, and be incorporated into the official records of the non-federal entity. Condition We selected 40 payroll transactions for testing and noted 20 instances involving 6 employees where employees were not paid at their authorized pay rates for the pay period tested due to the exclusion of approved retroactive payroll adjustments. For these 20 instances, the difference between the amount that should have been paid using the authorized pay rates and the actual amount paid to the employees aggregated to $11,863. We noted that for all 20 instances involving all 6 employees, the retroactive adjustments were made during the fiscal year ended June 30, 2021; however, for 12 instances involving 3 employees, the retroactive adjustments paid to the employees were incorrectly calculated. Management has determined that the difference between the correct amount of retroactive pay and the actual amount paid to the 3 employees aggregated to an underpayment of $2,465. Cause There were numerous pay rate changes not processed in a timely manner. For example, a pay rate change effective August 21, 2019 was not processed until May 2021. Further, there was no process to review the retroactive pay calculations prior to these amounts being entered into the payroll system. Effect For the pay periods tested, employees were underpaid by $11,863. In addition, the incorrectly calculated retroactive adjustments made subsequent to the pay periods tested aggregated to an underpayment of $2,465. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit reported as Finding 2020-003. Recommendation We recommend that the Organization correct all outstanding errors identified in our testing and review all retroactive payment calculations not identified in our testing for any errors. We recommend that the Organization process pay changes in a timely manner. Additionally, we recommend the Organization establish policies and procedures requiring the review of retroactive payment calculations by an individual other than the preparer prior to these amounts being entered into the payroll system.
Finding 2021-002 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Labor Native American Employment and Training AB-33758-19-60-A-15 / AB-34934-20-60-A-15 CFDA No. 17.265 Condition The auditors selected 40 payroll transactions for testing and noted 20 instances involving 6 employees where employees were not paid at their authorized pay rates for the pay period tested due to the exclusion of approved retroactive payroll adjustments. For these 20 instances, the difference between the amount that should have been paid using the authorized pay rates and the actual amount paid to the employees aggregated to $11,863. The auditors noted that for all 20 instances involving all 6 employees, the retroactive adjustments were made during the fiscal year ended June 30, 2021; however, for 12 instances involving 3 employees, the retroactive adjustments paid to the employees were incorrectly calculated. Management has determined that the difference between the correct amount of retroactive pay and the actual amount paid to the 3 employees aggregated to an underpayment of $2,465. Recommendation The auditors recommend that the Organization correct all outstanding errors identified in their testing and review all retroactive payment calculations not identified in their testing for any errors. The auditors again recommend that the Organization process pay changes in a timely manner. Additionally, the auditors again recommend the Organization establish policies and procedures requiring the review of retroactive payment calculations by an individual other than the preparer prior to these amounts being entered into the payroll system. Action Taken Our change in the staff evaluation and merit procedures will minimize the need to do retroactive pay calculations. The Controller review of retroactive pay calculations should eliminate errors in calculations.
2020-003
FAC accepted this audit on March 30, 2021 — management decision was due September 30, 2021.
Significant Deficiency Finding 2020-003 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Labor 477 Cluster Native American Employment and Training AB-32277-18-60-A-15 / AB-33758-19-60-A-15 CFDA No. 17.265 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.430), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provide reasonable assurance that charges are accurate and allowable, and be incorporated into the official records of the non-federal entity. Condition We selected 40 payroll transactions for testing and noted 12 instances involving 4 employees where employees were not paid at their authorized pay rates for the pay period tested due to the exclusion of approved retroactive payroll adjustments. For these 12 instances, the difference between the amount that should have been paid using the authorized pay rates and the actual amount paid to the employees aggregated to $575. We noted that for 4 instances involving 4 employees, the retroactive adjustments were subsequently made during the fiscal year ended June 30, 2020 after the pay period we tested; however, for 3 instances involving 3 employees, the retroactive adjustments paid to the employees were incorrectly calculated. Management has determined that the difference between the correct amount of retroactive pay and the actual amount paid to the 3 employees aggregated to an underpayment of $1,226. We also noted that for 8 instances involving 2 of the employees discussed in the previous paragraph, an additional retroactive adjustment was paid to each employee subsequent to June 30, 2020. However, the retroactive adjustments paid to the employees were incorrectly calculated. Management is currently working to correct these errors. Cause There were numerous pay rate changes not processed in a timely manner. For example, a pay rate change effective October 1, 2019 was not processed until January 2021. Further, there was no process to review the retroactive pay calculations prior to these amounts being entered into the payroll system. Effect The affected employees were underpaid and therefore federal reimbursements for program expenditures were understated. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization process pay changes in a timely manner and review all retroactive payment calculations not identified in our testing for errors. Additionally, we recommend the Organization establish policies and procedures requiring the review of retroactive payment calculations by an individual other than the preparer prior to these amounts being entered into the payroll system. Views of Responsible Officials and Planned Corrective Action
Show full finding ▾Hide full finding ▴Significant Deficiency Finding 2020-003 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Labor 477 Cluster Native American Employment and Training AB-32277-18-60-A-15 / AB-33758-19-60-A-15 CFDA No. 17.265 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.430), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provide reasonable assurance that charges are accurate and allowable, and be incorporated into the official records of the non-federal entity. Condition We selected 40 payroll transactions for testing and noted 12 instances involving 4 employees where employees were not paid at their authorized pay rates for the pay period tested due to the exclusion of approved retroactive payroll adjustments. For these 12 instances, the difference between the amount that should have been paid using the authorized pay rates and the actual amount paid to the employees aggregated to $575. We noted that for 4 instances involving 4 employees, the retroactive adjustments were subsequently made during the fiscal year ended June 30, 2020 after the pay period we tested; however, for 3 instances involving 3 employees, the retroactive adjustments paid to the employees were incorrectly calculated. Management has determined that the difference between the correct amount of retroactive pay and the actual amount paid to the 3 employees aggregated to an underpayment of $1,226. We also noted that for 8 instances involving 2 of the employees discussed in the previous paragraph, an additional retroactive adjustment was paid to each employee subsequent to June 30, 2020. However, the retroactive adjustments paid to the employees were incorrectly calculated. Management is currently working to correct these errors. Cause There were numerous pay rate changes not processed in a timely manner. For example, a pay rate change effective October 1, 2019 was not processed until January 2021. Further, there was no process to review the retroactive pay calculations prior to these amounts being entered into the payroll system. Effect The affected employees were underpaid and therefore federal reimbursements for program expenditures were understated. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization process pay changes in a timely manner and review all retroactive payment calculations not identified in our testing for errors. Additionally, we recommend the Organization establish policies and procedures requiring the review of retroactive payment calculations by an individual other than the preparer prior to these amounts being entered into the payroll system. Views of Responsible Officials and Planned Corrective Action
Finding 2020-003 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Labor 477 Cluster Native American Employment and Training AB-32277-18-60-A-16 / AB-33758-19-60-A-15 CFDA No. 17.265 Condition The auditors selected 40 payroll transactions for testing and noted 12 instances involving 4 employees where employees were not paid at their authorized pay rates for the pay period tested due to the exclusion of approved retroactive payroll adjustments. For these 12 instances, the difference between the amount that should have been paid using the authorized pay rates and the actual amount paid to the employees aggregated to $575. The auditors noted that for 4 instances involving 4 employees, the retroactive adjustments were subsequently made during the fiscal year ended June 30, 2020 after the pay period the auditors tested; however, for 3 instances involving 3 employees, the retroactive adjustments paid to the employees were incorrectly calculated. Management has determined that the difference between the correct amount of retroactive pay and the actual amount paid to the 3 employees aggregated to an underpayment of $1,226. The auditors also noted that for 8 instances involving 2 of the employees discussed in the previous paragraph, an additional retroactive adjustment was paid to each employee subsequent to June 30, 2020. However, the retroactive adjustments paid to the employees were incorrectly calculated. Management is currently working to correct these errors. Recommendation The auditors recommend that the Organization process pay changes in a timely manner and review all retroactive payment calculations not identified in the auditors? testing for errors. Additionally, the auditors recommend the Organization establish policies and procedures requiring the review of retroactive payment calculations by an individual other than the preparer prior to these amounts being entered into the payroll system. Action Taken Authorized pay rates are processed upon the receipt of the staffs? satisfactory performance evaluation. In some instances, the receipt date requires a retroactive pay rate calculations. In the future, the Personnel Specialist will review retroactive pay calculations to insure accuracy before payments are made.
Significant Deficiency Finding 2020-004 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Health and Human Services Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 1701HIT6NS-04 CFDA No. 93.047 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.430), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provide reasonable assurance that charges are accurate and allowable, and be incorporated into the official records of the non-federal entity. Condition We selected 40 payroll transactions for testing and noted 17 instances involving 4 employees where employees were not paid at their authorized pay rates for the pay period tested due to the exclusion of approved retroactive payroll adjustments. For these 17 instances, the difference between the amount that should have been paid using the authorized pay rates and the actual amount paid to the employees aggregated to $753. We noted that for 14 instances involving 3 employees, the retroactive adjustments were subsequently made during the fiscal year ended June 30, 2020 after the pay period we tested; however, for 3 instances involving 1 employee, the retroactive adjustment paid to the employee was incorrectly calculated. Management has determined that the difference between the correct amount of retroactive pay and the actual amount paid to this employee was an underpayment of $18, which will be paid to the employee in March 2021. In addition, we noted 3 instances involving one employee where the employee was not paid the retroactive adjustment as of June 30, 2020. Cause There were numerous pay rate changes not processed in a timely manner. For example, a pay rate change effective January 3, 2019 was not processed until January 2020. Further, there was no process to review the retroactive payment calculations prior to these amounts being entered into the payroll system. Effect The affected employees were underpaid and therefore federal reimbursements for program expenditures were understated. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization process pay changes in a timely manner and review all retroactive payment calculations not identified in our testing for errors. Additionally, we recommend the Organization establish policies and procedures requiring the review of retroactive payment calculations by an individual other than the preparer prior to these amounts being entered into the payroll system. Views of Responsible Officials and Planned Corrective Action
Show full finding ▾Hide full finding ▴Significant Deficiency Finding 2020-004 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Health and Human Services Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 1701HIT6NS-04 CFDA No. 93.047 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.430), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provide reasonable assurance that charges are accurate and allowable, and be incorporated into the official records of the non-federal entity. Condition We selected 40 payroll transactions for testing and noted 17 instances involving 4 employees where employees were not paid at their authorized pay rates for the pay period tested due to the exclusion of approved retroactive payroll adjustments. For these 17 instances, the difference between the amount that should have been paid using the authorized pay rates and the actual amount paid to the employees aggregated to $753. We noted that for 14 instances involving 3 employees, the retroactive adjustments were subsequently made during the fiscal year ended June 30, 2020 after the pay period we tested; however, for 3 instances involving 1 employee, the retroactive adjustment paid to the employee was incorrectly calculated. Management has determined that the difference between the correct amount of retroactive pay and the actual amount paid to this employee was an underpayment of $18, which will be paid to the employee in March 2021. In addition, we noted 3 instances involving one employee where the employee was not paid the retroactive adjustment as of June 30, 2020. Cause There were numerous pay rate changes not processed in a timely manner. For example, a pay rate change effective January 3, 2019 was not processed until January 2020. Further, there was no process to review the retroactive payment calculations prior to these amounts being entered into the payroll system. Effect The affected employees were underpaid and therefore federal reimbursements for program expenditures were understated. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization process pay changes in a timely manner and review all retroactive payment calculations not identified in our testing for errors. Additionally, we recommend the Organization establish policies and procedures requiring the review of retroactive payment calculations by an individual other than the preparer prior to these amounts being entered into the payroll system. Views of Responsible Officials and Planned Corrective Action
Finding 2020-004 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Health and Human Services Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 1701HIT6NS-04 CFDA No. 93.047 Condition The auditors selected 40 payroll transactions for testing and noted 17 instances involving 4 employees where employees were not paid at their authorized pay rates for the pay period tested due to the exclusion of approved retroactive payroll adjustments. For these 17 instances, the difference between the amount that should have been paid using the authorized pay rates and the actual amount paid to the employees aggregated to $753. The auditors noted that for 14 instances involving 3 employees, the retroactive adjustments were subsequently made during the fiscal year ended June 30, 2020 after the pay period the auditors tested; however, for 3 instances involving 1 employee, the retroactive adjustment paid to the employee was incorrectly calculated. Management has determined that the difference between the correct amount of retroactive pay and the actual amount paid to this employee was an underpayment of $18, which will be paid to the employee in March 2021. In addition, the auditors noted 3 instances involving one employee where the employee was not paid the retroactive adjustment as of June 30, 2020. Recommendation The auditors recommend that the Organization process pay changes in a timely manner and review all retroactive payment calculations not identified in the auditors? testing for errors. Additionally, the auditors recommend the Organization establish policies and procedures requiring the review of retroactive payment calculations by an individual other than the preparer prior to these amounts being entered into the payroll system. Action Taken The Personnel Officer and the President/CEO will closely monitor the due dates for staff evaluations to insure staff receive merit increase in a timely manner and to avoid lengthy retroactive calculations. Moving forward the personnel specialist will review retroactive calculations before payments are made.
Significant Deficiency Finding 2020-005 Procurement U.S. Department of Health and Human Services Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 2001HIOATB-00 CFDA No. 93.047 COVID-19 Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 2001HINAC2-00 / 2001HINAC3-00 CFDA No. 93.047 Criteria For purchases of $20,000 or more, the Organization?s procurement policies and procedures dictate that the Director or Designate submits all required procurement documents to the Controller for review and approval. Upon approval, the Controller then submits these documents to the President/CEO for review and approval. The Document Review Form evidences the appropriate review and approval by the Controller and the President/CEO. Condition We noted that for two of five purchases tested, which were in excess of the $20,000 threshold, the Organization was unable to locate the Document Review Form evidencing the reviews and approvals of the Controller and the President/CEO. Cause We were informed that the Organization was in the midst of selecting vendors to contract its meal services when the COVID-19 pandemic occurred. As such, the Organization faced challenges in performing its established procurement procedures, which typically requires hard copies to be forwarded from one individual to another for appropriate review and approval. Effect The Organization did not comply with its established procurement policies and procedures. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization adhere to its established procurement policies and procedures. For purchases of $20,000 or more, the Organization should prepare, execute, and keep on file the required Document Review Form evidencing the review and approval of the procurement action. Views of Responsible Officials and Planned Corrective Action
Show full finding ▾Hide full finding ▴Significant Deficiency Finding 2020-005 Procurement U.S. Department of Health and Human Services Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 2001HIOATB-00 CFDA No. 93.047 COVID-19 Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 2001HINAC2-00 / 2001HINAC3-00 CFDA No. 93.047 Criteria For purchases of $20,000 or more, the Organization?s procurement policies and procedures dictate that the Director or Designate submits all required procurement documents to the Controller for review and approval. Upon approval, the Controller then submits these documents to the President/CEO for review and approval. The Document Review Form evidences the appropriate review and approval by the Controller and the President/CEO. Condition We noted that for two of five purchases tested, which were in excess of the $20,000 threshold, the Organization was unable to locate the Document Review Form evidencing the reviews and approvals of the Controller and the President/CEO. Cause We were informed that the Organization was in the midst of selecting vendors to contract its meal services when the COVID-19 pandemic occurred. As such, the Organization faced challenges in performing its established procurement procedures, which typically requires hard copies to be forwarded from one individual to another for appropriate review and approval. Effect The Organization did not comply with its established procurement policies and procedures. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization adhere to its established procurement policies and procedures. For purchases of $20,000 or more, the Organization should prepare, execute, and keep on file the required Document Review Form evidencing the review and approval of the procurement action. Views of Responsible Officials and Planned Corrective Action
Finding 2020-005 Procurement U.S. Department of Health and Human Services Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 2001HIOATB-00 CFDA No. 93.047 COVID-19 Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 2001HINAC2-00 / 2001HINAC3-00 CFDA No. 93.047 Condition The auditors noted that for two of five purchases tested, which were in excess of the $20,000 threshold, the Organization was unable to locate the Document Review Form evidencing the reviews and approvals of the Controller and the President/CEO. Recommendation The auditors recommend that the Organization adhere to its established procurement policies and procedures. For purchases of $20,000 or more, the Organization should prepare, execute, and keep on file the required Document Review Form evidencing the review and approval of the procurement action. Action Taken ALU LIKE misfiled the document review sheets and will continue to look for them. These purchases were done at a time when staff were rushing to collect files and equipment to work remotely from home due to the government stay at home order which began on March 23, 2020 and ended on April 30, 2020. All fiscal staff will be reminded about the importance of keeping up to date tracking records of their document review forms.
Significant Deficiency Finding 2020-006 Procurement U.S. Department of Health and Human Services Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 2001HIOATB-00 CFDA No. 93.047 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.320(b)), for purchases meeting the small purchases threshold, price or rate quotations must be obtained from an adequate number of qualified sources. For purchases of $4,000 to $19,999, the Organization?s procurement policies and procedures require that three telephone quotations be obtained and documented on the Record of Telephone Quotations form. Condition We noted that no price quotations were obtained for a purchase amounting to $14,237. Cause Due to the COVID-19 pandemic, the program?s contracted vendor reached its capacity and was unable to provide the required meals to the Organization. Therefore, the Organization procured additional vendors to meet the needs of the program participants. Effect The Organization did not comply with its established procurement policy and procedures. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization adhere to its established procurement policies and procedures requiring at least three telephone quotations for procurement actions of $4,000 to $19,999. Views of Responsible Officials and Planned Corrective Action
Show full finding ▾Hide full finding ▴Significant Deficiency Finding 2020-006 Procurement U.S. Department of Health and Human Services Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 2001HIOATB-00 CFDA No. 93.047 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.320(b)), for purchases meeting the small purchases threshold, price or rate quotations must be obtained from an adequate number of qualified sources. For purchases of $4,000 to $19,999, the Organization?s procurement policies and procedures require that three telephone quotations be obtained and documented on the Record of Telephone Quotations form. Condition We noted that no price quotations were obtained for a purchase amounting to $14,237. Cause Due to the COVID-19 pandemic, the program?s contracted vendor reached its capacity and was unable to provide the required meals to the Organization. Therefore, the Organization procured additional vendors to meet the needs of the program participants. Effect The Organization did not comply with its established procurement policy and procedures. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization adhere to its established procurement policies and procedures requiring at least three telephone quotations for procurement actions of $4,000 to $19,999. Views of Responsible Officials and Planned Corrective Action
Finding 2020-006 Procurement U.S. Department of Health and Human Services Special Programs for the Aging ? Title VI, Part A ? Grants to Indian Tribes; Part B ? Grants to Native Hawaiians 2001HIOATB-00 CFDA No. 93.047 Condition The auditors noted that no price quotations were obtained for a purchase amounting to $14,237. Recommendation The auditors recommend that the Organization adhere to its established procurement policies and procedures requiring at least three telephone quotations for procurement actions of $4,000 to $19,999. Action Taken ALU LIKE will amend its fiscal policy to make it clear that a response back from a vendor indicating they cannot provide the product and service has the same status as a no bid. In addition, the sole source policy will be amended to allow for a sole source procurement when we receive only one bid and have exhausted all reasonable efforts to obtain more than one bid. ALU LIKE will also go over the amended procurement policy with Directors and fiscal staff.
FAC accepted this audit on July 22, 2020 — management decision was due January 22, 2021.
Significant Deficiency Finding 2019-003 Procurement U.S. Department of Education Native Hawaiian Career and Technical Education V259A130001 / V259A130002 / V259A130003 / V259A130004 / V259A130005 / V259A130006 / V259A130007 / V259A180002 / V259A180003 / V259A180004 / V259A180007 / V259A180008 CFDA No. 84.259 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.318), every non-federal entity receiving federal awards must have written procurement procedures that conform to the procurement standards contained in the Uniform Guidance. Condition We noted that the Organization?s procurement policies and procedures, contained in the Fiscal Manual dated October 26, 2012, do not conform to the procurement standards contained in the Uniform Guidance. Cause The Organization did not update their procurement policies and procedures outlined in its Fiscal Manual since October 2012. Effect The Organization did not comply with procurement requirements contained in 2 CFR ? 200.318. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization update its procurement policies to conform to the procurement standards contained in the Uniform Guidance. Views of Responsible Officials and Planned Corrective Action ALU LIKE, Inc. will update its fiscal manual to provide a tighter nexus to our existing Conflict of Interest (ALI 211), Rules of Conduct (ALI 282), Monitoring (ALI 280), and Disciplinary/Corrective Action (ALI 275) policies. ALU LIKE, Inc. will also develop policies to address procurement requirements under OMB Guidance ?200.318 regarding a lease vs. purchase analysis, economical purchases such as bulk purchases, competent contracting, and the use of Federal Excess and Surplus property.
Show full finding ▾Hide full finding ▴Significant Deficiency Finding 2019-003 Procurement U.S. Department of Education Native Hawaiian Career and Technical Education V259A130001 / V259A130002 / V259A130003 / V259A130004 / V259A130005 / V259A130006 / V259A130007 / V259A180002 / V259A180003 / V259A180004 / V259A180007 / V259A180008 CFDA No. 84.259 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.318), every non-federal entity receiving federal awards must have written procurement procedures that conform to the procurement standards contained in the Uniform Guidance. Condition We noted that the Organization?s procurement policies and procedures, contained in the Fiscal Manual dated October 26, 2012, do not conform to the procurement standards contained in the Uniform Guidance. Cause The Organization did not update their procurement policies and procedures outlined in its Fiscal Manual since October 2012. Effect The Organization did not comply with procurement requirements contained in 2 CFR ? 200.318. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization update its procurement policies to conform to the procurement standards contained in the Uniform Guidance. Views of Responsible Officials and Planned Corrective Action ALU LIKE, Inc. will update its fiscal manual to provide a tighter nexus to our existing Conflict of Interest (ALI 211), Rules of Conduct (ALI 282), Monitoring (ALI 280), and Disciplinary/Corrective Action (ALI 275) policies. ALU LIKE, Inc. will also develop policies to address procurement requirements under OMB Guidance ?200.318 regarding a lease vs. purchase analysis, economical purchases such as bulk purchases, competent contracting, and the use of Federal Excess and Surplus property.
Finding 2019-003 Procurement U.S. Department of Education Native Hawaiian Career and Technical Education V259A130001 / V259A130002 / V259A130003 / V259A130004 / V259A130005 / V259A130006 / V259A130007 / V259A180002 / V259A180003 / V259A180004 / V259A180007 / V259A180008 CFDA No. 84.259 Condition The auditors noted that the Organization's procurement policies and procedures, contained in the Fiscal Manual dated October 26, 2012, do not conform to the procurement standards contained in the Uniform Guidance. Recommendation The auditors recommend that the Organization update its procurement policies to conform to the procurement standards contained in the Uniform Guidance. Action Taken ALU LIKE is still updating our policies and procedures and fiscal manual and drafting new policies and procedures to conform to the procurement standards in the Uniform Guidance.
Significant Deficiency Finding 2019-004 Subrecipient Monitoring U.S. Department of Education Native Hawaiian Career and Technical Education V259A130001 / V259A130002 / V259A130003 / V259A130004 / V259A130005 / V259A130006 / V259A130007 / V259A180002 / V259A180003 / V259A180004 / V259A180007 / V259A180008 CFDA No. 84.259 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.33), all pass-through entities (PTE) must monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes in compliance with federal statutes and the terms of the subawards. This includes verifying and obtaining single audit reports for every subrecipient whose federal expenditures exceed the threshold set forth in the Uniform Guidance. If necessary, the PTE must issue management decisions for audit findings that relate to federal awards made to the subrecipient and such management decisions must be issued within six months of acceptance of the audit report by the Federal Audit Clearinghouse. Additionally, the PTE must follow-up to ensure that the subrecipient takes timely and appropriate action on all deficiencies detected. Condition We noted that for one of nine subrecipients selected for testing, the Organization did not obtain the subrecipient?s single audit reports in a timely fashion. The single audit reports for the subrecipient?s June 30, 2018 fiscal year end was not received until February 2020. Furthermore, the Organization did not issue management decisions for audit findings that related to the federal award made to the subrecipient. Cause We were informed that the subrecipient?s audit report was not available during the Organization?s budget-year closeout period (December 2018), since the single audit reports were not issued until January 2019. Although the Organization followed-up with the subrecipient in May 2019, the single audit reports were not provided to the Organization until February 2020. Effect The Organization did not monitor the activities of this subrecipient in accordance with the Uniform Guidance. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization adhere to its established policies and procedures requiring subrecipients to submit required single audit reports on a timely basis for the Organization?s review. If necessary, management decisions should be issued for audit findings related to federal awards made to subrecipients. Views of Responsible Officials and Planned Corrective Action ALU LIKE understands the importance of adhering to established policies and procedures with respect to the timely submission of the required single audit report. Thus, ALU LIKE took the following actions to obtain the fiscal audit from its subrecipient: 1) On 11/14/19, the Sub-recipient?s Auditor emailed ALU LIKE, Inc. indicating they were in the process of completing their 6/30/19 audit; 2) ALU LIKE?s program specialist called the sub-recipient to ask about the status of the single audit report on the following dates: 05/01/19, 10/28/2019, 10/30/2019, 11/4/2019, 11/7/2019, 11/13/2019, 11/20/2019, 11/21/2019, 11/26/2019, and 1/29/2020; 3) In May of 2019 ALU LIKE?s administrative Assistant also sent an email requesting the status of the single audit report; 4) From December 4 -7, 2019 ALU LIKE?s Program Specialist conducted face to face reminders with the sub-recipient about the overdue single audit report at the Association for Career and Technical Conference; and 5) Subrecipient submitted their single audit report to ALU LIKE, Inc. on February 18, 2020 with a January 18, 2019 completion date. In the future, the sub-recipient will add ALU LIKE to their automatic list of Annual Audit recipients. Future communications regarding the request for documentation will be sent to the sub-recipients CEO and Director of Operations with a ?read receipt? to indicate the email was received. ALU LIKE, Inc. will conduct 30-day follow-ups if requested documents are not received and will take into account a sub recipient?s responsiveness before entering into a sub-recipient relationship under OMB Uniform Guidance ?200.318 (h).
Show full finding ▾Hide full finding ▴Significant Deficiency Finding 2019-004 Subrecipient Monitoring U.S. Department of Education Native Hawaiian Career and Technical Education V259A130001 / V259A130002 / V259A130003 / V259A130004 / V259A130005 / V259A130006 / V259A130007 / V259A180002 / V259A180003 / V259A180004 / V259A180007 / V259A180008 CFDA No. 84.259 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.33), all pass-through entities (PTE) must monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes in compliance with federal statutes and the terms of the subawards. This includes verifying and obtaining single audit reports for every subrecipient whose federal expenditures exceed the threshold set forth in the Uniform Guidance. If necessary, the PTE must issue management decisions for audit findings that relate to federal awards made to the subrecipient and such management decisions must be issued within six months of acceptance of the audit report by the Federal Audit Clearinghouse. Additionally, the PTE must follow-up to ensure that the subrecipient takes timely and appropriate action on all deficiencies detected. Condition We noted that for one of nine subrecipients selected for testing, the Organization did not obtain the subrecipient?s single audit reports in a timely fashion. The single audit reports for the subrecipient?s June 30, 2018 fiscal year end was not received until February 2020. Furthermore, the Organization did not issue management decisions for audit findings that related to the federal award made to the subrecipient. Cause We were informed that the subrecipient?s audit report was not available during the Organization?s budget-year closeout period (December 2018), since the single audit reports were not issued until January 2019. Although the Organization followed-up with the subrecipient in May 2019, the single audit reports were not provided to the Organization until February 2020. Effect The Organization did not monitor the activities of this subrecipient in accordance with the Uniform Guidance. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization adhere to its established policies and procedures requiring subrecipients to submit required single audit reports on a timely basis for the Organization?s review. If necessary, management decisions should be issued for audit findings related to federal awards made to subrecipients. Views of Responsible Officials and Planned Corrective Action ALU LIKE understands the importance of adhering to established policies and procedures with respect to the timely submission of the required single audit report. Thus, ALU LIKE took the following actions to obtain the fiscal audit from its subrecipient: 1) On 11/14/19, the Sub-recipient?s Auditor emailed ALU LIKE, Inc. indicating they were in the process of completing their 6/30/19 audit; 2) ALU LIKE?s program specialist called the sub-recipient to ask about the status of the single audit report on the following dates: 05/01/19, 10/28/2019, 10/30/2019, 11/4/2019, 11/7/2019, 11/13/2019, 11/20/2019, 11/21/2019, 11/26/2019, and 1/29/2020; 3) In May of 2019 ALU LIKE?s administrative Assistant also sent an email requesting the status of the single audit report; 4) From December 4 -7, 2019 ALU LIKE?s Program Specialist conducted face to face reminders with the sub-recipient about the overdue single audit report at the Association for Career and Technical Conference; and 5) Subrecipient submitted their single audit report to ALU LIKE, Inc. on February 18, 2020 with a January 18, 2019 completion date. In the future, the sub-recipient will add ALU LIKE to their automatic list of Annual Audit recipients. Future communications regarding the request for documentation will be sent to the sub-recipients CEO and Director of Operations with a ?read receipt? to indicate the email was received. ALU LIKE, Inc. will conduct 30-day follow-ups if requested documents are not received and will take into account a sub recipient?s responsiveness before entering into a sub-recipient relationship under OMB Uniform Guidance ?200.318 (h).
Finding 2019-004 Subrecipient Monitoring U.S. Department of Education Native Hawaiian Career and Technical Education V259A130001 / V259A130002 / V259A130003 / V259A130004 / V259A130005 / V259A130006 / V259A130007 / V259A180002 / V259A180003 / V259A180004 / V259A180007 / V259A180008 CFDA No. 84.259 Condition The auditors noted that for one of nine subrecipients selected for testing, the Organization did not obtain the subrecipient's single audit reports in a timely fashion. The single audit reports for the subrecipient's June 30, 2018 fiscal year end was not received until February 2020. Furthermore, the Organization did not issue management decisions for audit findings that related to the federal award made to the subrecipient. Recommendation The auditors recommend that the Organization adhere to its established policies and procedures requiring subrecipients to submit required single audit reports on a timely basis for the Organization's review. If necessary, management decisions should be issued for audit findings related to federal awards made to subrecipients. Action Taken ALU LIKE, Inc. is creating a check list to ensure all subrecipient documents are received in a timely manner. The checklist will require a paper trial of all requests for documents.
Significant Deficiency Finding 2019-005 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Labor 477 Cluster Native American Employment and Training AB-29204-16-55-A-15 / AB-30647-17-60-A-15 / AB-31832-18-60-A-15 / AB-32277-18-60-A-16 CFDA No. 17.265 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.430), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provide reasonable assurance that charges are accurate and allowable, and be incorporated into the official records of the non-federal entity. Condition The Organization?s policy requires the Personnel Officer to sign and date all Personnel Action Forms (PAFs) to indicate approval of the employee?s authorized pay rate prior to entering this information into the payroll system. We noted that for two of eight PAFs selected for testing, the Personnel Officer did not sign and date the PAFs approving the employee?s authorized pay rate. Cause We were informed that there were numerous changes in the Personnel Department over the last several years. As a result, the Personnel Officer did not consistently adhere to the Organization?s policy for documenting approval of the employees? authorized pay rate. Effect The affected employees? authorized pay rates were entered into the payroll system without proper documentation of the Personnel Officer?s approval. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization adhere to its established policies and procedures requiring that authorized pay rates be entered into the payroll system only upon the documented approval of the Personnel Officer. Views of Responsible Officials and Planned Corrective Action The Personnel Office is the only staff member who can approve and enter into ALU LIKE?s payroll system. The Personnel Office manually entered all pay rate entries into our new ADP payroll system, including staff and participants. The Personnel Officer will conduct a monthly review of all new payroll entries in the month to ensure she has signed authorization documentation. The payroll specialist will also do an additional review before filing the employee file.
Show full finding ▾Hide full finding ▴Significant Deficiency Finding 2019-005 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Labor 477 Cluster Native American Employment and Training AB-29204-16-55-A-15 / AB-30647-17-60-A-15 / AB-31832-18-60-A-15 / AB-32277-18-60-A-16 CFDA No. 17.265 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.430), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provide reasonable assurance that charges are accurate and allowable, and be incorporated into the official records of the non-federal entity. Condition The Organization?s policy requires the Personnel Officer to sign and date all Personnel Action Forms (PAFs) to indicate approval of the employee?s authorized pay rate prior to entering this information into the payroll system. We noted that for two of eight PAFs selected for testing, the Personnel Officer did not sign and date the PAFs approving the employee?s authorized pay rate. Cause We were informed that there were numerous changes in the Personnel Department over the last several years. As a result, the Personnel Officer did not consistently adhere to the Organization?s policy for documenting approval of the employees? authorized pay rate. Effect The affected employees? authorized pay rates were entered into the payroll system without proper documentation of the Personnel Officer?s approval. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the Organization adhere to its established policies and procedures requiring that authorized pay rates be entered into the payroll system only upon the documented approval of the Personnel Officer. Views of Responsible Officials and Planned Corrective Action The Personnel Office is the only staff member who can approve and enter into ALU LIKE?s payroll system. The Personnel Office manually entered all pay rate entries into our new ADP payroll system, including staff and participants. The Personnel Officer will conduct a monthly review of all new payroll entries in the month to ensure she has signed authorization documentation. The payroll specialist will also do an additional review before filing the employee file.
Finding 2019-005 Activities Allowed or Unallowed / Allowable Costs / Cost Principles U.S. Department of Labor 477 Cluster Native American Employment and Training AB-29204-16-55-A-15 / AB-30647-17-60-A-15 / AB-31832-18-60-A-15 / AB-32277-18-60-A-16 CFDA No.17.265 Condition The Organization's policy requires the Personnel Officer to sign and date all Personnel Action Forms (PAFs) to indicate approval of the employee's authorized pay rate prior to entering this information into the payroll system. The auditors noted that for two of eight PAFs selected for testing, the Personnel Officer did not sign and date the PAFs approving the employee's authorized pay rate. Recommendation The auditors recommend that the Organization adhere to its established policies and procedures requiring that authorized pay rates be entered into the payroll system only upon the documented approval of the Personnel Officer. Action Taken The Personnel Officer has reviewed all files to ensure all approvals have her signature. In the future, the Personnel Specialist will check each file for signature before it is filed.
Significant Deficiency Finding 2019-006 Reporting U.S. Department of Labor 477 Cluster Native American Employment and Training AB-29204-16-55-A-15 / AB-30647-17-60-A-15 / AB-31832-18-60-A-15 / AB-32277-18-60-A-16 CFDA No. 17.265 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.333), a non-federal entity must retain financial records, supporting documentation, statistical records and all other non-federal entity records pertinent to a federal award and reports submitted to the federal awarding agency. Condition The U.S. Department of Labor?s Bear Tracks system is utilized by all awardees to accumulate participant data, including various performance measures reported in the goal attainment section of the performance reports. We noted that for one of six performance reports selected for testing, the Organization did not maintain sufficient records to support certain performance measures contained in the performance report which was submitted to the U.S. Department of Labor. Cause The Organization did not print out and maintain its files pertinent information from the Bear Tracks system. This system does not maintain historical performance measures for program participants as of a particular point in time. Effect The underlying data to verify that the performance measures accumulated and summarized on the performance report was unavailable to provide documentation supporting the accuracy and completeness of this report. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit reported as Finding 2018-002. Recommendation We again recommend that the Organization adhere to its policies and procedures to maintain sufficient documentation to support performance measures contained in the performance reports, such as electronic screenshots or printed hard copies of records at the time these reports are prepared. Views of Responsible Officials and Planned Corrective Action We agree with this finding in part. ALU LIKE has two grants with the Department of Labor that is administered by two different Departments: Employment and Training and the Native Hawaiian Career and Technical Education. Both grants are required to use the Bear Tracks software. The previous findings were related to the point in time documentation of Bear Tracks for the Employment and Training Department. The current finding is related to the point in time documentation Bear Tracks for the Native Hawaiian Career and Technical Education Department. Although the Department was able to provide the auditor with a paper trail of raw data to substantiate their service numbers, moving forward, they will adopt the Employment and Training Department?s procedures to address the Beat Tracks point in time challenge.
Show full finding ▾Hide full finding ▴Significant Deficiency Finding 2019-006 Reporting U.S. Department of Labor 477 Cluster Native American Employment and Training AB-29204-16-55-A-15 / AB-30647-17-60-A-15 / AB-31832-18-60-A-15 / AB-32277-18-60-A-16 CFDA No. 17.265 Criteria In accordance with the Uniform Guidance (2 CFR ? 200.333), a non-federal entity must retain financial records, supporting documentation, statistical records and all other non-federal entity records pertinent to a federal award and reports submitted to the federal awarding agency. Condition The U.S. Department of Labor?s Bear Tracks system is utilized by all awardees to accumulate participant data, including various performance measures reported in the goal attainment section of the performance reports. We noted that for one of six performance reports selected for testing, the Organization did not maintain sufficient records to support certain performance measures contained in the performance report which was submitted to the U.S. Department of Labor. Cause The Organization did not print out and maintain its files pertinent information from the Bear Tracks system. This system does not maintain historical performance measures for program participants as of a particular point in time. Effect The underlying data to verify that the performance measures accumulated and summarized on the performance report was unavailable to provide documentation supporting the accuracy and completeness of this report. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit reported as Finding 2018-002. Recommendation We again recommend that the Organization adhere to its policies and procedures to maintain sufficient documentation to support performance measures contained in the performance reports, such as electronic screenshots or printed hard copies of records at the time these reports are prepared. Views of Responsible Officials and Planned Corrective Action We agree with this finding in part. ALU LIKE has two grants with the Department of Labor that is administered by two different Departments: Employment and Training and the Native Hawaiian Career and Technical Education. Both grants are required to use the Bear Tracks software. The previous findings were related to the point in time documentation of Bear Tracks for the Employment and Training Department. The current finding is related to the point in time documentation Bear Tracks for the Native Hawaiian Career and Technical Education Department. Although the Department was able to provide the auditor with a paper trail of raw data to substantiate their service numbers, moving forward, they will adopt the Employment and Training Department?s procedures to address the Beat Tracks point in time challenge.
Finding 2019-006 Reporting U.S. Department of Labor 477 Cluster Native American Employment and Training AB-29204-16-55-A-15 / AB-30647-17-60-A-15 / AB-31832-18-60-A-15 / AB-32277-18-60-A-16 CFDA No. 17.265 Condition The U.S. Department of Labor's Bear Tracks system is utilized by all awardees to accumulate participant data, including various performance measures reported in the goal attainment section of the performance reports. The auditors noted that for one of six performance reports selected for testing, the Organization did not maintain sufficient records to support certain performance measures contained in the performance report which was submitted to the U.S. Department of Labor. Recommendation The auditors again recommend that the Organization adhere to its policies and procedures to maintain sufficient documentation to support performance measures contained in the performance reports, such as electronic screenshots or printed hard copies of records at the time these reports are prepared. Action Taken The Native Hawaiian Career and Technical Education Department will adhere to the policies and procedures set out for the Employment and Training Department to address the point in time challenge of the Bear Tracks software.
2018-002
FAC accepted this audit on March 27, 2019 — management decision was due September 27, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-004
FAC accepted this audit on March 27, 2018 — management decision was due September 27, 2018.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on March 22, 2017 — management decision was due September 22, 2017.
GSA_MIGRATION
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