EIN: 510197097
UEI: KVLNN914CL99
Audited by: WEST RHODE AND ROBERTS
Oversight agency: 93 [Department of Health and Human Services]
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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 June 27, 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 December 27, 2025 (252 days ago).
What is a management decision? →FAC accepted this audit on July 3, 2024 — management decision was due January 3, 2025.
Due to the size of the staff, certain accounting functions are performed by the person who initiates the transactions. This results in a lack of segregation of accounting function responsibilities. Cause: The Organization’s accounting department is small which resulted in too many accounting functions with two staff persons. Effect: The lack of segregation of duties increases the possibility that a material misstatement in the entity’s financial statements will not be prevented or detected and corrected on a timely basis. Questioned Costs: There were no questioned costs.
Show full finding ▾Hide full finding ▴Program: All programs Criteria or Specific Requirement: No one employee should have access to multiple phases of a transaction. Payroll change reports should be reviewed by someone other than the employee preparing them. Condition: Due to the size of the staff, certain accounting functions are performed by the person who initiates the transactions. This results in a lack of segregation of accounting function responsibilities. Cause: The Organization’s accounting department is small which resulted in too many accounting functions with two staff persons. Effect: The lack of segregation of duties increases the possibility that a material misstatement in the entity’s financial statements will not be prevented or detected and corrected on a timely basis. Questioned Costs: There were no questioned costs.
We acknowledge the challenges that come with maintaining appropriate segregation of duties in a small accounting department and have implemented a new control measure to effectively mitigate the risks involved. Moving forward, the Executive Director will receive a copy of the payroll change report after each payroll where a change has occurred. The Executive Director will thoroughly review the report and any supporting documentation and initial it. The report will then be filed with the corresponding pay period's payroll journal entry. Additionally, the Executive Director has full access to view all historical payroll change reports within the payroll system.
FAC accepted this audit on March 28, 2023 — management decision was due September 28, 2023.
FAC accepted this audit on March 30, 2022 — management decision was due September 30, 2022.
FAC accepted this audit on March 22, 2021 — management decision was due September 22, 2021.
During our audit, we inquired with management regarding their suspension and debarment policy and identified that the Organization did not have a policy in place to ensure that their vendors are not suspended or debarred. Context: Ensuring that the Organization?s vendors are not suspended or debarred should be part of the expense approval process. Auditors tested a selection of expenses to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing. Cause: Management was not aware of the requirement to verify that vendors were not suspended or debarred. Effect: The Organization was not in compliance with Uniform Guidance requirements. Recommendation: We recommend that the Organization implement controls over compliance related to suspension and debarment. Questioned Costs: None Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2020-001 Suspension and Debarment Policy Criteria: The Uniform Guidance requires that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded. Condition: During our audit, we inquired with management regarding their suspension and debarment policy and identified that the Organization did not have a policy in place to ensure that their vendors are not suspended or debarred. Context: Ensuring that the Organization?s vendors are not suspended or debarred should be part of the expense approval process. Auditors tested a selection of expenses to determine if any of the selected vendors were suspended or debarred. None were identified as suspended or debarred in this testing. Cause: Management was not aware of the requirement to verify that vendors were not suspended or debarred. Effect: The Organization was not in compliance with Uniform Guidance requirements. Recommendation: We recommend that the Organization implement controls over compliance related to suspension and debarment. Questioned Costs: None Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
1. Finding 2020-001 Suspension and Debarment Policy a. Program Information: N/A b. Criteria: The Uniform Guidance requires that, for covered transactions, the non-Federal entity verify that entities are not suspended, debarred, or otherwise excluded. c. Condition: During our audit, we inquired with management regarding their suspension and debarment policy and identified that the Organization did not have a policy in place to ensure that their vendors are not suspended or debarred. Response: It was our understanding that we did not need a suspension and debarment policy as none of our transactions would be considered covered transactions as defined by the Uniform Guidance. Upon discussion with our prior auditor we were told ?Program CFDA 92.432 (our VIIC Federal grant) was not listed in the 2019 compliance supplement. Normally this would specifically say which compliance requirements apply to a particular grant. ?Procurement, Suspension and Debarment? is one of the 12 possible compliance requirements. When the grant is not listed in the compliance supplement it is up to the auditor to determine which of the 12 apply. Their determination based on the nature of the grant?s expenditures was that this compliance requirement did not apply in 2019. The procurement policy listed in the Accounting Manual satisfied the prior auditors. As such, we never had a policy in place. After reading the compliance supplement we note that federally required audit fees would need to fall under a suspension and debarment policy. Based on that determination we will submit for board approval on February 24, 2021 an updated Accounting Manual with the Suspension and Debarment policy added effective retroactively to January 1, 2021. Contact persons responsible for corrective action: 1. Leticia Zuno, Executive Director 2. Angela Noyes, Director of Finance Completion date: February 24, 2021
During our audit, we identified one employee?s payroll expenses which were not in accordance with the Organization?s approved cost allocation plan. Context: Reviewing for appropriate coding of time is part of the payroll approval process to ensure that the Organization only requests reimbursement for allowable activities. Auditors tested a selection of payroll expenses to determine if costs charged to the program were for conducting allowable activities per the grant agreement. While the activities of all selected employees were determined to be allowable per the grant agreement, the time for one employee was incorrectly coded and did not accurately reflect the program that should have been charged. While the Organization has multiple grants and contracts that allow for reimbursement for the same services performed, the incorrect coding was not identified during the initial review process. Management later identified the issue, but due to the passage of time, the employee could not determine how much time should have been charged to the other program and because the services were allowable under both programs, no adjustment was made. Cause: The employee was originally only working on one program, but began splitting time between two different programs, the alternate program charged was a fixed rate contract, and management was working from home which disrupted the typical review. Effect: The Organization?s controls did not identify that payroll expenses between February and September 2020 for a certain employee were not allocated correctly. Recommendation: We recommend that the Organization re-train employees on proper coding of time and review the payroll allocation review process to ensure that it can be performed effectively in the office or at home. Questioned Costs: None Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2020-002 Payroll Allocation Review Program: CFDA 93.432 ACL Centers for Independent Living Cluster Criteria: The Uniform Guidance requires the existence of internal controls to determine that charges to federal awards are for allowable activities and that the costs are adequately documented. Condition: During our audit, we identified one employee?s payroll expenses which were not in accordance with the Organization?s approved cost allocation plan. Context: Reviewing for appropriate coding of time is part of the payroll approval process to ensure that the Organization only requests reimbursement for allowable activities. Auditors tested a selection of payroll expenses to determine if costs charged to the program were for conducting allowable activities per the grant agreement. While the activities of all selected employees were determined to be allowable per the grant agreement, the time for one employee was incorrectly coded and did not accurately reflect the program that should have been charged. While the Organization has multiple grants and contracts that allow for reimbursement for the same services performed, the incorrect coding was not identified during the initial review process. Management later identified the issue, but due to the passage of time, the employee could not determine how much time should have been charged to the other program and because the services were allowable under both programs, no adjustment was made. Cause: The employee was originally only working on one program, but began splitting time between two different programs, the alternate program charged was a fixed rate contract, and management was working from home which disrupted the typical review. Effect: The Organization?s controls did not identify that payroll expenses between February and September 2020 for a certain employee were not allocated correctly. Recommendation: We recommend that the Organization re-train employees on proper coding of time and review the payroll allocation review process to ensure that it can be performed effectively in the office or at home. Questioned Costs: None Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2. Finding 2020-002 Payroll Allocation Review a. Program Information: CFDA 93.432 ACL Centers for Independent Living Cluster b. Criteria: The Uniform Guidance requires the existence of internal controls to determine that charges to federal awards are for allowable activities and that the costs are adequately documented. c. Condition: During our audit, we identified one employee?s payroll expenses which were not in accordance with the Organization?s approved cost allocation plan. Response: There are controls in place to determine that charges to federal awards are for allowable activities and that the costs are adequately documented. We have preventative controls in place to try and prevent errors as well as detective controls to detect errors. Preventative controls include manager approvals of staff time, allocations, and personal activity report documentation. The payroll clerk also checks allocations to make sure they are in accordance with our cost allocation plan before processing payroll. Detective controls include comparing the budgeted payroll to actual payroll and analyzing and correcting anomalies. Due to the global pandemic that caused the organization to switch to a work from home status, the controls that normally work, failed to discover the error in time to make a quicker determination. The payroll expense selected did have an error as it was allocated to a funding source different than our approved allocation, however the error was detected prior to the audit. At the time it was discovered, it was determined that the expense could be paid from either funding source as the work performed was the same. If the employee had been performing duties that would not have been allowable on that particular funding source, an administrative correction would have been noted on the timesheet and the general ledger allocation corrected. When the error was discovered a discussion was had with both the manager and the staff person to remember to accurately record to the correct funding source, staying as close to the allocation as possible. Contact persons responsible for corrective action: 1. Leticia Zuno, Executive Director 2. Angela Noyes, Director of Finance Completion date: September 30, 2020
FAC accepted this audit on April 7, 2020 — management decision was due October 7, 2020.
FAC accepted this audit on March 10, 2019 — management decision was due September 10, 2019.
FAC accepted this audit on March 18, 2018 — management decision was due September 18, 2018.
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on December 21, 2016 — management decision was due June 21, 2017.
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