EIN: 520591554
UEI: RUJHF55469D6
Audited by: GELMAN, ROSENBERG & FREEDMAN
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 4, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 4, 2026 (2 days from today).
What is a management decision? →During our audit of Everstand’s compensation practices, we noted that certain salaries and benefits charged to Federal programs were allocated using predetermined estimates rather than contemporaneous records reflecting actual time spent. These allocations were not supported by detailed documentation, such as timekeeping records or personnel activity reports. Cause: Everstand has not implemented a system for documenting time and effort in a manner that complies with Federal requirements. The current process relies on estimates rather than actual, verifiable work performed. Effect or Potential Effect: Without accurate and documented time and effort reporting, there is a risk that Federal awards are either overcharged or undercharged for salaries and benefits. This creates the potential for noncompliance with Federal cost principles, and could lead to disallowed costs in the event of a monitoring or program audit. Questioned Costs: Without a system to track actual time and effort, the determination of questioned costs is not available. Context: We tested a statistically valid sample of employee salaries charged to Federal awards. The deficiencies noted were isolated to those employees working on multiple programs at a time. Identification as a Repeat Finding, if applicable: Not a repeat finding. Recommendation: We recommend improvements to the controls around time and effort reporting that identifies and allocates time based on actual level of effort. Additionally, we recommend periodic trainings for key personnel that discusses the requirements and importance of compliance with the Federal regulation.
Show full finding ▾Hide full finding ▴Finding 2025-002: Time/Salary Allocations (Significant Deficiency) Federal Agency: United States Department of Health and Human Services. Federal Program: Unaccompanied Children Program. Assistance Listing Number: 93.676 Pass-through Entity, if applicable: Not applicable. Award Identification Number and Year: All awards and all of 2025 fiscal year. Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): CFR §200.430 Compensation—personal services. States; (g) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee’s Salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: During our audit of Everstand’s compensation practices, we noted that certain salaries and benefits charged to Federal programs were allocated using predetermined estimates rather than contemporaneous records reflecting actual time spent. These allocations were not supported by detailed documentation, such as timekeeping records or personnel activity reports. Cause: Everstand has not implemented a system for documenting time and effort in a manner that complies with Federal requirements. The current process relies on estimates rather than actual, verifiable work performed. Effect or Potential Effect: Without accurate and documented time and effort reporting, there is a risk that Federal awards are either overcharged or undercharged for salaries and benefits. This creates the potential for noncompliance with Federal cost principles, and could lead to disallowed costs in the event of a monitoring or program audit. Questioned Costs: Without a system to track actual time and effort, the determination of questioned costs is not available. Context: We tested a statistically valid sample of employee salaries charged to Federal awards. The deficiencies noted were isolated to those employees working on multiple programs at a time. Identification as a Repeat Finding, if applicable: Not a repeat finding. Recommendation: We recommend improvements to the controls around time and effort reporting that identifies and allocates time based on actual level of effort. Additionally, we recommend periodic trainings for key personnel that discusses the requirements and importance of compliance with the Federal regulation.
Views of Responsible Officials: Management acknowledges the findings related to Payroll Allocation, and Training & Compliance, as outlined in the recent audit report. We appreciate the recommendations provided and are committed to implementing corrective actions to strengthen compliance, improve payroll allocation accuracy, and enhance staff knowledge of grant management requirements.
During our testing of subrecipient monitoring, we noted several exceptions as follows: No process was in place to verify that subrecipients are suspended or debarred from receiving Federal funds. Pre-award risk assessments were not completed. The monitoring procedures were not linked to assessed risk levels. The audited financial statements of the subrecipients were not received in order to assist in the risk assessment process. Cause: These conditions occurred due to a lack of formalized procedures to align subrecipient agreements, reporting requirements, and monitoring activities with the specific requirements of 2 CFR 200.332. Management relied on existing subcontract templates and internal policies that were not fully updated to reflect Uniform Guidance requirements. Effect or Potential Effect: Failure to properly structure subaward agreements, and obtain adequate financial reporting, increases the risk that subrecipients may not comply with Federal statutes and regulations. Questioned Costs: Costs associated with qualitative monitoring procedures are not identifiable. Context: We tested a statistically valid sample of subawards charged to Federal awards. The deficiencies noted were consistent across the sample population, indicating a systemic issue rather than isolated exceptions. Identification as a Repeat Finding, if applicable: Not a repeat finding. Recommendation: We recommend that management implement processes and procedures as follows: Establish formalized policies and procedures on subrecipient monitoring; Include a screening of subrecipients against the Federal suspended and debarred list as part of the contracting process; Implement pre-award risk assessments that clearly links monitoring procedures to the level of assessed risk; Document the monitoring procedures that occurred throughout the year in accordance with the established policies and procedures and identified risk assessment for each subrecipient.
Show full finding ▾Hide full finding ▴Finding 2025-003: Subrecipient Monitoring (Significant Deficiency) Federal Agency: United States Department of Health and Human Services. Federal Program: Unaccompanied Children Program. Assistance Listing Number: 93.676 Pass-through Entity, if applicable: Not applicable. Award Identification Number and Year: All awards and all of 2025 fiscal year. Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Criteria or specific requirement (including statutory, regulatory, or other citation): Per 2 CFR 200.332 Requirements for pass-through entities: Verify that the subrecipient is not excluded or disqualified in accordance with § 180.300. Pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate subrecipient monitoring (§200.332(b)). Verify that a subrecipient is audited as required. Condition: During our testing of subrecipient monitoring, we noted several exceptions as follows: No process was in place to verify that subrecipients are suspended or debarred from receiving Federal funds. Pre-award risk assessments were not completed. The monitoring procedures were not linked to assessed risk levels. The audited financial statements of the subrecipients were not received in order to assist in the risk assessment process. Cause: These conditions occurred due to a lack of formalized procedures to align subrecipient agreements, reporting requirements, and monitoring activities with the specific requirements of 2 CFR 200.332. Management relied on existing subcontract templates and internal policies that were not fully updated to reflect Uniform Guidance requirements. Effect or Potential Effect: Failure to properly structure subaward agreements, and obtain adequate financial reporting, increases the risk that subrecipients may not comply with Federal statutes and regulations. Questioned Costs: Costs associated with qualitative monitoring procedures are not identifiable. Context: We tested a statistically valid sample of subawards charged to Federal awards. The deficiencies noted were consistent across the sample population, indicating a systemic issue rather than isolated exceptions. Identification as a Repeat Finding, if applicable: Not a repeat finding. Recommendation: We recommend that management implement processes and procedures as follows: Establish formalized policies and procedures on subrecipient monitoring; Include a screening of subrecipients against the Federal suspended and debarred list as part of the contracting process; Implement pre-award risk assessments that clearly links monitoring procedures to the level of assessed risk; Document the monitoring procedures that occurred throughout the year in accordance with the established policies and procedures and identified risk assessment for each subrecipient.
Views of Responsible Officials: Management acknowledges the audit finding related to Subrecipient Monitoring and appreciates the opportunity to address this matter. We recognize the importance of robust monitoring procedures to ensure compliance with Federal requirements and mitigate risk. Although procedures exist for verifying SAM.gov registration (suspension/debarment status) and obtaining audited financial statements from subgrantees, these procedures were not documented or codified in the Caminos Nacional Policy Manual. Pre-award risk assessments have been conducted informally without a formal determination of risk, and protocols surrounding risk assessment were inadequately documented, resulting in inconsistent implementation.
During our review of subrecipient activities, we noted that Everstand was not submitting the required reporting under FFATA regulations. Cause: Internal controls over financial reporting were not operating effectively to ensure reporting under FFATA in a timely manner. Effect or Potential Effect: Failure to submit the required reports by the submission deadline results in noncompliance with the Federal Funding Accountability and Transparency Act of 2006 as outlined in Appendix A to 2 CFR Part 170. Questioned Costs: Costs associated with qualitative reporting requirements are not identifiable. Context: We tested a statistically valid sample of subawards charged to Federal awards. The deficiencies noted were consistent across the sample population, indicating a systemic issue rather than isolated exceptions. Identification as a Repeat Finding, if applicable: Not a repeat finding. Recommendation: We recommend that management strengthen controls over reporting requirements for each Federal award to ensure timely submission of required reports.
Show full finding ▾Hide full finding ▴Finding 2025-004: Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting (Significant Deficiency) Federal Agency: United States Department of Health and Human Services. Federal Program: Unaccompanied Children Program. Assistance Listing Number: 93.676 Pass-through Entity, if applicable: Not applicable. Award Identification Number and Year: All awards and all of 2025 fiscal year. Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR 200.332 and as required by the Federal Funding Accountability and Transparency Act of 2006 (Pub. L. 109–282), as amended by section 6202 of Public Law 110–252, recipients must report information for each subaward of $30,000 or more in Federal funds and executive total compensation, as outlined in Appendix A to 2 CFR Part 170. The information is to be submitted to the FFATA Subaward Reporting System (FSRS) by the end of the month following the month in which the subaward was awarded. Condition: During our review of subrecipient activities, we noted that Everstand was not submitting the required reporting under FFATA regulations. Cause: Internal controls over financial reporting were not operating effectively to ensure reporting under FFATA in a timely manner. Effect or Potential Effect: Failure to submit the required reports by the submission deadline results in noncompliance with the Federal Funding Accountability and Transparency Act of 2006 as outlined in Appendix A to 2 CFR Part 170. Questioned Costs: Costs associated with qualitative reporting requirements are not identifiable. Context: We tested a statistically valid sample of subawards charged to Federal awards. The deficiencies noted were consistent across the sample population, indicating a systemic issue rather than isolated exceptions. Identification as a Repeat Finding, if applicable: Not a repeat finding. Recommendation: We recommend that management strengthen controls over reporting requirements for each Federal award to ensure timely submission of required reports.
Views of Responsible Officials: Management acknowledges the audit finding related to the Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting and appreciates the opportunity to address this matter. Everstand does have an established procedure for consistent reporting of subrecipient activities as required under FFATA regulations. However, the lack of a clearly defined responsibility for this task resulted in non-compliance. Management recognizes this gap and is committed to implementing corrective measures to ensure full compliance moving forward.
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
FAC accepted this audit on April 1, 2024 — management decision was due October 1, 2024.
No documentation was retained regarding the solicitation of competitive prices for procurements meeting the small purchase threshold. Criteria or Specific Requirement: §200.320b. states that “Procurement by small purchase procedures: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Context: Our sample size was 8 out of a total population of 43 vendors over small purchase threshold during the year ended June 30, 2023. Questioned Costs: None. Effect: Significant vendors could be selected due to biases or without open competition. Cause: The Board did not obtain or document price quotes for the competitive solicitation related to the procurement of goods and services qualifying as small purchases. Repeat Finding: Yes. Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care’s procurement policy. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. Please see management’s planned corrective action in a separate letter.
Show full finding ▾Hide full finding ▴2023 – 001 Federal Agency: U.S. Department of Health and Human Services Program: Unaccompanied Children Program Assistance Listing Number: 93.676 Award Periods: July 1, 2022 – June 30, 2023. Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Condition: No documentation was retained regarding the solicitation of competitive prices for procurements meeting the small purchase threshold. Criteria or Specific Requirement: §200.320b. states that “Procurement by small purchase procedures: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Context: Our sample size was 8 out of a total population of 43 vendors over small purchase threshold during the year ended June 30, 2023. Questioned Costs: None. Effect: Significant vendors could be selected due to biases or without open competition. Cause: The Board did not obtain or document price quotes for the competitive solicitation related to the procurement of goods and services qualifying as small purchases. Repeat Finding: Yes. Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care’s procurement policy. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. Please see management’s planned corrective action in a separate letter.
2023-001 Assistance Listing Number: 93.676 – Unaccompanied Children Program Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care’s procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Chief Financial Officer to update procurement policy specifically related to documentation of vendor award process to ensure documentation is retained regarding solicitation and approval of vendors providing services related to the Board’s federal programs. Name(s) of the contact person(s) responsible for corrective action: Martin Lespada, Chief Financial Officer Planned completion date for corrective action plan: May 1, 2024 If the U.S. Department of Health and Human Services has questions regarding this plan, please call Martin Lespada at 410-922-2100.
2022-001
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
No documentation was retained regarding the solicitation of competitive prices for procurements meeting the small purchase threshold. Criteria or Specific Requirement: ?200.320b. states that ?Procurement by small purchase procedures: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Context: 47 vendors over small purchase threshold during the year ended June 30, 2022. Questioned Costs: None. Effect: Significant vendors could be selected due to biases or without open competition. Cause: The Board did not obtain or document price quotes for the competitive solicitation related to the procurement of goods and services qualifying as small purchases. Repeat Finding: Yes. Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care?s procurement policy. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. Please see management?s planned corrective action in a separate letter.
Show full finding ▾Hide full finding ▴2022 ? 001 Federal Agency: U.S. Department of Health and Human Services Program, CFDA: 93.676 - Residential Shelter Services for Unaccompanied Alien Children; Residential Long-Term Foster Care for Unaccompanied Alien Children; Board of Child Care Caminos Shelter Program ? Nacional; Board of Child Care Caminos Shelter Program - West Award Periods: July 1, 2021 ? June 30, 2022. Type of Finding: Significant deficiency in Internal Control over Compliance. Condition: No documentation was retained regarding the solicitation of competitive prices for procurements meeting the small purchase threshold. Criteria or Specific Requirement: ?200.320b. states that ?Procurement by small purchase procedures: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Context: 47 vendors over small purchase threshold during the year ended June 30, 2022. Questioned Costs: None. Effect: Significant vendors could be selected due to biases or without open competition. Cause: The Board did not obtain or document price quotes for the competitive solicitation related to the procurement of goods and services qualifying as small purchases. Repeat Finding: Yes. Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care?s procurement policy. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. Please see management?s planned corrective action in a separate letter.
U.S. Department of Health and Human Services 2022-001 CFDA 93.676 - Residential Shelter Services for Unaccompanied Alien Children; Residential Long-Term Foster Care for Unaccompanied Alien Children; Board of Child Care Caminos Shelter Program ? Nacional; Board of Child Care Caminos Shelter Program - West Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care?s procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Chief Financial Officer to update procurement policy specifically related to documentation of vendor award process to ensure documentation is retained regarding solicitation and approval of vendors providing services related to the Board?s federal programs. Name(s) of the contact person(s) responsible for corrective action: Terrell Boston-Smith, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2023 If the U.S. Department of Health and Human Services has questions regarding this plan, please call Terrell Boston-Smith at 410-922-2100.
2021-001
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
No documentation was retained regarding the solicitation of competitive prices for procurements meeting the small purchase threshold. Criteria or Specific Requirement: ?200.320b. states that ?Procurement by small purchase procedures: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Context: 10 vendors over small purchase threshold during the year ended June 30, 2021. Questioned Costs: None. Effect: Significant vendors could be selected due to biases or without open competition. Cause: The Board did not obtain or document price quotes for the competitive solicitation related to the procurement of goods and services qualifying as small purchases. Repeat Finding: Yes. Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care?s procurement policy. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. Please see management?s planned corrective action in a separate letter.
Show full finding ▾Hide full finding ▴2021 ? 001 Federal Agency: U.S. Department of Health and Human Services Program, CFDA: 93.676 - Residential Shelter Services for Unaccompanied Alien Children; Residential Long-Term Foster Care for Unaccompanied Alien Children; Board of Child Care Caminos Shelter Program ? Nacional; Board of Child Care Caminos Shelter Program - West Award Periods: July 1, 2020 ? June 30, 2021. Type of Finding: Significant deficiency in Internal Control over Compliance. Condition: No documentation was retained regarding the solicitation of competitive prices for procurements meeting the small purchase threshold. Criteria or Specific Requirement: ?200.320b. states that ?Procurement by small purchase procedures: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Context: 10 vendors over small purchase threshold during the year ended June 30, 2021. Questioned Costs: None. Effect: Significant vendors could be selected due to biases or without open competition. Cause: The Board did not obtain or document price quotes for the competitive solicitation related to the procurement of goods and services qualifying as small purchases. Repeat Finding: Yes. Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care?s procurement policy. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. Please see management?s planned corrective action in a separate letter.
CFDA 93.676 - Residential Shelter Services for Unaccompanied Alien Children; Residential Long-Term Foster Care for Unaccompanied Alien Children; Board of Child Care Caminos Shelter Program ? Nacional; Board of Child Care Caminos Shelter Program - West Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care?s procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Chief Financial Officer to update procurement policy specifically related to documentation of vendor award process to ensure documentation is retained regarding solicitation and approval of vendors providing services related to the Board?s federal programs. Name(s) of the contact person(s) responsible for corrective action: Terrell Boston-Smith, Chief Financial Officer Planned completion date for corrective action plan: December 31, 2022 If the U.S. Department of Health and Human Services has questions regarding this plan, please call Terrell Boston-Smith at 410-922-2100.
2020-001
FAC accepted this audit on March 30, 2021 — management decision was due September 30, 2021.
No documentation was retained regarding the solicitation of competitive prices for procurements meeting the small purchase threshold. Criteria or specific requirement: ?200.320b. states that ?Procurement by small purchase procedures: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Context: 31 vendors over small purchase threshold during the year ended June 30, 2020. Questioned Costs: None. Effect: Significant vendors could be selected due to biases or without open competition. Cause: The Board did not obtain or document price quotes for the competitive solicitation related to the procurement of goods and services qualifying as small purchases. Repeat Finding: No. Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care?s procurement policy. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Please see management?s planned corrective action in a separate letter.
Show full finding ▾Hide full finding ▴2020 ? 001 Federal Agency: U.S. Department of Health and Human Services Program, CFDA: 93.676 - Residential Shelter Services for Unaccompanied Alien Children; Residential Long-Term Foster Care for Unaccompanied Alien Children; Board of Child Care Caminos Shelter Program ? Nacional; Board of Child Care Caminos Shelter Program - West Award Periods: July 1, 2019 ? June 30, 2020. Type of finding: Significant deficiency in Internal Control over Compliance. Condition: No documentation was retained regarding the solicitation of competitive prices for procurements meeting the small purchase threshold. Criteria or specific requirement: ?200.320b. states that ?Procurement by small purchase procedures: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Context: 31 vendors over small purchase threshold during the year ended June 30, 2020. Questioned Costs: None. Effect: Significant vendors could be selected due to biases or without open competition. Cause: The Board did not obtain or document price quotes for the competitive solicitation related to the procurement of goods and services qualifying as small purchases. Repeat Finding: No. Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care?s procurement policy. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Please see management?s planned corrective action in a separate letter.
CFDA 93.676 - Residential Shelter Services for Unaccompanied Alien Children; Residential Long-Term Foster Care for Unaccompanied Alien Children; Board of Child Care Caminos Shelter Program ? Nacional; Board of Child Care Caminos Shelter Program - West Recommendation: We recommend Board of Child Care document and retain evidence of the solicitation of price quotes for federal purchases over the small purchase threshold in compliance with Uniform Guidance 200.320 and Board of Child Care?s procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Chief Financial Officer to update procurement policy specifically related to documentation of vendor award process to ensure documentation is retained regarding solicitation and approval of vendors providing services related to the Board?s federal programs. Name(s) of the contact person(s) responsible for corrective action: Bobby Baird, Chief Financial Officer Planned completion date for corrective action plan: April 15, 2021 If the U.S. Department of Health and Human Services has questions regarding this plan, please call Bobby Baird at 410-922-2100.
FAC accepted this audit on March 29, 2020 — management decision was due September 29, 2020.
No control was noted relative to the review of the reimbursements on the federal award. Criteria or specific requirement: ?200.319 states that "The non-Federal entity must have written procedures for procurement transactions. These procedures must ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Such description must not, in competitive procurements, contain features which unduly restrict competition" ?200.320b. states that ?Procurement by small purchase procedures: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Context: 58 vendors over small purchase threshold during the year ended June 30, 2019. Questioned Costs: None. Effect: Significant vendors could be selected due to biases or without open competition. Cause: The Board?s procurement policy was not updated to comply with updated UG regulations required to be implemented on July 1, 2018. Repeat Finding: No. Recommendation: We recommend the development and implementation of a procurement policy and conflict of interest policy that are in compliance with Uniform Guidance ?200.319-200.320. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Please see management?s planned corrective action in a separate letter.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Health and Human Services Program, CFDA: 93.676 - Caminos Shelter Program, LFTC, and Caminos Shelter West Program Award Periods: July 1, 2018 ? June 30, 2019. Type of finding: Material Weakness in Internal Control over Compliance. Condition: No control was noted relative to the review of the reimbursements on the federal award. Criteria or specific requirement: ?200.319 states that "The non-Federal entity must have written procedures for procurement transactions. These procedures must ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Such description must not, in competitive procurements, contain features which unduly restrict competition" ?200.320b. states that ?Procurement by small purchase procedures: Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." Context: 58 vendors over small purchase threshold during the year ended June 30, 2019. Questioned Costs: None. Effect: Significant vendors could be selected due to biases or without open competition. Cause: The Board?s procurement policy was not updated to comply with updated UG regulations required to be implemented on July 1, 2018. Repeat Finding: No. Recommendation: We recommend the development and implementation of a procurement policy and conflict of interest policy that are in compliance with Uniform Guidance ?200.319-200.320. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Please see management?s planned corrective action in a separate letter.
Recommendation: We recommend the development and implementation of a procurement policy in compliance with Uniform Guidance ?200.319-200.320. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Chief Financial Officer to update existing policy specifically related to procurement. Name(s) of the contact person(s) responsible for corrective action: Bobby Baird, Chief Financial Officer Planned completion date for corrective action plan: This policy update will be completed immediately. If the U.S. Department of Health and Human Services has questions regarding this plan, please call Bobby Baird at 410-922-2100.
FAC accepted this audit on March 27, 2019 — management decision was due September 27, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on January 9, 2017 — management decision was due July 9, 2017.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
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