EIN: 520700497
UEI: CLHCSTHHSX25
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 11, 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 January 11, 2026, which was (222 days ago).
What is a management decision? →Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Views of Responsible Officials: FASEB acknowledges the findings identified by the audit regarding procurement and suspension and debarment. We recognize the importance of maintaining adequate records of the procurement process to ensure compliance with federal regulations and to promote transparency and accountability in our operations. Managements Response to Audit Finding on inadequate recording of procurement history or justification: 1. Review and Update Procurement Policies: We will conduct a thorough review of our current procurement policies and procedures to identify any gaps or areas requiring improvement. Updates will be made to ensure that our procurement policies align with federal regulations, including those related to suspension and debarment. 2. Training for Staff: We will provide comprehensive training for all staff involved in the procurement process to ensure they understand the updated policies and the importance of maintaining proper records. Training will include guidance on documentation requirements, vendor selection criteria, and compliance with federal regulations. 3. Implementation of Record-Keeping System: We will implement a centralized, secure, and user-friendly record-keeping system to document all procurement activities. This system will include templates and checklists to guide staff in capturing all necessary information, including vendor selection, bid evaluations, contract awards, and verification of suspension and debarment status. 4. Regular Monitoring and Audits: We will establish a schedule for regular internal audits of the procurement process to ensure ongoing compliance and to identify any potential issues promptly. Findings from these audits will be reviewed by senior management, and corrective actions will be taken as needed. 5. Vendor Verification: We will enhance our procedures for verifying the suspension and debarment status of potential vendors before awarding contracts. This verification process will be documented and retained as part of the procurement records. Conclusion: FASEB is committed to addressing the findings related to procurement and suspension and debarment. We believe that the steps outlined in our corrective action plan will ensure compliance with Federal regulations and enhance the integrity and transparency of our procurement process. We appreciate the opportunity to improve our practices and will provide updates on our progress as requested.
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Views of Responsible Officials: FASEB acknowledges the audit finding regarding the exclusion of certain Federal expenditures from the Schedule of Expenditures of Federal Awards. We recognize the critical importance of accurately reporting all Federal expenditures to ensure compliance with Federal requirements and to maintain transparency in our financial reporting. Managements Response to Audit Finding on missing Federal expenditure on final SEFA: 1. Review and Update Financial Reporting Procedures: We will review and revise our current financial reporting procedures to ensure that all federal expenditures are accurately captured and reported in the SEFA. Specific emphasis will be placed on identifying all sources of federal funding and ensuring they are correctly classified and included in the SEFA.2. Training for Staff: Comprehensive training will be provided for all staff involved in the preparation and review of the SEFA. The training will cover federal reporting requirements, proper identification of federal expenditures, and the importance of accurate SEFA reporting. 3. Enhanced Review and Reconciliation Process: We will establish an enhanced review and reconciliation process to verify the completeness and accuracy of the SEFA before submission. This process will involve cross-checking federal expenditures against grant agreements, payment records, and other relevant documentation. Conclusion: FASEB is committed to addressing the findings related to the omission of Federal expenditures in the SEFA. We are confident that the steps outlined in our corrective action plan will ensure comprehensive and accurate reporting of all Federal expenditures. We value the opportunity to improve our financial reporting practices and will provide progress updates as requested.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 13, 2020. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 13, 2021, which was (1987 days ago).
What is a management decision? →Finding: 2019-002: Preparation of the SEFA ? Significant Deficiency CFDA: 47.074, 93.396, 93.837, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866 and 93.867 ? Research and Development Cluster Criteria: Management is responsible for the design, implementation and maintenance of internal controls relevant to the preparation and fair presentation of the schedule of expenditures of federal awards (SEFA) that is free from material misstatement, whether due to fraud or error. As per the Uniform Guidance, the auditee is required to prepare the SEFA in accordance with Section 200.510(b). Condition: The SEFA provided by the Federation incorrectly netted the program income received from its Biomedical Research grant against the expenditures incurred. As a result, the amount of total expenses reported by the SEFA were understated by $87,715. Cause: The Federation?s oversight of the preparation of the SEFA failed to note the netting of program income. Effect: The Federation is reporting inaccurate financial information. Repeat finding: No. Recommendation: We recommend the Federation follows its policies and procedures regarding the financial statement preparation, including the SEFA, to ensure the financial statements are accurately recorded and reconcile to the accounting records. Program income received by its federal programs should be used to reduce the amount requested for cost reimbursement rather than reducing the amount reported on the SEFA. Management?s Response: See corrective action plan.
Finding 2019-002: Preparation of the SEFA Recommendation: We recommend the Federation follows its policies and procedures regarding the financial statement preparation, including the SEFA, to ensure the financial statements are accurately recorded and reconcile to the accounting records. Program income received by its federal programs should be used to reduce the amount requested for cost reimbursement rather than reducing the amount reported on the SEFA. Action Taken: We agree with RSM?s recommendation to follow policies and procedures regarding the financial statement preparation, including the SEFA, to ensure the financial statements are accurately recorded and reconcile to the accounting records. FASEB follows policies and procedures for financials statement preparation and reconciles on a monthly basis. This finding, however, is in regard to the placement of an account representing program income on the SEFA only, which is prepared annually. We appreciate that this placement did not alter the net result of the SEFA or the financial statements. In 2019 there was an unusual arrangement where the MARC program earned registration income,FASEB presented the revenue on the SEFA as a contra amount to expense in error. As recommended by RSM US,LLP, our immediate corrective action for future events similar will be to present this income item as a reduction in the amount requested for cost reimbursement.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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