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LATIN AMERICAN YOUTH CENTER, INCNon-Profit

EIN: 521023074

UEI: C89ALDVJ4VJ3

Audited by: GELMAN, ROSENBERG & FREEDMAN

Oversight agency: 93 [Department of Health and Human Services]

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Data as of August 28, 2026

LATIN AMERICAN YOUTH CENTER, INC10 audit years22 findings9 repeat
10
Audit Years
22
Total Findings
9
Repeat Findings
$6.2M
Federal Awards Expended (FY 2025)

FY 2025-09-30

LOW-RISK AUDITEE$6,245,614 federal awards expendedNo findings recorded this year

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on May 8, 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 November 8, 2026 (70 days from today).

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FY 2024-09-30

LOW-RISK AUDITEE$6,766,925 federal awards expended

FAC accepted this audit on April 9, 2025 — management decision was due October 9, 2025.

2024-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

We identified one instance in which the Center did not submit a sub-recipient's FFATA report. Cause: The Center does not have the appropriate staffing in place to ensure compliance with this specific requirement. Effect or Potential Effect: The Center was not in compliance with FFATA reporting requirements. Questioned Costs: None noted. Context: We performed statistical sampling procedures over the Center's sub-recipients required to be reported under FFATA. We consider this sample representative of the population. 1 out of 1 samples were missing the FFATA requirement. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that the Center clearly communicate FFATA reporting requirements to responsible staff, and conduct regular training's to ensure that there is an understanding of requirements to be in compliance with FFATA.

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Finding 2024-001: Non-Compliance with Federal Fund Accountability and Transparency Act Information on the Federal Program: 14.276 Criteria or Specific Requirement: In accordance with 2 CFR Chapter 1, Part 170, prime awardees of a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardees awards any sub-award equal to or greater than $30,000 in Federal funds that does not include recovery funds. Condition: We identified one instance in which the Center did not submit a sub-recipient's FFATA report. Cause: The Center does not have the appropriate staffing in place to ensure compliance with this specific requirement. Effect or Potential Effect: The Center was not in compliance with FFATA reporting requirements. Questioned Costs: None noted. Context: We performed statistical sampling procedures over the Center's sub-recipients required to be reported under FFATA. We consider this sample representative of the population. 1 out of 1 samples were missing the FFATA requirement. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that the Center clearly communicate FFATA reporting requirements to responsible staff, and conduct regular training's to ensure that there is an understanding of requirements to be in compliance with FFATA.

Corrective Action Plan

Views of Responsible Officials: To ensure compliance moving forward, the Center, as a direct recipient, will identify all Federal grants where they have a subaward reporting recipient, along with their reporting timelines and deadlines. The Center has likewise identified the staff owner of FFATA reporting within the Center. Immediately after the finding during the audit, the Center has prepared the subsequent year’s FFATA report to ensure compliance in subsequent fiscal year, 2025.

About Reporting →

FY 2023-09-30

LOW-RISK AUDITEE$5,984,608 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 9, 2024 — management decision was due October 9, 2024.

FY 2022-09-30

LOW-RISK AUDITEE$4,697,688 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 16, 2023 — management decision was due September 16, 2023.

FY 2021-09-30

LOW-RISK AUDITEE$3,815,807 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 2, 2022 — management decision was due November 2, 2022.

FY 2020-09-30

$3,711,290 federal awards expended

FAC accepted this audit on May 12, 2021 — management decision was due November 12, 2021.

2020-001
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYREPEAT OF 2019-003OTHER MATTERS

During our audit, we noted several cases in which the Center did not perform, or did not maintain proper support to demonstrate that it performed, terrorist screening of its contractors, consultants, vendors, etc. in accordance with the above-noted requirements. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. Cause: The Center does not have policies and procedures in place with respect to these requirements. Effect or Potential Effect: The Center could inadvertently contract with and/or make payments to vendors, consultants and contractors who have been disbarred, suspended or otherwise excluded from receiving Federal funds. Questioned Costs: None noted. Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: 2019-003 Recommendation: We recommend that the Center develop a formal policy with respect to this requirement to ensure screening processes are conducted properly, timely and that the process is properly documented. Furthermore, management should regularly communicate these policies and procedures to all employees, and it should emphasize the importance of maintaining full compliance with U.S. Government ?anti-terrorism? provisions.

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Finding 2020-001: Compliance with U.S. Government Terrorism Requirements Federal Programs: All Programs Criteria: The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 was enacted in order to deter and punish terrorist acts in the United States and around the world and to enhance law enforcement investigatory tools. Executive Order (EO) 13224, which was signed into law during 2001, provides a means by which to disrupt the financial support network for terrorists and related organizations by authorizing the U.S. Treasury, in consultation with other U.S. Government agencies, to designate and block the assets of foreign individuals and entities that commit, or pose a significant risk of committing, acts of terrorism. Condition: During our audit, we noted several cases in which the Center did not perform, or did not maintain proper support to demonstrate that it performed, terrorist screening of its contractors, consultants, vendors, etc. in accordance with the above-noted requirements. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. Cause: The Center does not have policies and procedures in place with respect to these requirements. Effect or Potential Effect: The Center could inadvertently contract with and/or make payments to vendors, consultants and contractors who have been disbarred, suspended or otherwise excluded from receiving Federal funds. Questioned Costs: None noted. Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: 2019-003 Recommendation: We recommend that the Center develop a formal policy with respect to this requirement to ensure screening processes are conducted properly, timely and that the process is properly documented. Furthermore, management should regularly communicate these policies and procedures to all employees, and it should emphasize the importance of maintaining full compliance with U.S. Government ?anti-terrorism? provisions.

Corrective Action Plan

Views of Responsible Officials: Management agrees that there needs to be a formal process to screen and ensure that all of its vendors, contractors, consultants, etc are in accordance with the Obstruct Terrorism Act of 2001. Management has fully implemented a screening process in FY21 to resolve this finding.

Prior Finding References

2019-003

About Procurement and Suspension and Debarment →
2020-002
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYREPEAT OF 2019-005OTHER MATTERS

The Center did not track the expenses and didn't provide the necessary documentation to meet the individual cost-share requirements under the provisions of the grants. Cause: The Center does not have policies and procedures in place with respect to these requirements. Effect or Potential Effect: The Center did not adhere to the matching requirements of the Federal awards. Questioned Costs: None noted. Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: 2019-005 Recommendation: We recommend the Center ensure that costs included as a match meet the basic criteria for acceptable matching, including that the costs are not paid by the Federal Government under another award. We recommend that the Center implement policies to monitor the required matching contributions to ensure they are met.

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Finding 2020-002: Cost Share Documentation Federal Programs: All Programs Criteria: CFR 200.306 ?Cost Sharing or Matching? states that for all Federal awards, any shared costs or matching funds and all contributions, including cash and third party in-kind contributions, must be accepted as part of the non-Federal entity's cost sharing or matching when such contributions meet all of the following criteria: (1) Are verifiable from the non-Federal entity's records; (2) Are not included as contributions for any other Federal award; (3) Are necessary and reasonable for accomplishment of project or program objectives; (4) Are allowable under Subpart E?Cost Principles; (5) Are not paid by the Federal Government under another Federal award, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs; (6) Are provided for in the approved budget when required by the Federal awarding agency; and (7) Conform to other provisions as applicable. Condition: The Center did not track the expenses and didn't provide the necessary documentation to meet the individual cost-share requirements under the provisions of the grants. Cause: The Center does not have policies and procedures in place with respect to these requirements. Effect or Potential Effect: The Center did not adhere to the matching requirements of the Federal awards. Questioned Costs: None noted. Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: 2019-005 Recommendation: We recommend the Center ensure that costs included as a match meet the basic criteria for acceptable matching, including that the costs are not paid by the Federal Government under another award. We recommend that the Center implement policies to monitor the required matching contributions to ensure they are met.

Corrective Action Plan

Views of Responsible Officials: Management agrees that there needs to be a process to track Cost Share matching contributions. Management has fully implemented a policy in FY21 to resolve the finding.

Prior Finding References

2019-005

About Matching, Level of Effort, Earmarking →

FY 2019-09-30

$3,782,014 federal awards expended

FAC accepted this audit on July 22, 2020 — management decision was due January 22, 2021.

2019-001
Other
SIGNIFICANT DEFICIENCYREPEAT OF 2018-001OTHER MATTERS

At the commencement of our 2019 audit fieldwork, LAYC had made improvement in reconciling asset and liability accounts; however, we did continue to note a few of these accounts were not reconciled as of September 30, 2019. Upon further inquiry, it was noted that management was unable to perform monthly close-out procedures for all accounts, and thus, some accounts remained unreconciled throughout the duration of the year. Cause: The Center did not have the proper internal controls in place to ensure timely and accurate reconciliation of its asset and liability accounts. Effect or Potential Effect: Without timely and accurate reconciliation of all asset and liability accounts, there exists the potential for undetected errors or misappropriation of funds, as well as internal financial statements that are incomplete, inaccurate and unreliable. Questioned Costs: None noted. Context: There was improvement in the process from the prior year; however, not all accounts were reconciled adequately or in a timely basis. Due to the improvement noted, the current year finding is classified as a significant deficiency. Identification as a Repeat Finding: Finding 2018-001 Recommendation: Accordingly, we recommend that all asset and liability accounts be reconciled on a regular basis(i.e. monthly), as well as before the start of the audit. This process should result in prevention of, or timely detection of, errors, omissions, and misappropriation of funds. We also recommend that these procedures be formalized in writing and incorporated into the accounting policies and procedures manual. All reconciliations should be reviewed and approved by management.

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Finding 2019-001: Reconciliation of Asset and Liability Accounts Federal Programs: All Programs Criteria: As stated in 2 CFR 200.303, the non-federal entity (i.e. the Center) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or in the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: At the commencement of our 2019 audit fieldwork, LAYC had made improvement in reconciling asset and liability accounts; however, we did continue to note a few of these accounts were not reconciled as of September 30, 2019. Upon further inquiry, it was noted that management was unable to perform monthly close-out procedures for all accounts, and thus, some accounts remained unreconciled throughout the duration of the year. Cause: The Center did not have the proper internal controls in place to ensure timely and accurate reconciliation of its asset and liability accounts. Effect or Potential Effect: Without timely and accurate reconciliation of all asset and liability accounts, there exists the potential for undetected errors or misappropriation of funds, as well as internal financial statements that are incomplete, inaccurate and unreliable. Questioned Costs: None noted. Context: There was improvement in the process from the prior year; however, not all accounts were reconciled adequately or in a timely basis. Due to the improvement noted, the current year finding is classified as a significant deficiency. Identification as a Repeat Finding: Finding 2018-001 Recommendation: Accordingly, we recommend that all asset and liability accounts be reconciled on a regular basis(i.e. monthly), as well as before the start of the audit. This process should result in prevention of, or timely detection of, errors, omissions, and misappropriation of funds. We also recommend that these procedures be formalized in writing and incorporated into the accounting policies and procedures manual. All reconciliations should be reviewed and approved by management.

Corrective Action Plan

Views of Responsible Officials: Management agrees that the Center needs an improved reconciliation processes. With the hiring of a new Chief Financial Officer (CFO) in October 2019,significant progress has been made in the area of internal controls. With the full implementation of the Intacct accounting system, and a reorganized and strengthened business office, the Center expects to begin reconciling all asset and liability accounts on a monthly basis. Management has also communicated this message across the organization, since programmatic staff play a key role in providing information to the business office to ensure timely reconciliations. Beginning in fiscal year 2020, all balance sheet accounts have been reconciled within 30 days of the prior month end. Management expects this significant deficiency to be cured in FY 20.

Prior Finding References

2018-001

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2019-002
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2018-002OTHER MATTERS

During our audit, we noted instances where we were unable to agree the numbers within the federal financial reports submitted to Federal grantors with the numbers reported in the Center?s financial records. While it appears that the total expenditures are appropriately stated, cash on-hand as stated in the federal financial reports did not agree to the Center?s financial records. We also noted several instances where federal financial reports or programmatic reports were not submitted within the deadlines outlined in the grant agreements. Cause: The Center did not have the proper internal controls in place around its grants management to ensure timely and accurate federal financial reports as part of compliance with the Federal regulations. Effect or Potential Effect: The Center misreported its federal activity on its federal financial reports. Questioned Costs: None noted. Context: Federal financial reports were not prepared adequately and/or submitted on a timely basis. The issue is considered systemic in nature. Identification as a Repeat Finding: 2018-002 Recommendation: We continue to recommend that the Center implement policies and procedures to ensure that amounts noted in Federal financial reports agree to the figures presented within the Center?s financial statements. The established policies and procedures should also ensure tracking the progress of the preparation and submission of federal financial and programmatic reports throughout the year in order to ensure that they are submitted timely and in accordance with specific grant terms.

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Finding 2019-002: Federal Financial Reporting Federal Programs: All Programs Criteria: Various grantors require that the Center submit a quarterly Federal Financial Report (FFR), SF-425, in accordance with the quarterly schedule indicated in its grant agreement, within 30 days following the end of each calendar quarter. Condition: During our audit, we noted instances where we were unable to agree the numbers within the federal financial reports submitted to Federal grantors with the numbers reported in the Center?s financial records. While it appears that the total expenditures are appropriately stated, cash on-hand as stated in the federal financial reports did not agree to the Center?s financial records. We also noted several instances where federal financial reports or programmatic reports were not submitted within the deadlines outlined in the grant agreements. Cause: The Center did not have the proper internal controls in place around its grants management to ensure timely and accurate federal financial reports as part of compliance with the Federal regulations. Effect or Potential Effect: The Center misreported its federal activity on its federal financial reports. Questioned Costs: None noted. Context: Federal financial reports were not prepared adequately and/or submitted on a timely basis. The issue is considered systemic in nature. Identification as a Repeat Finding: 2018-002 Recommendation: We continue to recommend that the Center implement policies and procedures to ensure that amounts noted in Federal financial reports agree to the figures presented within the Center?s financial statements. The established policies and procedures should also ensure tracking the progress of the preparation and submission of federal financial and programmatic reports throughout the year in order to ensure that they are submitted timely and in accordance with specific grant terms.

Corrective Action Plan

Views of Responsible Officials: Management agrees that federal financial reporting should be completed timely and accurately. The Center expects to address this deficiency with its reorganized and strengthened business office under the leadership of the new CFO. During fiscal year 2019, the Center developed a comprehensive grants repository which captures several data elements related to federal awards, including financial reporting deadlines and requirements. The grant repository will be available to all key staff responsible for tracking federal awards in FY20. Additionally, the CFO now reviews all reports prior to submission to ensure reported numbers agree with the Center?s financial records. Management expects this significant deficiency to be cured in FY 20.

Prior Finding References

2018-002

About Reporting →
2019-003
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our audit, we noted several cases in which the Center did not perform, or did not maintain proper support to demonstrate that it performed, terrorist screening of its contractors, consultants, vendors, etc. in accordance with the above-noted requirements. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. Cause: The Center does not have policies and procedures in place with respect to these requirements. Effect or Potential Effect: The Center could inadvertently contract with and/or make payments to vendors, consultants and contractors who have been disbarred, suspended or otherwise excluded from receiving Federal funds. Questioned Costs: None noted.Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable Recommendation: We recommend that the Center develop a formal policy with respect to this requirement to ensure screening processes are conducted properly, timely and that the process is properly documented. Furthermore, management should regularly communicate these policies and procedures to all employees, and it should emphasize the importance of maintaining full compliance with U.S. Government ?anti-terrorism? provisions.

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Finding 2019-003: Compliance with U.S. Government Terrorism Requirements Federal Programs: All Programs Criteria: The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 was enacted in order to deter and punish terrorist acts in the United States and around the world and to enhance law enforcement investigatory tools. Executive Order (EO) 13224, which was signed into law during 2001, provides a means by which to disrupt the financial support network for terrorists and related organizations by authorizing the U.S. Treasury, in consultation with other U.S. Government agencies, to designate and block the assets of foreign individuals and entities that commit, or pose a significant risk of committing, acts of terrorism. Condition: During our audit, we noted several cases in which the Center did not perform, or did not maintain proper support to demonstrate that it performed, terrorist screening of its contractors, consultants, vendors, etc. in accordance with the above-noted requirements. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. Cause: The Center does not have policies and procedures in place with respect to these requirements. Effect or Potential Effect: The Center could inadvertently contract with and/or make payments to vendors, consultants and contractors who have been disbarred, suspended or otherwise excluded from receiving Federal funds. Questioned Costs: None noted.Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable Recommendation: We recommend that the Center develop a formal policy with respect to this requirement to ensure screening processes are conducted properly, timely and that the process is properly documented. Furthermore, management should regularly communicate these policies and procedures to all employees, and it should emphasize the importance of maintaining full compliance with U.S. Government ?anti-terrorism? provisions.

Corrective Action Plan

Views of Responsible Officials: Managed agrees that there needs to be a formal process to screen process to ensure that none of its vendors, contractors, consultants, etc are in accordance with the Obstruct Terrorism Act of 2001. Management will institute a screen process in FY 20.

About Procurement and Suspension and Debarment →
2019-004
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Center does not consistently follow its own internal procurement policy, as we noted multiple instances where it had failed to document its competitive bid process by obtaining quotations.Cause: The Center did not adhere to its procurement policy in that it failed to perform the prescribed procurement procedures throughout the fiscal year. 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, and thus, there lies the potential that the Center will not receive the best value for its purchases. The procurement process should also allow for an evaluation of potential conflicts of interest with prospective vendors and contractors. Furthermore, failure to perform the proper procurement procedures could result in disallowance of federal expenditures based on lack of fair competition. Questioned Costs: None noted. Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable Recommendation: We recommend all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompany the procurement documentation. Without proper procurement documentation, there is a risk that the Center will not perform proper evaluation of each element of cost to determine reasonableness. We also believe all long-standing contractual engagements should evidence occasional re-evaluation to ensure such relationships are free of conflicts and are continuing to provide the Center with an acceptable standard of service. Lastly, we suggest the Center incorporate such provisions into its procurement policies, and communicate such policies to all employees, not only to provide transparency with respect to such transactions, but also to ensure the Center are in compliance with specific donor requirements regarding general procurement justification.

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Finding 2019-004: Procurement Federal Programs: All Programs Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, paragraph 318 ?General procurement standards? states that the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards. Furthermore, paragraph 319 ?Competition? states that all procurement transactions must be conducted in a manner providing full and open competition consistent with these standards. Condition: The Center does not consistently follow its own internal procurement policy, as we noted multiple instances where it had failed to document its competitive bid process by obtaining quotations.Cause: The Center did not adhere to its procurement policy in that it failed to perform the prescribed procurement procedures throughout the fiscal year. 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, and thus, there lies the potential that the Center will not receive the best value for its purchases. The procurement process should also allow for an evaluation of potential conflicts of interest with prospective vendors and contractors. Furthermore, failure to perform the proper procurement procedures could result in disallowance of federal expenditures based on lack of fair competition. Questioned Costs: None noted. Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable Recommendation: We recommend all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompany the procurement documentation. Without proper procurement documentation, there is a risk that the Center will not perform proper evaluation of each element of cost to determine reasonableness. We also believe all long-standing contractual engagements should evidence occasional re-evaluation to ensure such relationships are free of conflicts and are continuing to provide the Center with an acceptable standard of service. Lastly, we suggest the Center incorporate such provisions into its procurement policies, and communicate such policies to all employees, not only to provide transparency with respect to such transactions, but also to ensure the Center are in compliance with specific donor requirements regarding general procurement justification.

Corrective Action Plan

Views of Responsible Officials: Management agrees that there needs to be a formal bidding process for contracts and will implement process beginning in FY 20. This will ensure that the Center secure goods and services at fair and reasonable prices. Additionally, Management will review all longstanding contacts so ensure they are in fact reasonable based on today?s market. Management will also communicate to the programmatic staff the new process to provide transparency and to ensure we are in compliance with funder agreements.

About Procurement and Suspension and Debarment →
2019-005
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Center did not track the expenses and didn't provide the necessary documentation to meet the individual cost-share requirements under the provisions of the grants. Cause: The Center does not have policies and procedures in place with respect to these requirements. Effect or Potential Effect: The Center did not adhere to the matching requirements of the Federal awards. Questioned Costs: None noted. Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable Recommendation: We recommend the Center ensure that costs included as a match meet the basic criteria for acceptable matching, including that the costs are not paid by the Federal Government under another award. We recommend that the Center implement policies to monitor the required matching contributions to ensure they are met.

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Finding 2019-005: Cost Share Documentation Federal Programs: All Programs Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, paragraph 306 ?Cost sharing or matching? states that for all Federal awards, any shared costs or matching funds and all contributions, including cash and third party in-kind contributions, must be accepted as part of the non-Federal entity's cost sharing or matching when such contributions meet all of the following criteria:(1) Are verifiable from the non-Federal entity's records;(2) Are not included as contributions for any other Federal award;(3) Are necessary and reasonable for accomplishment of project or program objectives;(4) Are allowable under Subpart E?Cost Principles;(5) Are not paid by the Federal Government under another Federal award, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs; (6) Are provided for in the approved budget when required by the Federal awarding agency; and (7) Conform to other provisions as applicable.Condition: The Center did not track the expenses and didn't provide the necessary documentation to meet the individual cost-share requirements under the provisions of the grants. Cause: The Center does not have policies and procedures in place with respect to these requirements. Effect or Potential Effect: The Center did not adhere to the matching requirements of the Federal awards. Questioned Costs: None noted. Context: The Center failed to perform and/or properly document its due diligence with respect to these requirements. The issue is considered systemic in nature. Identification as a Repeat Finding: Not applicable Recommendation: We recommend the Center ensure that costs included as a match meet the basic criteria for acceptable matching, including that the costs are not paid by the Federal Government under another award. We recommend that the Center implement policies to monitor the required matching contributions to ensure they are met.

Corrective Action Plan

Views of Responsible Officials: Management agrees that there needs to be a process to track Cost Share matching contributions. The Center will implement a policy in FY 20 to ensure that matching contributions are properly documented and tracked.

About Matching, Level of Effort, Earmarking →

FY 2018-09-30

MATERIAL NONCOMPLIANCE DISCLOSED$3,441,026 federal awards expended

FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.

2018-001
Other
MATERIAL WEAKNESSREPEAT OF 2017-001OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-001

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2018-002
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2017-009OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-009

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2018-003
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2017-003OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-003

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FY 2017-09-30

LOW-RISK AUDITEE$4,337,232 federal awards expended

FAC accepted this audit on September 29, 2018 — management decision was due March 29, 2019.

2017-001
Reporting
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-002
Cost Allowability
MATERIAL WEAKNESSSIGNIFICANT DEFICIENCYREPEAT OF 2016-001OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-001

About Allowable Costs / Cost Principles →
2017-003
Other
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-004
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-005
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2017-006
Reporting
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-007
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-008
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-009
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2016-09-30

LOW-RISK AUDITEE$4,580,604 federal awards expended

FAC accepted this audit on July 9, 2017 — management decision was due January 9, 2018.

2016-001
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2015-001OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-001

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2016-002
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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