EIN: 521338072
UEI: D1CRFN89NF71
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 26, 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 26, 2026 (93 days from today).
What is a management decision? →We noted that while the Foundation does conduct screenings on all vendors, suppliers and consultants, the date that the screening is conducted is not documented. As such, we are unable to determine if the screening was conducted prior to payment or signing of the contract. Cause: The Foundation does not require that the date the screening is conducted be documented. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or contract signing increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted as this compliance requirement is an administrative reporting requirement that does not impact cost eligibility. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding: Refer to Finding 2024-004. Recommendation: We recommend that the Foundation revise their policy regarding suspension and debarment to require that all screenings are accompanied by the documented date on which they were conducted.
Show full finding ▾Hide full finding ▴Finding 2025-004: Non-Compliance with Suspension and Debarment (Significant Deficiency) Federal Agency: National Institute of Health Federal Program: All of Us Research Program Assistance Listing Number: 93.368 Criteria: 2 CFR §200.213 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 with, is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: We noted that while the Foundation does conduct screenings on all vendors, suppliers and consultants, the date that the screening is conducted is not documented. As such, we are unable to determine if the screening was conducted prior to payment or signing of the contract. Cause: The Foundation does not require that the date the screening is conducted be documented. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or contract signing increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted as this compliance requirement is an administrative reporting requirement that does not impact cost eligibility. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding: Refer to Finding 2024-004. Recommendation: We recommend that the Foundation revise their policy regarding suspension and debarment to require that all screenings are accompanied by the documented date on which they were conducted.
Views of Responsible Officials: Each screening is uploaded with the first payment request to any vendor, supplier, or consultant. The Foundation will retroactively document the date the screening was conducted, the date the screening was reviewed, as well as the name of the person performing the review of the screening for all vendors, suppliers, or consultants that were paid during FY26. Going forward, the date the screening was performed, along with the person reviewing the screening and the date of that review, will be documented. The Foundation performs new screenings annually for all vendors, suppliers and consultants at the beginning of the fiscal year.
2024-004
We noted one instance in which there was no documented approval date of a report, and one instance in which the submission of a report was not timely in accordance with the award agreement. Cause: The Foundation does not have the appropriate internal controls in place to ensure that all internal reviews over reports are documented with a date of review. In addition, the Foundation is lacking internal controls to ensure that all reports are submitted timely in line with award agreement requirements. Effect or Potential Effect: Without proper dating of internal review and approval over reports, there exists the possibility that the review was not done prior to submission and information reported is inaccurate. Untimely submission of reports could result in withholding of funding. Questioned Costs: None noted as this compliance requirement is an administrative reporting requirement that does not impact cost eligibility. Context: Our audit procedures consisted of testwork performed over a sample of reports required to be submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Identification as a Repeat Finding: Refer to finding 2024-005. Recommendation: We recommend that the Foundation ensure that all approvals over performance and financial reporting are documented along with the date of review. In addition, we recommend the Foundation implement procedures to ensure that all reports are submitted within the specific timeframes specified in award agreements.
Show full finding ▾Hide full finding ▴Finding 2025-005: Reporting (Significant Deficiency) Federal Agency: National Institute of Health Federal Program: All of Us Research Program Assistance Listing Number: 93.368 Criteria: As noted in 2 CFR §200.303 "The non-Federal entity 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 the 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 the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: We noted one instance in which there was no documented approval date of a report, and one instance in which the submission of a report was not timely in accordance with the award agreement. Cause: The Foundation does not have the appropriate internal controls in place to ensure that all internal reviews over reports are documented with a date of review. In addition, the Foundation is lacking internal controls to ensure that all reports are submitted timely in line with award agreement requirements. Effect or Potential Effect: Without proper dating of internal review and approval over reports, there exists the possibility that the review was not done prior to submission and information reported is inaccurate. Untimely submission of reports could result in withholding of funding. Questioned Costs: None noted as this compliance requirement is an administrative reporting requirement that does not impact cost eligibility. Context: Our audit procedures consisted of testwork performed over a sample of reports required to be submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Identification as a Repeat Finding: Refer to finding 2024-005. Recommendation: We recommend that the Foundation ensure that all approvals over performance and financial reporting are documented along with the date of review. In addition, we recommend the Foundation implement procedures to ensure that all reports are submitted within the specific timeframes specified in award agreements.
Views of Responsible Officials: In March 2026, the Foundation hired a staff accountant that replaced a role that was previously held by a consultant. The Foundation's Board President, in the absence of the vacant Executive Director position, is approving the reports. The reports are being submitted on a timely basis.
2024-005
We noted that while the Foundation does keep timesheets, we noted several instances in which the timesheets lacked evidence of supervisory approval. In addition, we noted several instances in which the timesheet was not dated when approved. In addition, we noted several instances in which an employee's timesheet was not available for examination. Cause: The Foundation does not document their review and approval process consistently over timesheets. In addition, the Foundation does not ensure adequate retention of timesheets or ensure that timesheets are properly completed for all employees. Effect or Potential Effect: Without the proper, documented, approval processes in place over timesheets, there exists the potential for allocation errors. Questioned Costs: Undetermined, as the allocations are based on employee timesheets, but it is undeterminable if those timesheets were truly accurate due to the lack of consistent, documented approval over the timesheets by a supervisor. Context: Our audit procedures consisted of testwork performed over a sample of timesheets submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation ensure that all approvals over timesheets are clearly documented and dated.
Show full finding ▾Hide full finding ▴Finding 2025-006: Timekeeping and Payroll Allocations (Material Weakness) Federal Agency: National Institute of Health Federal Program: All of Us Research Program Assistance Listing Number: 93.368 Criteria: According to 2 CFR Section 200.430(i) 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; ii. Be incorporated into the official records of the non-Federal entity; iii. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; iv. Encompass Federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; v. Comply with the established accounting policies and practices of the non-Federal entity; 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. viii. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition: We noted that while the Foundation does keep timesheets, we noted several instances in which the timesheets lacked evidence of supervisory approval. In addition, we noted several instances in which the timesheet was not dated when approved. In addition, we noted several instances in which an employee's timesheet was not available for examination. Cause: The Foundation does not document their review and approval process consistently over timesheets. In addition, the Foundation does not ensure adequate retention of timesheets or ensure that timesheets are properly completed for all employees. Effect or Potential Effect: Without the proper, documented, approval processes in place over timesheets, there exists the potential for allocation errors. Questioned Costs: Undetermined, as the allocations are based on employee timesheets, but it is undeterminable if those timesheets were truly accurate due to the lack of consistent, documented approval over the timesheets by a supervisor. Context: Our audit procedures consisted of testwork performed over a sample of timesheets submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation ensure that all approvals over timesheets are clearly documented and dated.
Views of Responsible Officials: All the Foundation's employees now complete an excel timesheet that is then submitted to their supervisor for review and approval. Payroll is processed only after all employee timesheets are approved and received by the Senior Accountant who processes payroll.
2024-006
During our testing performed over subrecipient expenditures, we were unable to obtain evidence that pre-award risk assessment procedures were performed over subrecipients, consistent with 2 CFR §200.332(b). As such, the Foundation did not adequately determine appropriate monitoring procedures over the sub-recipients. Cause: The Foundation does not have established internal controls or policies regarding subrecipients. Effect or Potential Effect: The Organization could inadvertently be engaged in relationships with subrecipients of higher risk without the appropriate level of oversight to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Questioned Costs: None noted as this compliance requirement is a administrative reporting requirement that does not impact cost eligibility. Context: Our audit procedures consisted of substantive testwork over a sample of subrecipients. We consider our sample to be representative of the population. The samples were made using statistical sampling and we believe the condition appeared to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend the Foundation formalize internal control procedures and policies with respect to sub-recipient pre-award risk assessment. The risk assessments should be conducted in order to establish appropriate monitoring procedures.
Show full finding ▾Hide full finding ▴Finding 2025-007: Pre-Award Risk Assessment for Sub-Recipient (Significant Deficiency) Federal Agency: National Institute of Health Federal Program: All of Us Research Program Assistance Listing Number: 93.368 Criteria: As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures to prescribe to each individual subrecipient. Condition: During our testing performed over subrecipient expenditures, we were unable to obtain evidence that pre-award risk assessment procedures were performed over subrecipients, consistent with 2 CFR §200.332(b). As such, the Foundation did not adequately determine appropriate monitoring procedures over the sub-recipients. Cause: The Foundation does not have established internal controls or policies regarding subrecipients. Effect or Potential Effect: The Organization could inadvertently be engaged in relationships with subrecipients of higher risk without the appropriate level of oversight to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Questioned Costs: None noted as this compliance requirement is a administrative reporting requirement that does not impact cost eligibility. Context: Our audit procedures consisted of substantive testwork over a sample of subrecipients. We consider our sample to be representative of the population. The samples were made using statistical sampling and we believe the condition appeared to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend the Foundation formalize internal control procedures and policies with respect to sub-recipient pre-award risk assessment. The risk assessments should be conducted in order to establish appropriate monitoring procedures.
Views of Responsible Officials: The Foundation will retroactively perform a risk assessment of all subrecipients for FY26. Going forward, a pre-award risk assessment will be performed prior to awarding a subrecipient and appropriate monitoring procedures over sub-recipients will be implemented.
We identified three instances in which the Foundation did not submit a sub-recipient's FFATA report. Cause: The Foundation does not have internal policies or procedures outlining the FFATA requirements and management and staff within the Foundation were unaware of the requirement. Effect or Potential Effect: The Foundation was not in compliance with FFATA reporting requirements. Questioned Costs: None noted as this compliance requirement is a administrative reporting requirement that does not impact cost eligibility. Context: We performed statistical sampling procedures over the Foundation's sub-recipients required to be reported under FFATA. We consider this sample representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation establish internal policies and procedures with respect to FFATA requirements, clearly communicate FFATA reporting requirements to responsible staff, and conduct regular trainings to ensure that there is an understanding of requirements to be in compliance with FFATA.
Show full finding ▾Hide full finding ▴Finding 2025-008: Reporting for Federal Fund and Accountability Transparency Act (Significant Deficiency) Federal Agency: National Institute of Health Federal Program: All of Us Research Program Assistance Listing Number: 93.368 Criteria: 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 awardee awards any sub-award equal to or greater than $30,000 in Federal funds that does not include recovery funds. Condition: We identified three instances in which the Foundation did not submit a sub-recipient's FFATA report. Cause: The Foundation does not have internal policies or procedures outlining the FFATA requirements and management and staff within the Foundation were unaware of the requirement. Effect or Potential Effect: The Foundation was not in compliance with FFATA reporting requirements. Questioned Costs: None noted as this compliance requirement is a administrative reporting requirement that does not impact cost eligibility. Context: We performed statistical sampling procedures over the Foundation's sub-recipients required to be reported under FFATA. We consider this sample representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation establish internal policies and procedures with respect to FFATA requirements, clearly communicate FFATA reporting requirements to responsible staff, and conduct regular trainings to ensure that there is an understanding of requirements to be in compliance with FFATA.
Views of Responsible Officials: The Foundation will retroactively receive the FFATA reports for their sub-recipients, and going forward will ensure that the FFATA reports are received and submitted for all sub-recipients.
FAC accepted this audit on May 15, 2025 — management decision was due November 15, 2025.
We noted that while the Foundation does conduct screenings on all vendors, suppliers and consultants, the date that the screening is conducted is not documented. As such, we are unable to determine if the screening was conducted prior to payment or signing of the contract. Cause: The Foundation does not require that the date the screening is conducted be documented. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or contract signing increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation revise their policy regarding suspension and debarment to require that all screenings are accompanied by the documented date in which they were conducted.
Show full finding ▾Hide full finding ▴Finding 2024-004: Non-Compliance with Suspension and Debarment (Significant Deficiency) Information on the Federal Program: 93.368 Criteria: 2 CFR §200.213 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; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: We noted that while the Foundation does conduct screenings on all vendors, suppliers and consultants, the date that the screening is conducted is not documented. As such, we are unable to determine if the screening was conducted prior to payment or signing of the contract. Cause: The Foundation does not require that the date the screening is conducted be documented. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or contract signing increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation revise their policy regarding suspension and debarment to require that all screenings are accompanied by the documented date in which they were conducted.
Views of Responsible Officials: Working diligently with NIH team to put policies and procedures in place to conduct the proper screenings for vendors, suppliers and consultants.
We noted that while the Foundation does not have a formal review and approval process in place over performance and financial reports that is documented and available for examination. Cause: The Foundation does not document their review and approval process over performance and financial reports. Effect or Potential Effect: Without the proper approval processes in place over performance and financial reports, there exists the potential for reporting errors. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork performed over a sample of reports required to be submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation ensure that all approvals over performance and financial reporting are clearly documented and available for examination.
Show full finding ▾Hide full finding ▴Finding 2024-005: Reporting (Significant Deficiency) Information on the Federal Program: 93.368 Criteria: As noted in 2 CFR §200.303 "The non-Federal entity 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 the 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 the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: We noted that while the Foundation does not have a formal review and approval process in place over performance and financial reports that is documented and available for examination. Cause: The Foundation does not document their review and approval process over performance and financial reports. Effect or Potential Effect: Without the proper approval processes in place over performance and financial reports, there exists the potential for reporting errors. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork performed over a sample of reports required to be submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation ensure that all approvals over performance and financial reporting are clearly documented and available for examination.
Views of Responsible Officials: DREF is in the process of hiring a part-time CFO to review all financial reports.
We noted that while the Foundation does keep timesheets, we noted several instances in which the timesheets lacked evidence of supervisory approval. In addition, we noted several instances in which the timesheet was not dated when approved. Cause: The Foundation does not document their review and approval process consistently over timesheets. Effect or Potential Effect: Without the proper, documented, approval processes in place over timesheets, there exists the potential for allocation errors. Questioned Costs: Undetermined, as the allocations are based on employee timesheets, but it is undeterminable if those timesheets were truly accurate due to the lack of consistent, documented approval over the timesheets by a supervisor. Context: Our audit procedures consisted of testwork performed over a sample of timesheets submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation ensure that all approvals over timesheets are clearly documented and dated.
Show full finding ▾Hide full finding ▴Finding 2024-006: Timekeeping and Payroll Allocations (Significant Deficiency) Information on the Federal Program: 93.368 Criteria: According to 2 CFR Section 200.430(i) 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; ii. Be incorporated into the official records of the non-Federal entity; iii. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; iv. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; v. Comply with the established accounting policies and practices of the non-Federal entity; 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. viii. Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.” Condition: We noted that while the Foundation does keep timesheets, we noted several instances in which the timesheets lacked evidence of supervisory approval. In addition, we noted several instances in which the timesheet was not dated when approved. Cause: The Foundation does not document their review and approval process consistently over timesheets. Effect or Potential Effect: Without the proper, documented, approval processes in place over timesheets, there exists the potential for allocation errors. Questioned Costs: Undetermined, as the allocations are based on employee timesheets, but it is undeterminable if those timesheets were truly accurate due to the lack of consistent, documented approval over the timesheets by a supervisor. Context: Our audit procedures consisted of testwork performed over a sample of timesheets submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation ensure that all approvals over timesheets are clearly documented and dated.
Views of Responsible Officials: Timesheets are now being submitted with every payroll to the proper supervisor for review and signatures.
During our audit, we noted that management was unable to prepare the Schedule of Expenditures of Federal Awards (SEFA) without assistance. In addition, we noted that formalized, documented internal control policies have not been established over various areas of Federal award management. Cause: The Foundation's controls are not adequately designed, and staff within the Foundation are not properly trained on Federal award management and reporting. Effect or Potential Effect: Without the proper controls in place, there exists the potential for reporting errors and the misappropriation of funds. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend the Foundation formalize internal control procedures over all compliance areas that are adequately communicated to staff. In addition, the Foundation should ensure all staff are properly trained on Federal award management and reporting.
Show full finding ▾Hide full finding ▴Finding 2024-007 Federal Award Management and Internal Controls (Material Weakness) Information on the Federal Program: 93.368 Criteria: As noted in 2 CFR §200.303 "The non-Federal entity 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 the 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 the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our audit, we noted that management was unable to prepare the Schedule of Expenditures of Federal Awards (SEFA) without assistance. In addition, we noted that formalized, documented internal control policies have not been established over various areas of Federal award management. Cause: The Foundation's controls are not adequately designed, and staff within the Foundation are not properly trained on Federal award management and reporting. Effect or Potential Effect: Without the proper controls in place, there exists the potential for reporting errors and the misappropriation of funds. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend the Foundation formalize internal control procedures over all compliance areas that are adequately communicated to staff. In addition, the Foundation should ensure all staff are properly trained on Federal award management and reporting.
Views of Responsible Officials: Currently in the process of working with the Federal Award Manager to create better internal controls and policies.
FAC accepted this audit on March 27, 2024 — management decision was due September 27, 2024.
In testing the Foundation's compliance with the period of performance availability for Federal awards, we noted one instance in which an invoice for an expense incurred outside of both the award's period of performance and the Foundation's fiscal year-end was recorded and charged to the Federal award. Cause: The Foundation's controls are not adequately designed to detect an expense recorded outside of the award's period of performance or outside of the Foundation's fiscal year-end. Effect: Costs that are not incurred and recorded within the period of performance may be determined and considered an unallowable charge against a Federally funded program. Questioned Costs: $55,000 Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards that ended within the 2023 fiscal year-end. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that all invoices be reviewed to ensure that expenses are appropriately recorded in the period for which they are incurred.
Show full finding ▾Hide full finding ▴Finding 2023-002: Period of Performance Information on the Federal Program: 93.368 Criteria: 2 CFR §200.309 non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in §200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Condition: In testing the Foundation's compliance with the period of performance availability for Federal awards, we noted one instance in which an invoice for an expense incurred outside of both the award's period of performance and the Foundation's fiscal year-end was recorded and charged to the Federal award. Cause: The Foundation's controls are not adequately designed to detect an expense recorded outside of the award's period of performance or outside of the Foundation's fiscal year-end. Effect: Costs that are not incurred and recorded within the period of performance may be determined and considered an unallowable charge against a Federally funded program. Questioned Costs: $55,000 Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards that ended within the 2023 fiscal year-end. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that all invoices be reviewed to ensure that expenses are appropriately recorded in the period for which they are incurred.
Views of Responsible Officials: Grant funds received pursuant to a period of performance or an approved drawdown or reimbursement request will be expended as specified in the request. When Federal grants are funded in advance, rather than on a reimbursement basis, the Foundation will minimize the time elapsing between the receipt of Federal grant funds and disbursement of such funds for their approved purpose. We will implement procedures to ensure that expenses are recorded or accrued properly.
We noted that while the Foundation does conduct screenings on all vendors, suppliers and consultants, the date that the screening is conducted is not documented. As such, we are unable to determine if the screening was conducted prior to payment or signing of the contract. Cause: The Foundation does not require that the date the screening is conducted be documented. Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or contract signing increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation revise their policy regarding suspension and debarment to require that all screenings are accompanied by the documented date in which they were conducted.
Show full finding ▾Hide full finding ▴Finding 2023-003: Non-Compliance with Suspension and Debarment Information on the Federal Program: 93.368 Criteria: 2 CFR §200.213 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; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: We noted that while the Foundation does conduct screenings on all vendors, suppliers and consultants, the date that the screening is conducted is not documented. As such, we are unable to determine if the screening was conducted prior to payment or signing of the contract. Cause: The Foundation does not require that the date the screening is conducted be documented. Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or contract signing increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation revise their policy regarding suspension and debarment to require that all screenings are accompanied by the documented date in which they were conducted.
Views of Responsible Officials: The Foundation will conduct screenings on all vendors, suppliers and consultants. The Foundation will also ensure that the screening date is documented prior to payment or signing of the contract.
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
We noted during our audit that the Foundation was unable to provide support to verify the submission dates of the reports selected for testing. The Foundation was also unable to provide evidence that the sampled reports were approved. Cause: Based on our discussions with management, reports are submitted to the grant officer by the Executive Director through email, and the email date is the evidence of the submission date and approval. Based on our understanding, there was a technical issue with the Executive Director's email during the year, and as a result, certain emails were lost or deleted and are unable to be located. As copies of these emails were not saved at the time they were sent, there is no way to obtain the email or validate compliance with the terms in the grant agreement. Effect: It is possible that the Foundation did not submit the required reports to the Grant Officer or the reports were not submitted in a timely manner. In both instances, non-compliance with the provisions in the award agreement could impact future funding. Questioned Costs: None Context: Our audit procedures consisted of testwork performed over a sample of reports required to be submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Recommendation: We recommend that all emails sent to the grant officer that contain monthly reports should be saved and filed at the time sent. This practice will ensure that documentation for all submission dates are readily available. Additionally, we recommend that the Foundation implement a formal approval policy over the reports to ensure that all reports go through a proper review prior to submission.
Show full finding ▾Hide full finding ▴Finding 2022-002: Reporting Information on the Federal Program: 93.368 Criteria: National Institutes of Health requires that the Foundation submit monthly financial and programmatic reports in accordance with the grant agreement. Reports are due within 30 days of the end of the reporting period. Condition: We noted during our audit that the Foundation was unable to provide support to verify the submission dates of the reports selected for testing. The Foundation was also unable to provide evidence that the sampled reports were approved. Cause: Based on our discussions with management, reports are submitted to the grant officer by the Executive Director through email, and the email date is the evidence of the submission date and approval. Based on our understanding, there was a technical issue with the Executive Director's email during the year, and as a result, certain emails were lost or deleted and are unable to be located. As copies of these emails were not saved at the time they were sent, there is no way to obtain the email or validate compliance with the terms in the grant agreement. Effect: It is possible that the Foundation did not submit the required reports to the Grant Officer or the reports were not submitted in a timely manner. In both instances, non-compliance with the provisions in the award agreement could impact future funding. Questioned Costs: None Context: Our audit procedures consisted of testwork performed over a sample of reports required to be submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Recommendation: We recommend that all emails sent to the grant officer that contain monthly reports should be saved and filed at the time sent. This practice will ensure that documentation for all submission dates are readily available. Additionally, we recommend that the Foundation implement a formal approval policy over the reports to ensure that all reports go through a proper review prior to submission.
Views of Responsible Officials: NIH Technical and Financial performance sections of the monthly NIH report are submitted monthly via email at different times of the month. The Technical Performance section of the report is submitted on the last day of the reporting month and the Financial Performance section of the report is submitted no later than 10 business days after the reporting month. The later submission of financial information allows for the closing of the month-end financial records. The Foundation submitted all of the 2021-2022 monthly reports within the NIH due date timeframes. Copies of the email submissions for three out of the twelve reports could not be located. The Foundation was not aware that copies of the report submission emails needed to be saved and maintained for audit purposes. NIH has not required that proof of the report submissions be retained and/or filed for audit purposes. The Foundation will download and file the report submission email for future reference. The Foundation's All of Us monthly reports are assembled by the Program Assistant and the Financial Consultant. The Principal Investigator is responsible for reviewing, finalizing and submitting the final reports. In the future the final reports will be signed as evidence of the approval of the information submitted.
We noted that time tracking was only required for employees charging time to federal awards. Additionally, the time tracking only included time spent by the employee on Federal activities, and not non-Federal activities. Timesheets should be required for all staff and should include time spent on both non-Federal and Federal activities in order to be in compliance with the Uniform Guidance. Additionally, we noted that timesheets lacked evidence of employee attestation. All timesheets should include employee signature to verify accuracy of time reported. Cause: Policies in place at the Foundation over time tracking only require that time spent on the Federal-activities be tracked. Policies also do not require employee signature on the timesheets prior to submission. Effect: It is possible that time charged to the Federal activities is not accurate as the allocation is not based on true time spent on activities as a whole, including both Federal and non-Federal. Questioned Costs: Unknown Context: Our audit procedures consisted of testwork completed on individual employee timesheets for certain pay periods. We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: 2021-002. Recommendation: Timesheets should be required for all staff and should also include time spent on both Federal and non-Federal activities in order to be in compliance with Uniform Guidance Cost Principals. Additionally, all timesheets should include employee signature to verify accuracy of time reported.
Show full finding ▾Hide full finding ▴Finding 2022-003: Time Tracking and Reporting Information on the Federal Program: 93.368 Criteria: CFR 200.430 indicates that the allocation of salaries for employees must be consistently applied to both Federal and Non-Federal activities. Condition: We noted that time tracking was only required for employees charging time to federal awards. Additionally, the time tracking only included time spent by the employee on Federal activities, and not non-Federal activities. Timesheets should be required for all staff and should include time spent on both non-Federal and Federal activities in order to be in compliance with the Uniform Guidance. Additionally, we noted that timesheets lacked evidence of employee attestation. All timesheets should include employee signature to verify accuracy of time reported. Cause: Policies in place at the Foundation over time tracking only require that time spent on the Federal-activities be tracked. Policies also do not require employee signature on the timesheets prior to submission. Effect: It is possible that time charged to the Federal activities is not accurate as the allocation is not based on true time spent on activities as a whole, including both Federal and non-Federal. Questioned Costs: Unknown Context: Our audit procedures consisted of testwork completed on individual employee timesheets for certain pay periods. We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: 2021-002. Recommendation: Timesheets should be required for all staff and should also include time spent on both Federal and non-Federal activities in order to be in compliance with Uniform Guidance Cost Principals. Additionally, all timesheets should include employee signature to verify accuracy of time reported.
Views of Responsible Officials: As of March 2023, we have implemented timesheet and work tracking for all employees and contractors receiving compensation from the Foundation. The timesheets have been enhanced to show the task completed. Each timesheet is reviewed, signed and dated by the Executive Director.
2021-002
FAC accepted this audit on April 26, 2022 — management decision was due October 26, 2022.
The Foundation allocated time to Federal awards based on budgeted percentages instead of actual time spent. Cause: The Foundation does not require that timesheets be completed based on actual time spent, and instead, timesheets are completed based on the budgeted percentages established for each employee. Effect: The Foundation could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None. Context: Our audit procedures consisted of testwork performed over the restricted income analysis. We consider our testwork to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that the Foundation revise their current time tracking policies to require that all timesheets be completed on a basis of actual time spent. If adjustments are required, these should be completed on a monthly or quarterly basis. All timesheets should have evidence of supervisory approval.
Show full finding ▾Hide full finding ▴Finding 2021-002: Time Tracking and Reporting Information on the Federal Program: 93.368 Criteria: Under 2 CFR 200.430 all charges to Federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: The Foundation allocated time to Federal awards based on budgeted percentages instead of actual time spent. Cause: The Foundation does not require that timesheets be completed based on actual time spent, and instead, timesheets are completed based on the budgeted percentages established for each employee. Effect: The Foundation could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None. Context: Our audit procedures consisted of testwork performed over the restricted income analysis. We consider our testwork to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that the Foundation revise their current time tracking policies to require that all timesheets be completed on a basis of actual time spent. If adjustments are required, these should be completed on a monthly or quarterly basis. All timesheets should have evidence of supervisory approval.
Views of Responsible Officials: The Foundation is currently using the timesheet tracking application provided by ADP Payroll Processing System. The system captures total time accumulated by employee per department and function. We understand that a more detail time tracking system is required that captures time expended by detailed tasks. The Foundation began tracking employee time at the task level, using excel, for employees working on the federal grant immediately when we were notified of the requirement. This information is being used to substantiate work charged to the federal grant. We will implement the a broader task level tracking system for all employees.
We noted multiple instances of incomplete or missing supporting documentation to support certain expense transactions. Cause: The Foundation had significant turnover in the accounting department, which resulted in the Foundation not following internal policies and procedures over expenses. Effect: Without periodic training and consistent application of the Foundation's internal policies and procedures, this could potentially result in material noncompliance and misappropriation of funds. Questioned Costs: None noted as there was other contemporaneous documentation to support the transactions. Context: Our audit procedures consisted of internal control testwork over the cash disbursements cycle over a sample population of expenditures using a statistical sample. We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding Recommendation: In order to provide a clear audit trail and substantiate the proper recording of expense transactions, we recommend that the Foundation retain copies of all invoices, payment information and approvals within an organized filing system so that the supporting documentation is able to be located in a timely manner.
Show full finding ▾Hide full finding ▴Finding 2021-003: Supporting Documentation Information on the Federal Program: 93.368 Criteria: As noted in 2 CFR ?200.303 "The non-Federal entity 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 the 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 the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: We noted multiple instances of incomplete or missing supporting documentation to support certain expense transactions. Cause: The Foundation had significant turnover in the accounting department, which resulted in the Foundation not following internal policies and procedures over expenses. Effect: Without periodic training and consistent application of the Foundation's internal policies and procedures, this could potentially result in material noncompliance and misappropriation of funds. Questioned Costs: None noted as there was other contemporaneous documentation to support the transactions. Context: Our audit procedures consisted of internal control testwork over the cash disbursements cycle over a sample population of expenditures using a statistical sample. We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding Recommendation: In order to provide a clear audit trail and substantiate the proper recording of expense transactions, we recommend that the Foundation retain copies of all invoices, payment information and approvals within an organized filing system so that the supporting documentation is able to be located in a timely manner.
Views of Responsible Officials: The Foundation has been established an electronic filing system to store all documentation supporting financial transactions. An internal audit will be performed quarterly to ensure that all the documentation has been captured and maintained. In addition, the Foundation is currently using an electronic accounts payable system which captures and stores approved invoices which have been paid through that system.
The Foundation did not perform screenings on its potential or current vendors, suppliers, contractors or employees that were paid with Federal funds. Cause: The Foundation did not have a formal internal policy with respect to screening vendors, suppliers, contractors and employees in order to adhere to compliance over suspension and debarment. Effect: Failure to screen potential and current vendors, suppliers, contractors, subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that management develop and implement a formal policy on suspension and debarment. This policy should include a threshold, generally $25,000, for when vendors, suppliers, employees and sub-contractors/grantees should be screened. All screenings should be conducted prior to signing a contract or issuing payment. We recommend that the Foundation notify all employees of this policy and ensure that it is enforced during the upcoming fiscal year.
Show full finding ▾Hide full finding ▴Finding 2021-004: Non-Compliance with Suspension and Debarment Information on the Federal Program: 93.368 Criteria: Under 2 CFR ?200.213, 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; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: The Foundation did not perform screenings on its potential or current vendors, suppliers, contractors or employees that were paid with Federal funds. Cause: The Foundation did not have a formal internal policy with respect to screening vendors, suppliers, contractors and employees in order to adhere to compliance over suspension and debarment. Effect: Failure to screen potential and current vendors, suppliers, contractors, subrecipients, employees, fellows, etc. increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that management develop and implement a formal policy on suspension and debarment. This policy should include a threshold, generally $25,000, for when vendors, suppliers, employees and sub-contractors/grantees should be screened. All screenings should be conducted prior to signing a contract or issuing payment. We recommend that the Foundation notify all employees of this policy and ensure that it is enforced during the upcoming fiscal year.
Views of Responsible Officials: The Foundation was not aware of the federal requirement to verify that persons with whom we intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. All contractors working on the current federal grant has already been screened using the SAM system. The Foundation will implement a formal policy on suspension and debarment which will include the requirement to screen all vendors, suppliers, employees and sub-contractors/grantees. Procedures and processes will be implemented to screen individuals in accordance with the policy.
The Foundation did not perform and document adequate procurement procedures over qualifying purchases using Federal funds. Cause: The Foundation did not follow their established, internal procurement policy. Effect: Purchases of goods and services could be made above prevailing market rates if the prescribed procurement procedures are not adhered to, and thus, there lies the potential that the Foundation will not receive the best value for its purchases. The procurement process also allows for the evaluation of potential conflicts of interest with prospective vendors and contractors. 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: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that the Foundation revise their procurement policy to be in line with required standards. This policy should be communicated to all employees and enforced during the upcoming fiscal year. All procurement records for purchases in excess of the threshold should include the following at a minimum: (a) basis for the contractor/goods selected or (b) justification for lack of competition when quotes or competitive bids are not obtained. Additionally, the conclusion should be clearly documented and accompany the procurement documentation. We also believe that all long-standing contractual engagements should evidence occasional re-evaluation to ensure such relationships are free of conflicts.
Show full finding ▾Hide full finding ▴Finding 2021-005: Procurement Information on the Federal Program: 93.368 Criteria: Under 2 CFR 200.318, a recipient of U.S Government funds must use their own documented procurement procedures which reflect applicable Uniform Guidance requirements to procure goods and services in order to ensure that all purchases are conducted in a manner that provides full and open competition. Condition: The Foundation did not perform and document adequate procurement procedures over qualifying purchases using Federal funds. Cause: The Foundation did not follow their established, internal procurement policy. Effect: Purchases of goods and services could be made above prevailing market rates if the prescribed procurement procedures are not adhered to, and thus, there lies the potential that the Foundation will not receive the best value for its purchases. The procurement process also allows for the evaluation of potential conflicts of interest with prospective vendors and contractors. 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: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that the Foundation revise their procurement policy to be in line with required standards. This policy should be communicated to all employees and enforced during the upcoming fiscal year. All procurement records for purchases in excess of the threshold should include the following at a minimum: (a) basis for the contractor/goods selected or (b) justification for lack of competition when quotes or competitive bids are not obtained. Additionally, the conclusion should be clearly documented and accompany the procurement documentation. We also believe that all long-standing contractual engagements should evidence occasional re-evaluation to ensure such relationships are free of conflicts.
Views of Responsible Officials: The Foundation will revise its current procurement policy to be in line with required federal standards. The policy will be communicated to all employees and monitored to ensure enforcement. All procurement records for purchases in excess of the threshold will include the following at a minimum: (a) basis for the contractor/goods selected or (b) justification for lack of competition when quotes or competitive bids are not obtained. Additionally, procurement conclusions will be clearly documented and accompany the financial transaction package. Long-standing contractual engagements will be re-evaluated occasionally to ensure such relationships are free of conflicts.
The Foundation was unable to reconcile cash draw downs on a monthly basis to their supporting documentation and draw down schedule. Indirect rates were not charged and drawn down in a consistent manner. Additionally, there was no review or approval documented for the amounts that were drawn down from the Federal Government. Cause: The Foundation does not have formal policies and procedures in place regarding the cash draw/management process. Effect: The Foundation could inadvertently over-draw funds from the Federal Government that were not truly needed at the time. Similarly, the Foundation could potentially under-draw funds that they incurred during each period. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork performed over cash receipts and draw down requests from the Federal Government. Our samples were selected directly from the Foundation's internal draw down schedule and cash receipt ledger. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend the Foundation implement a formal approval process over the Federal cash draw process. All draws made should be appropriately supported with underlying documentation. The Foundation should keep a draw-down schedule that can be reconciled to the amount requested.
Show full finding ▾Hide full finding ▴Finding 2021-006: Cash Management and Draw Process Information on the Federal Program: 93.368 Criteria: Under 2 CFR 200.303, organizations that receive federal funding are required to ?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 the 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 the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Foundation was unable to reconcile cash draw downs on a monthly basis to their supporting documentation and draw down schedule. Indirect rates were not charged and drawn down in a consistent manner. Additionally, there was no review or approval documented for the amounts that were drawn down from the Federal Government. Cause: The Foundation does not have formal policies and procedures in place regarding the cash draw/management process. Effect: The Foundation could inadvertently over-draw funds from the Federal Government that were not truly needed at the time. Similarly, the Foundation could potentially under-draw funds that they incurred during each period. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork performed over cash receipts and draw down requests from the Federal Government. Our samples were selected directly from the Foundation's internal draw down schedule and cash receipt ledger. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend the Foundation implement a formal approval process over the Federal cash draw process. All draws made should be appropriately supported with underlying documentation. The Foundation should keep a draw-down schedule that can be reconciled to the amount requested.
Views of Responsible Officials: A process has been implemented to document the review and approval of each monthly drawdown. In conjunction with this process, the monthly drawdown amounts are supported and substantiated by the corresponding monthly financial activity report submitted to the federal agency. The Accountant submits this package to the Executive Director review and approval. Upon approval, the monthly drawdown amount is submitted for payment.
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