EIN: 521622336
UEI: GL8EKK2U5YE9
Audited by: Vasquez and Company, LLP
Oversight agency: 47 [National Science Foundation]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2026 (33 days from today).
What is a management decision? →During our audit, we identified discrepancies related to federal expenditures for two Research and Development Cluster programs, specifically, CCF-1734706 and DUE-1821136, in the amounts of $67,165 and $37,886, respectively. These expenditures were incurred in FY 2023 but were only reported in the FY2024 SEFA. Cause: The reporting discrepancies occurred due to administrative delays in invoice processing and a lack of timely year-end accruals for subrecipient expenses. Specifically, one invoice amounting to $67,165 was held and not approved for processing until a required final report was received in December 2023, causing it to miss the FY23 accrual window. Additionally, the second invoice amounting to $37,886 was received by CRA accounting staff in a batch email containing a mix of both FY23 and FY24 expenses. This invoice was not properly identified for accrual to the prior fiscal period. Consequently, these expenses were incorrectly recorded in the year paid rather than the year the activity occurred. Effect: Because federal expenditures were reported in an incorrect fiscal year, the SEFA for FY2024 was considered overstated, while the FY2023 SEFA was understated. As a result, the SEFA did not accurately reflect federal expenditures for each fiscal year, which could affect the determination of major programs, the accuracy of audit coverage, and compliance with Uniform Guidance reporting requirements. Questioned Costs: None. Recommendation: We recommend CRA strengthen its internal controls over the review and reconciliation of grant-related expenditures and receipts to ensure accurate and timely reporting in the SEFA. This should include implementing procedures to verify the timing of expenditures prior to SEFA submission, reconciling SEFA amounts to the general ledger, and providing additional training to staff responsible for federal award reporting. Views of Responsible Officials and Planned Corrective Action: CRA management agrees with the finding and the recommendation to strengthen internal controls surrounding the timing of federal expenditure reporting to ensure compliance with 2 CFR 200.510(b). To ensure all federal expenditures are captured in the correct fiscal year, CRA will implement the following accrual and reconciliation procedure: - On June 30 of each year, the Senior Manager for Contracts and Grants Administration will generate an estimate of costs for the fiscal year for which subrecipient bills have not yet been received or entered into Bill.com. - As subrecipient bills are subsequently entered into Bill.com, the Senior Manager will send formal requests to PBMares to accrue those specific bills. These will be cross-referenced against the original June 30 estimates list to track outstanding items. - By approximately September 30, CRA will perform a final review and accrue any remaining expenses that were estimated as of June 30 for which bills have still not been entered into Bill.com, ensuring they are properly attributed to the prior fiscal year. Personnel Responsible for Implementation: Jacob Wolkenhauer Position of Responsible Personnel: Senior Manager for Contracts and Grants Administration Expected Date of Implementation: Immediately
Show full finding ▾Hide full finding ▴Federal Program Information: Federal Assistance Listing Number: 47.070, 47.076 Federal Program Name: Research and Development Cluster Federal Agency: National Science Foundation Federal Award Number: CCF-1734706; CNS-2231962; DUE-1821136 Federal Award Year: April 1, 2018 to March 31, 2024; August 1, 2022 to July 31, 2024; October 1, 2024 to September 30, 2024 Criteria: Per 2 CFR 200.510(b), Financial Statements: Schedule of Expenditures of Federal Awards (SEFA), the SEFA must include the total federal awards expended, as determined in accordance with 2 CFR 200.502, Basis for Determining Federal Awards Expended, and must align with the same reporting period as the auditee's financial statements. 2 CFR 200.502(a) specifies that the timing of when a federal award is expended is based on the occurrence of the activity related to the award. Identified Condition: During our audit, we identified discrepancies related to federal expenditures for two Research and Development Cluster programs, specifically, CCF-1734706 and DUE-1821136, in the amounts of $67,165 and $37,886, respectively. These expenditures were incurred in FY 2023 but were only reported in the FY2024 SEFA. Cause: The reporting discrepancies occurred due to administrative delays in invoice processing and a lack of timely year-end accruals for subrecipient expenses. Specifically, one invoice amounting to $67,165 was held and not approved for processing until a required final report was received in December 2023, causing it to miss the FY23 accrual window. Additionally, the second invoice amounting to $37,886 was received by CRA accounting staff in a batch email containing a mix of both FY23 and FY24 expenses. This invoice was not properly identified for accrual to the prior fiscal period. Consequently, these expenses were incorrectly recorded in the year paid rather than the year the activity occurred. Effect: Because federal expenditures were reported in an incorrect fiscal year, the SEFA for FY2024 was considered overstated, while the FY2023 SEFA was understated. As a result, the SEFA did not accurately reflect federal expenditures for each fiscal year, which could affect the determination of major programs, the accuracy of audit coverage, and compliance with Uniform Guidance reporting requirements. Questioned Costs: None. Recommendation: We recommend CRA strengthen its internal controls over the review and reconciliation of grant-related expenditures and receipts to ensure accurate and timely reporting in the SEFA. This should include implementing procedures to verify the timing of expenditures prior to SEFA submission, reconciling SEFA amounts to the general ledger, and providing additional training to staff responsible for federal award reporting. Views of Responsible Officials and Planned Corrective Action: CRA management agrees with the finding and the recommendation to strengthen internal controls surrounding the timing of federal expenditure reporting to ensure compliance with 2 CFR 200.510(b). To ensure all federal expenditures are captured in the correct fiscal year, CRA will implement the following accrual and reconciliation procedure: - On June 30 of each year, the Senior Manager for Contracts and Grants Administration will generate an estimate of costs for the fiscal year for which subrecipient bills have not yet been received or entered into Bill.com. - As subrecipient bills are subsequently entered into Bill.com, the Senior Manager will send formal requests to PBMares to accrue those specific bills. These will be cross-referenced against the original June 30 estimates list to track outstanding items. - By approximately September 30, CRA will perform a final review and accrue any remaining expenses that were estimated as of June 30 for which bills have still not been entered into Bill.com, ensuring they are properly attributed to the prior fiscal year. Personnel Responsible for Implementation: Jacob Wolkenhauer Position of Responsible Personnel: Senior Manager for Contracts and Grants Administration Expected Date of Implementation: Immediately
Planned Corrective Action: CRA management agrees with the finding and will implement a formal accrual and reconciliation procedure to ensure all federal expenditures are captured in the correct fiscal year. The process will include: o Annual Cost Estimation: On June 30 of each year, the Senior Manager for Contracts and Grants Administration will generate an estimate of costs for subrecipient bills not yet received or entered into the system. o Active Accrual Tracking: As bills are entered into Bill.com, they will be cross-referenced against the June 30 estimates, and formal requests will be sent to PBMares to accrue these specific expenses. o Final Review: By approximately September 30, a final review will be conducted to accrue any remaining estimated expenses, ensuring they are properly attributed to the prior fiscal year. Responsible Personnel: Jacob Wolkenhauer, Senior Manager for Contracts and Grants Administration. Anticipated Completion Date: Immediate.
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
FAC accepted this audit on July 16, 2024 — management decision was due January 16, 2025.
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
The cost principals in 2 CFR Part 200, Subpart E states costs must meet the general criteria in order to be allowable under federal awards including that they must be determined in accordance with generally accepted accounting principles. Criteria: CRA is required to record their federal expenditures in accordance with generally accepted accounting principles. Cause: CRA did not perform a thorough review over the cut off of revenue and expenses to ensure they were recorded in the correct fiscal year when incurred. Context: Cherry Bekaert noted multiple instances where accrued expenses and expenses incurred in a period other than fiscal year 2021 were recorded in fiscal year 2021. Each of the errors noted below impacted either federal expenditures or federal grant revenue. Due to the prevalent nature of the errors noted, Cherry Bekaert considered the overarching control deficiency to be a material weakness, despite the dollar value of the errors. ? During our testing performed over the compliance requirements for activities allowed or unallowed and allowable costs/cost principles, we found multiple instances where expenses incurred in fiscal year 2020 or fiscal year 2022 were recorded in fiscal year 2021 erroneously. Known error of $9,599.70 of expenses recorded in fiscal year 2021 related to services performed in fiscal year 2020, with likely questioned costs of $59,944. Known error of $1,637.64 related to expenses paid in fiscal year 2021 but related to services performed in fiscal year 2022, with likely questioned costs of $10,226. During our testing performed over accrued expenses, we found multiple instances where expenses paid to subrecipients incurred in fiscal year 2022 were recorded in fiscal year 2021 erroneously. Known error of $35,613 of expenses recorded in fiscal year 2021 related to services performed in fiscal year 2022, with likely questioned costs of $100,346. Effect: Expenses are not being recorded in accordance with generally accepted accounting principles. Due to the prevalent nature of the errors noted, Cherry Bekaert considered the overarching control deficiency to be a material weakness, despite the dollar value of the errors. Recommendation: We recommend a formal policy be established, and adhered to, to ensure all expenses and receipts that are obtained subsequent to year-end are carefully reviewed to determine the period of performance and accrued as needed. Management response: CRA concurs with this finding.
Show full finding ▾Hide full finding ▴Finding: Material Weakness: 2021-001 ? National Science Foundation programs, Research and Development Cluster, Assistance Listing # 47.070. Compliance Requirement: Allowable Costs/Cost Principles Condition: The cost principals in 2 CFR Part 200, Subpart E states costs must meet the general criteria in order to be allowable under federal awards including that they must be determined in accordance with generally accepted accounting principles. Criteria: CRA is required to record their federal expenditures in accordance with generally accepted accounting principles. Cause: CRA did not perform a thorough review over the cut off of revenue and expenses to ensure they were recorded in the correct fiscal year when incurred. Context: Cherry Bekaert noted multiple instances where accrued expenses and expenses incurred in a period other than fiscal year 2021 were recorded in fiscal year 2021. Each of the errors noted below impacted either federal expenditures or federal grant revenue. Due to the prevalent nature of the errors noted, Cherry Bekaert considered the overarching control deficiency to be a material weakness, despite the dollar value of the errors. ? During our testing performed over the compliance requirements for activities allowed or unallowed and allowable costs/cost principles, we found multiple instances where expenses incurred in fiscal year 2020 or fiscal year 2022 were recorded in fiscal year 2021 erroneously. Known error of $9,599.70 of expenses recorded in fiscal year 2021 related to services performed in fiscal year 2020, with likely questioned costs of $59,944. Known error of $1,637.64 related to expenses paid in fiscal year 2021 but related to services performed in fiscal year 2022, with likely questioned costs of $10,226. During our testing performed over accrued expenses, we found multiple instances where expenses paid to subrecipients incurred in fiscal year 2022 were recorded in fiscal year 2021 erroneously. Known error of $35,613 of expenses recorded in fiscal year 2021 related to services performed in fiscal year 2022, with likely questioned costs of $100,346. Effect: Expenses are not being recorded in accordance with generally accepted accounting principles. Due to the prevalent nature of the errors noted, Cherry Bekaert considered the overarching control deficiency to be a material weakness, despite the dollar value of the errors. Recommendation: We recommend a formal policy be established, and adhered to, to ensure all expenses and receipts that are obtained subsequent to year-end are carefully reviewed to determine the period of performance and accrued as needed. Management response: CRA concurs with this finding.
CRA receives many grant-reimbursable invoices after year end that need to be accrued back to the previous fiscal year. The invoices noted covered a multi-month time period that crossed fiscal year-end. The errors noted were the result of incorrectly accruing the full amount on invoices that covered both fiscal year 2021 and fiscal year 2022. Since the errors in accrued expenses included grant-reimbursable costs, the accrued grant revenue entries were also impacted. CRA is working with its outsourced accounting provider to establish a more detailed review process over invoices received after year-end.
During our testing performed over the compliance requirements for activities allowed or unallowed and allowable costs/cost principles, we noted one instance where a charge card transaction was in excess of $20,000 and was not approved by the Treasurer, in accordance with CRA?s policy. Criteria: Grantees should follow approval procedures indicated in their Accounting Manual. This ensures there is a review over whether the charge card expenditure is an allowable expense. Cause: CRA did not adhere to their approval procedures indicated in their Accounting Manual. Context: Cherry Bekaert found a charge card expense with a known amount of $77,071 that was not approved by James Allen, Treasurer. This accounts for the entire population; no likely questioned costs calculated. CRA had attempted to correct this approval path in their system in the prior year; however, the workflow had not been set up properly. Alternative approvals were set up; therefore, there were no disruptions in the approval process to signify that the Treasurer?s approval was set up incorrectly. Effect: A system error in the approval path of expenses resulted in a missing approval from the Treasurer for an expense in excess of $20,000. Recommendation: CRA should test the approval workflow to ensure the Treasurer approves all expenses above the $20,000 threshold. Management response: CRA concurs with this finding. Corrective Action Plan: See attached management?s corrective action Plan.
Show full finding ▾Hide full finding ▴Finding: Significant Deficiency: 2021-002 ? National Science Foundation programs, Research and Development Cluster, Assistance Listing # 47.070. Compliance Requirement: Activities Allowed or Unallowed Condition: During our testing performed over the compliance requirements for activities allowed or unallowed and allowable costs/cost principles, we noted one instance where a charge card transaction was in excess of $20,000 and was not approved by the Treasurer, in accordance with CRA?s policy. Criteria: Grantees should follow approval procedures indicated in their Accounting Manual. This ensures there is a review over whether the charge card expenditure is an allowable expense. Cause: CRA did not adhere to their approval procedures indicated in their Accounting Manual. Context: Cherry Bekaert found a charge card expense with a known amount of $77,071 that was not approved by James Allen, Treasurer. This accounts for the entire population; no likely questioned costs calculated. CRA had attempted to correct this approval path in their system in the prior year; however, the workflow had not been set up properly. Alternative approvals were set up; therefore, there were no disruptions in the approval process to signify that the Treasurer?s approval was set up incorrectly. Effect: A system error in the approval path of expenses resulted in a missing approval from the Treasurer for an expense in excess of $20,000. Recommendation: CRA should test the approval workflow to ensure the Treasurer approves all expenses above the $20,000 threshold. Management response: CRA concurs with this finding. Corrective Action Plan: See attached management?s corrective action Plan.
CRA has validated the approval path for charge card expenses and confirmed that expenses over $20,000 are now correctly directed to the Board Treasurer (currently James Allan) for approval.
FAC accepted this audit on March 21, 2021 — management decision was due September 21, 2021.
FAC accepted this audit on February 6, 2020 — management decision was due August 6, 2020.
FAC accepted this audit on March 5, 2019 — management decision was due September 5, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on March 19, 2018 — management decision was due September 19, 2018.
FAC accepted this audit on March 23, 2017 — management decision was due September 23, 2017.
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