EIN: 521847976
UEI: CHCFR4VGR565
Audited by: GELMAN, ROSENBERG & FREEDMAN
Oversight agency: 17 [Department of Labor]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 25, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 25, 2026 (22 days from today).
What is a management decision? →During our audit, we noted that although the Coalition was able to provide general ledger detail supporting the amounts drawn down, there was no documentation evidencing review and approval of drawdown reimbursement requests prior to submission. Accordingly, we were unable to determine whether an independent review was performed to verify the accuracy and allowability of the amounts requested. Cause: This condition resulted from a transition in the controller position during the audit period, during which established procedures for documenting review and approval of drawdown reimbursement requests were not consistently followed. Effect or Potential Effect: The absence of documented review and approval increases the risk that unallowable or unsupported costs could be charged to the Federal program and that errors may not be identified and corrected in a timely manner. Questioned Costs: None. Context: 2 of 2 samples lacked documentation evidencing review and approval prior to submission. The sample is representative of the population. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that the Coalition formalize and consistently apply procedures requiring documented review and approval of all drawdown reimbursement requests prior to submission, and that such documentation be retained in accordance with Uniform Guidance record retention requirements.
Show full finding ▾Hide full finding ▴Finding 2025-001: Cash Management Federal Program: Building an Inclusive Workforce: Lifting Underrepresented Communities Assistance Listing Number: 17.289 Federal Agency: U.S. Department of Labor Federal Award Number(s): 24A60CP000157-01-04 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Uniform Guidance (2 CFR Part 200) requires non-Federal entities to establish and maintain effective internal controls over Federal awards that provide reasonable assurance that transactions are properly recorded, processed, and reported, and that compliance with Federal statutes, regulations, and the terms and conditions of the Federal award is achieved. This includes maintaining documentation evidencing the review and approval of drawdown reimbursement requests to ensure that only allowable costs are charged to the Federal program. Condition: During our audit, we noted that although the Coalition was able to provide general ledger detail supporting the amounts drawn down, there was no documentation evidencing review and approval of drawdown reimbursement requests prior to submission. Accordingly, we were unable to determine whether an independent review was performed to verify the accuracy and allowability of the amounts requested. Cause: This condition resulted from a transition in the controller position during the audit period, during which established procedures for documenting review and approval of drawdown reimbursement requests were not consistently followed. Effect or Potential Effect: The absence of documented review and approval increases the risk that unallowable or unsupported costs could be charged to the Federal program and that errors may not be identified and corrected in a timely manner. Questioned Costs: None. Context: 2 of 2 samples lacked documentation evidencing review and approval prior to submission. The sample is representative of the population. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that the Coalition formalize and consistently apply procedures requiring documented review and approval of all drawdown reimbursement requests prior to submission, and that such documentation be retained in accordance with Uniform Guidance record retention requirements.
Views of Responsible Official: Management notes that the Federal Payment Management System (PMS) automatically tracks when different users enter information such as submitting and certifying/approving draw-down amounts. During the time of the grant there were periods when only one staff member had access to PMS due to technical issues and delays in adding new users. To ensure there is back-up documentation of the approval workflow, we will institute a form to capture the individual signatures of the preparer and submitter of each draw down as additional evidence of multiple people connected to the process.
During the audit, we noted that one required report selected for testing was not submitted in accordance with the reporting deadline established in the terms and conditions of the Federal award. Cause: This condition resulted from management oversight related to monitoring and tracking report due dates. Effect or Potential Effect: The failure to submit required reports timely increases the risk of noncompliance with Federal reporting requirements and may result in delayed oversight by the Federal awarding agency, potential sanctions, or increased scrutiny in future monitoring or audits. Questioned Costs: None. Context: 1 of 2 financial reports were not submitted timely. The sample is representative of the population. Identification as a Repeat Finding, if Applicable: 2024-001 Recommendation: We recommend that the Coalition implement formal procedures to ensure timely submission of all required Federal reports. Such procedures may include the use of an automated tracking or calendar system to notify responsible personnel of upcoming reporting deadlines, as well as documented review and approval of reports prior to submission.
Show full finding ▾Hide full finding ▴Finding 2025-002: Reporting Federal Program: Building an Inclusive Workforce: Lifting Underrepresented Communities Assistance Listing Number: 17.289 Federal Agency: U.S. Department of Labor Federal Award Number(s): 24A60CP000157-01-04 Type of Finding: Significant Deficiency in Internal Control over Compliance and Non-compliance Criteria: In accordance with 2 CFR §200.303, non-Federal entities are required to establish and maintain effective internal control over Federal awards to provide reasonable assurance that the entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Such internal controls should be consistent with the Standards for Internal Control in the Federal Government or the COSO Internal Control—Integrated Framework, including controls designed to ensure timely submission of required reports. Additionally, 2 CFR §200.328(c) states that "the recipient or subrecipient must submit financial reports as required by the Federal award." Condition: During the audit, we noted that one required report selected for testing was not submitted in accordance with the reporting deadline established in the terms and conditions of the Federal award. Cause: This condition resulted from management oversight related to monitoring and tracking report due dates. Effect or Potential Effect: The failure to submit required reports timely increases the risk of noncompliance with Federal reporting requirements and may result in delayed oversight by the Federal awarding agency, potential sanctions, or increased scrutiny in future monitoring or audits. Questioned Costs: None. Context: 1 of 2 financial reports were not submitted timely. The sample is representative of the population. Identification as a Repeat Finding, if Applicable: 2024-001 Recommendation: We recommend that the Coalition implement formal procedures to ensure timely submission of all required Federal reports. Such procedures may include the use of an automated tracking or calendar system to notify responsible personnel of upcoming reporting deadlines, as well as documented review and approval of reports prior to submission.
Views of Responsible Official: Management agrees with the finding. Management will institute additional calendar alerts and accountability procedures to ensure reports are filed on time. Recognizing that technical issues, illness, and other unforeseen circumstances can arise, Management will institute a requirement that all late filings must be communicated to the Contract Monitor as soon as the delay is anticipated.
2024-001
During our audit, we noted that the Coalition did not file the required FFATA reports for subawards exceeding the $30,000 threshold within the required timeframe. Cause: This condition resulted from management oversight related to monitoring and tracking sub award amendments that exceed the FFATA reporting threshold. Effect or Potential Effect: Failure to comply with FFATA reporting requirements reduces transparency in the use of Federal funds and could potentially impact the Coalition's eligibility for future funding. Questioned Costs: None. Context: 1 out of 1 samples tested failed to comply with FFATA reporting requirements. The sample is representative of the population. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We continue to recommend that the Coalition establish and implement controls to ensure compliance with FFATA reporting requirements. This may include training staff responsible for grant compliance and performing periodic reviews to verify that all applicable subawards, including sub award amendments, are reported in FSRS in a timely manner.
Show full finding ▾Hide full finding ▴Finding 2025-003: FFATA Reporting Federal Program: Building an Inclusive Workforce: Lifting Underrepresented Communities Assistance Listing Number: 17.289 Federal Agency: U.S. Department of Labor Federal Award Number(s): 24A60CP000157-01-04 Type of Finding: Significant Deficiency in Internal Control over Compliance and Non-compliance Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires recipients of Federal awards who issue subawards of $30,000 or more to report subaward information in the FFATA Subaward Reporting System (FSRS). This reporting ensures transparency in the use of Federal funds. Condition: During our audit, we noted that the Coalition did not file the required FFATA reports for subawards exceeding the $30,000 threshold within the required timeframe. Cause: This condition resulted from management oversight related to monitoring and tracking sub award amendments that exceed the FFATA reporting threshold. Effect or Potential Effect: Failure to comply with FFATA reporting requirements reduces transparency in the use of Federal funds and could potentially impact the Coalition's eligibility for future funding. Questioned Costs: None. Context: 1 out of 1 samples tested failed to comply with FFATA reporting requirements. The sample is representative of the population. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We continue to recommend that the Coalition establish and implement controls to ensure compliance with FFATA reporting requirements. This may include training staff responsible for grant compliance and performing periodic reviews to verify that all applicable subawards, including sub award amendments, are reported in FSRS in a timely manner.
Views of Responsible Official: Management agrees with the finding. Management will develop an alert system for Program Directors to use in tracking their sub-awards and sub-contracted engagement values and related amendments. This system will create an alert when a contract value exceeds $30,000 prompting the Program Director to file, or work with appropriate staff to file the FFATA.
FAC accepted this audit on March 5, 2025 — management decision was due September 5, 2025.
During our audit, we noted that the Coalition did not file the required FFATA reports for subawards exceeding the $30,000 threshold within the required timeframe. Cause: Management indicated that the noncompliance occurred due to the lack of awareness of the FFATA reporting requirements. Effect: Failure to comply with FFATA reporting requirements reduces transparency in the use of Federal funds and could potentially impact the Coalition's eligibility for future funding. Questioned Costs: None Context: 1 out of 1 samples tested failed to comply with FFATA reporting requirements. Recommendation: We recommend that the Coalition establish and implement controls to ensure compliance with FFATA reporting requirements. This may include training staff responsible for grant compliance and performing periodic reviews to verify that all applicable subawards are reported in FSRS in a timely manner. During the audit, management filed the report upon identification of the issue.
Show full finding ▾Hide full finding ▴Finding 2024-001: Failure to Comply with FFATA Reporting Requirements Information on the Federal Program: Assistance Listing Number 17.289 Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires recipients of Federal awards who issue subawards of $30,000 or more to report subaward information in the FFATA Subaward Reporting System (FSRS). This reporting ensures transparency in the use of Federal funds. Condition: During our audit, we noted that the Coalition did not file the required FFATA reports for subawards exceeding the $30,000 threshold within the required timeframe. Cause: Management indicated that the noncompliance occurred due to the lack of awareness of the FFATA reporting requirements. Effect: Failure to comply with FFATA reporting requirements reduces transparency in the use of Federal funds and could potentially impact the Coalition's eligibility for future funding. Questioned Costs: None Context: 1 out of 1 samples tested failed to comply with FFATA reporting requirements. Recommendation: We recommend that the Coalition establish and implement controls to ensure compliance with FFATA reporting requirements. This may include training staff responsible for grant compliance and performing periodic reviews to verify that all applicable subawards are reported in FSRS in a timely manner. During the audit, management filed the report upon identification of the issue.
Views of Responsible Officials: Management agrees with the finding and has already filed the required FFATA report. Completion Date: 11/22/2024
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
FAC accepted this audit on March 2, 2023 — management decision was due September 2, 2023.
FAC accepted this audit on March 8, 2022 — management decision was due September 8, 2022.
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