EIN: 521999196
UEI: GVK8Z61DA3G1
Data as of August 19, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 27, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 27, 2025, which was (511 days ago).
What is a management decision? →Finding No. 2023-001: Reporting – Other Matter U.S. Department of Health and Human Services, Teenage Pregnancy Prevention Program, Assistance Listing Number 93.297 Criteria Under the Federal Funding Accountability and Transparency Act (FFATA), all entities receiving federal awards are required to report specific information about the federal funds they receive. Entities must report this information through the Federal Subaward Reporting System (FSRS) or other designated systems. Context The Organization has received multiple federal awards during the year and is subject to FFATA reporting. The noncompliance was identified through a review of the entity's records and evidence of proper submission due to a subrecipient’s lack of Unique Entity Identifier (UEI) number and the Organization’s inability to complete the submission of the FFATA reporting requirement. Cause The Organization’s subrecipient did not have the proper registration information to submit the information related to the FFATA reporting requirements. Effect The failure to report all required FFATA information diminishes the transparency of federal fund usage and prevents the public from having full access to information regarding the stewardship of taxpayer dollars. This noncompliance could potentially affect the Organization’s eligibility for future federal funding. Questioned Costs None Recommendation To ensure compliance with FFATA reporting requirements, we recommend that the Organization train relevant personnel on FFATA requirements and the use of the reporting systems. The Organization should also establish a monitoring system to verify that all subrecipients are evaluated for proper registration for the Organization to satisfy all necessary reporting requirements. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.
Views of Responsible Officials and Planned Corrective Actions: This condition was primarily the result of a subrecipient not having a verifiable Unique Entity Identifier (UEI) and/or registration in the Systems for Award Management (SAM.gov) registry. A UEI is a required field on the Federal Funding Accountability & Transparency Act Subaward Reporting System (FSRS) for FFATA reporting and this particular subrecipient’s lack of a UEI hindered the Organization from reporting on the subrecipients one-time subaward. Starting in July of 2024, before any subaward engagement or contracting occurs, all potential subrecipients will be required by the Organization to provide evidence of their UEIs and active registration on SAM.gov. Additionally, all program and compliance staff responsible for federally funded programs will be re-trained on federal FFATA reporting requirements. The Organization will also review its compliance monitoring system to ensure that potential subrecipient and contractors are registered in SAM.gov as well as meet basic requirements for federal procurement guidelines. Responsible Official: Peter Kiburi, Senior Director of Finance
Finding No. 2023-002: Procurement – Significant Deficiency in Internal Control Over Compliance U.S. Department of Health and Human Services, Teenage Pregnancy Prevention Program, Assistance Listing Number 93.297 Criteria Federal award recipients must comply with procurement standards as outlined in the Uniform Guidance which requires recipients to conduct procurements in a manner that provides full and open competition. Exceptions to this requirement, such as sole-source procurements, must be adequately justified and documented in accordance with federal regulations. Context The Organization received a federal award which included funding for specialized services. Certain vendors were chosen as the sole-source providers for these services. However, as an exception to the Organization’s procurement policy, there was no written justification as to why no other vendors were considered or how these vendors were uniquely qualified to meet the project’s needs. Upon inquiry of management, there was supported justification for the selection of these vendors which provided a reasonable basis, but there was nothing formally maintained to support this selection. Cause The finding suggests a gap in the Organization's procurement policies and procedures, which failed to ensure that proper documentation for sole-source justifications be retained. Effect The lack of adequate documentation for sole-source procurements raises concerns regarding the propriety of the procurement process and whether the organization obtained the best value for the federal funds expended. This deficiency could potentially result in questioned costs and might impact the Organization's eligibility for future federal funding. Questioned Costs None Recommendation We recommend that the Organization take the following actions to address this significant deficiency through review and reinforce training on federal procurement requirements for all staff involved in the procurement process: (1) Updating procurement policies and procedures to require documentation of sole-source justifications, including evidence of the unique qualifications of the vendor and the specific rationale for not considering other potential vendors; (2) Conducting a retrospective analysis of the procurement in question to determine if there were other qualified vendors that could have been considered; and (3) Developing and implementing a corrective action plan to ensure all future sole-source procurements are fully documented and comply with federal requirements. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.
Views of Responsible Officials and Planned Corrective Actions: This condition was primarily the result of a heavy reliance on external subject matter experts (SMEs) for technical aspects of programmatic workplan deliverables, as well as the use of single-sourcing selection carveouts in the interests of efficiency, that are provided for in the organization’s procurement policies & procedures. These instances of single sourcing nonetheless required additional levels of documentation and justification when in use, which was always not the case. Starting in August 2024, all program and compliance staff will be re-trained on federal procurement policy documentation and justification requirements. The Organization will also embark on concerted efforts to expand its pool of qualified and eligible SME vendors, to ensure more reliance on competitive bidding and minimize the future use single-source procurement. A comprehensive review of current Organizational policies and procedures will also be undertaken, to ensure that they are aligned and consistent with current federal procurement guidelines and requirements. Responsible Official: Peter Kiburi, Senior Director of Finance.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 29, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 29, 2023, which was (1240 days ago).
What is a management decision? →Finding No. 2021-001: Subrecipient Monitoring ? Material Weakness in Internal Control Over Compliance Criteria The Uniform Guidance requires federal award recipients to ensure that subawards are clearly identified as such to subrecipients and include the following relevant award information: ? Subrecipient name ? Subrecipient unique entity identifier ? Federal award identification number ? Award date to the recipient ? Subaward period of performance ? Subaward budget ? Funds obligated to the subrecipient with the current award and in total ? Federal award project description, name of federal awarding agency or pass-through entity and contact information for awarding official of the pass-through entity ? Assistance listing number and title ? Identification of whether the award is research and development ? Indirect cost rate, at the time of the subaward If any of these data elements change, the pass-through entity is required to communicate such to the subrecipients through subaward modifications. In the event that any of this information is not available, the pass-through entity must provide the best information available. The Uniform Guidance also requires that federal award recipients 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. Context Certain required information was not communicated to the subrecipients, including the assistance listing number and title. There was also a lack of documented risk assessment procedures over the subrecipient?s risk of noncompliance.Cause The cause of this finding is related to the awareness of the Organization?s explicit requirements around subrecipient monitoring activities. Specifically, the additional monitoring and communication requirements were not included within the Organization?s standard contractor or vendor agreements, which is what was used to communicate the requirements of the parties involved for the work to be completed on the award. Effect Omission or lack of information around the award information could lead to incomplete records at the subrecipient and a lack of risk assessment may result in insufficient supervision of subrecipient(s) necessary to satisfy the responsibilities prescribed from the standards. Questioned Costs None Recommendation We recommend that the Organization employ the use of a comprehensive subrecipient checklist to ensure that all required procedures are performed in order to comply with the prescribed requirements. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.
Views of Responsible Officials and Planned Corrective Actions: This condition was primarily the result of an award, in mid-2020, of a new and significant federal innovation award that came with an atypically large component of multidisciplinary network partners, sub awardees and consultants. While some obvious subrecipients were clearly identified and designated as such, based on subaward dollar threshold amounts, and their defined roles in the award work plan, and monitored accordingly, as required under 2 CFR section 200.331(a), other minor partners were not, because they were initially designated as contractors. Starting in July 2022, enhanced and mitigating controls were put in place that now required both responsible program management and compliance staff, to make concerted determinations on whether a partner/third party entity is a contractor or subawardee/subrecipient. All of the organization?s staff that are responsible for direct federal and/or pass-through awards were re-trained and oriented on making guided decisions on the test required for making a determination on whether a subrecipient or contractor relationship exists with a third-party entity that is receiving funding from the organization, as part of its federal award(s). The nuances and distinctions on whether an entity is being compensated for goods or services (contractor) or is receiving funds to support a federal program (sub-awardee), are now clearly documented and communicated throughout the programmatic and monitoring & compliance decision-making hierarchy within the organization. Additionally, starting in July of 2022, all subaward and subrecipient agreements entered into with third party entities are being revised and updated to incorporate, within the preamble and award notifications, the complete and pertinent 2 CFR section 200.332 Pass-through entity (PTE) federal award recipient information, as well as complete subrecipient entity information. Anticipated Completion Date: December 31, 2022 Responsible Official: Peter Kiburi, Director of Finance
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 19, 2021. 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 June 19, 2022, which was (1523 days ago).
What is a management decision? →Information on the Federal Programs: All Federal Programs Criteria: Title 2 CFR 200 Section 200.510 ?Financial Statements? requires recipients of Federal funds to (1) prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited, and (2) prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended. Additionally, in accordance with 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). Additionally, management is responsible for the preparation and fair presentation of the consolidated financial statements in accordance with accounting principles generally accepted in the United States of America; this includes the design, implementation and maintenance of internal control relevant to the preparation and fair presentation of consolidated financial statements that are free from material misstatement, whether due to fraud or error. Condition: During our audit, we noted that approval of timesheets was obtained through the electronic timesheet system implemented in July 2020, and documentation of review and approval of reconciliations for the year end audit as well as for the submitted Federal Financial Reports was provided for the later part of the year. However, we noted 3 instances where employee timesheets did not agree to the provided payroll allocation report or management could not provide payroll allocations reports for the time period tested. Cause: Over the past several years, the finance department has had significant turnover. The current Director of Finance began in early 2019, and a staff was added to the department mid-year. As a result of the changes in the department, additional funding and projects being secured, the finance department had difficulty in completing accurate reconciliations, following up on enforcement of certain controls, such as timesheet approval, agreeing payroll allocations to the general ledger, and establishing a proper review and approval process. Effect: Not agreeing payroll allocations to employee timesheets and to the general ledger may cause a discrepancy of charges to federal grants. Questioned Costs: Undetermined. Context: 3 out of 40 employee timesheets did not agree to the provided payroll allocation report and could not be tied to the general ledger detail since management could not provide payroll allocations reports for the time period tested. Identification of a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend during the Organization's review process that careful attention be made to agreeing payroll allocation reports and employee timesheets to the general ledger to ensure that time allocations are accurate.
Views of Responsible Officials and Planned Corrective Actions: This condition was primarily the result of management?s inability to provide 3 pay period payroll allocation schedules, to support the payroll journal entries for 3 pay periods. Management did however make every diligent effort to ensure that other contemporaneous support documentation for those pay periods, such as posted payroll journal entries, employee time sheets and payroll service payroll reports were provided, that tied to the posted payroll expense and reconciled general ledger journal entries. In July 2020, other enhanced and mitigating controls were also put in place, such as the transition to online electronic time-keeping, labor-distribution tracking and approval procedures. Also, in mid-2020, electronic Accounts Payable and vendor payment processing and approvals was introduced through the Expensify? electronic payment processing system. DCPCA Accounting Policies & Procedures and employee user guides were also updated to incorporate these operational changes and organizationwide employee training was conducted. These two significant improvements in the Organization?s standard operating procedures have together strengthened internal controls around payroll processing, expense management and reporting. The changes have increased efficiencies and reduced previously arduous and error-prone back-end record keeping in the finance department. The Director of Finance will also make concerted efforts to ensure that original accounting source record allocation and other reconciliation schedules, that support periodic and year-end journal entries, are reviewed, updated, approved and saved and backed-up with enhanced regularity. Anticipated Completion Date: December 31, 2021 Responsible Official: Peter Kiburi, Director of Finance
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 27, 2020. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 27, 2021, which was (1972 days ago).
What is a management decision? →Finding 2019-001: Reconciliation of Asset and Liability Accounts / Review and Approval of Yearend Reconciled Schedules Information on the Federal Programs: All Federal Programs Criteria: Title 2 CFR 200 Section 200.510 ?Financial Statements? requires recipients of Federal funds to (1) prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited, and (2) prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended. Additionally, in accordance with 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). Additionally, management is responsible for the preparation and fair presentation of the financial statements in accordance with accounting principles generally accepted in the United States of America; this includes the design, implementation and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. Condition: During our audit, we noted that DCPCA experienced challenges in reconciling financial transaction areas that were deemed significant to the audit, properly preparing the Schedule of Expenditures of Federal Awards (SEFA), as well as noting certain timesheets that did not have evidence of approval by a supervisor. As a result of this, seven (7) audit adjustments were proposed and several reclassifying adjustments, in order to ensure a fair presentation for year-end balances. The result of the audit adjustments proposed increased year-end net assets by approximately $112,000. Additionally, several pass-through identification numbers were incorrect on the SEFA, and while the total expenditures were correct, the revenue recognition of the Federal grants was incorrect, resulting in an overstating yearend outstanding accounts receivable by approximately $37,000. We also noted that reconciliations prepared for the year-end audit were not appropriately reviewed or approved, as well as no evidence of review and approval for submitted Federal Financial Reports, quarterly progress reports, and indirect calculations. We also noted that no true-up was performed for the 2018 year-end indirect charges for Federal awards, as well as no application submission for an indirect rate for 2019. Cause: Over the past several years, the Finance Department has had significant turnover. The current Director of Finance began in early 2019 and a staff was added to the department mid-year. As a result of the changes in the department, additional funding and projects being secured, the Finance department had difficulty in completing accurate reconciliations, following up on enforcement of certain controls, such as timesheet approval, as well as establishing a proper review and approval process.Effect: Significant audit adjustments were proposed during the audit. Additionally, the Board and management were relying on inaccurate reporting throughout the year for the organization's financial position. Questioned Costs: None Context: Year-end asset and liability accounts were not properly reconciled, reviewed, or approved, resulting in significant audit adjustments. 4 of 40 timesheets did not have evidence of approval by a supervisor. It appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend DCPCA perform reconciliations for all asset and liability accounts on a monthly basis, making the year-end reconciliation process less burdensome. Additionally, all reconciliations, along with reports filed, especially those in connection with the Federal awards, should be reviewed and approved. Evidence of such review and approval should be indicated, either via email, an encrypted electronic signature, or physical signature on documents.
Views of Responsible Officials and Planned Corrective Actions: In its Accounting Policies & Procedures, DCPCA has well-documented balance sheet accounts reconciliation and periodic close procedures and sequences. Finance department staff will strive to ensure that these procedures are thoroughly adhered to and followed every month. Additionally, DCPCA will continue to broaden the practice of flagging all transactions/journal entries with a greater than $50,000 threshold and subject them to further review on their implications on financial reporting as well as provide for an additional review by/approval by the President & CEO before posting to the general ledger. In late 2019 DCPCA, contacted its Federal awarding agency (HRSA) and requested additional Financial Technical Assistance (FTA) training resources for its inhouse finance team, with the aim of strengthening its proactive posture on preventative financial reporting and compliance, to ensure that the DCPCA is in a better position to effectively and efficiently manage and report on is HRSA grant(s). We are in contact with, and have an open request with HRSA's Division of Financial Integrity, to schedule required FTA training sessions. Anticipated Completion Date: December 31, 2020 Responsible Official: Peter Kiburi, Director of Finance
Finding: Reportable Condition #2019-002: Reporting Information on the Federal Programs: CFDA 93.129: Health Resources and Services Administration Bureau of Primary Health Care Technical and Non-Financial Assistance to Health Centers Criteria: Title 2 CFR 200 Section 200.510 ?Financial Statements? requires recipients of Federal funds to prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended. Additionally, in accordance with 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: DCPCA experienced challenges in preparing the Federal Financial Reports required to be filed during the year ended December 31, 2019. In the past three years, DCPCA has had significant changes in the accounting department, including turnover in key personnel. Additionally, beginning in 2017, some of the in-house work was transitioned to an outsourced accounting role; in 2019, the outsourced accounting agreement was terminated. The transition to new personnel created an environment for inaccuracies in the Federal Financial Reports. Indirect costs also were not calculated properly, causing an underreporting of indirect costs incurred. systematic in nature. Effect: With turnover in accounting staff, the Federal Financial Reports prepared during the year were not accurately completed. Cause: The accounting staff were not able to properly prepare the Federal Financial Reports due to changes in accounting roles. Questioned Costs: None Identification as a Repeat Finding, if Applicable: This is a repeat finding of Finding 2018-002. Recommendation: We recommend DCPCA create standard operating procedures (SOPs) that outline a process whereby Federal Financial Reports are prepared based on a reconciliation of cumulative expenditures over cumulative cash draws. These reports, along with the reconciliation, should be reviewed and approved by an individual in a supervisory capacity. DCPCA should enhance the reconciliation and review process to ensure formulas and allocation of costs are applied appropriately to the individual grants and agree the amounts to its reported expenses.
Views of Responsible Officials and Planned Corrective Action Plan: Management will institute policies and procedures going forward, that will ensure that cumulative Federal Expenditures are fully reconciled every period and/or quarter and that those expenditures are reconciled against periodic federal cash draws. To ensure proper quality control and accountability of the process, this reconciliation and review process will be segregated across these functionaries: the recently hired Senior Staff Accountant will perform the periodic and quarterly reconciliations, the Director of Finance will then review and approve the reconciliation and the CEO as the grantee Authorized Official will have the final one-over review before the federal financial reports are filed with the awarding agency. Anticipated Completion Date: December 31, 2020 Responsible Official: Peter Kiburi, Director of Finance
2018-002
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 1, 2019. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 1, 2020, which was (2423 days ago).
What is a management decision? →Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 6, 2017. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 6, 2018, which was (3148 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2015-001
GSA_MIGRATION
GSA_MIGRATION
2015-002
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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