EIN: 522168499
UEI: FMNRMMMXW7A5
Audited by: GELMAN, ROSENBERG & FREEDMAN
Oversight agency: 93 [Department of Health and Human Services]
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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 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 (84 days from today).
What is a management decision? →FAC accepted this audit on May 18, 2025 — management decision was due November 18, 2025.
FAC accepted this audit on May 14, 2024 — management decision was due November 14, 2024.
FAC accepted this audit on April 27, 2023 — management decision was due October 27, 2023.
During our 2022 audit, we noted multiple consultant contractors which were charged to the Federal program under a noncompetitive (sole source) justification. We noted that the Association did not have records sufficient to detail the history and the rationale of the method of procurement at the time the contracts were executed. Ultimately, official documentation was made available to justify the noncompetitive method of procurement dated March 2023, date of audit fieldwork. Cause: The Association did not document the history or the justification for the method of procurement selected for various consultants charged to the Federal program at the time the contracts were executed. Effect: The Association may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in ? 200.320 (f) Methods of procurement to be followed and thereby failing to full and open competition as required by the regulations. Questioned Costs: N/A Context: The audit sample consisted of eleven transactions of four consultants. The finding pertains to all items sampled. Identification as a Repeat Finding: Yes (2021-001) Recommendation: We recommend that the Association review it?s policy to ensure it clearly identifies the allowable categories of sole source justification. We also recommend that documentation is maintained to substantiate adherence to its policy on Procurement and Contacting and ensure that all instances are adequately documented according to the regulations.
Show full finding ▾Hide full finding ▴Finding 2022-002: Procurement (Noncompetitive Justification) Documentation Information on the Federal Programs: ? 93.243 - Clinical Support System for Serious Mental Illness ? Federal award number - 5H79SM080818-04 & 5H79SM080818-05 ? Federal award date - July 9, 2021 and July 9, 2022 ? Federal Agency - Department of Health and Human Services Criteria: ? 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: ? 200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Condition: During our 2022 audit, we noted multiple consultant contractors which were charged to the Federal program under a noncompetitive (sole source) justification. We noted that the Association did not have records sufficient to detail the history and the rationale of the method of procurement at the time the contracts were executed. Ultimately, official documentation was made available to justify the noncompetitive method of procurement dated March 2023, date of audit fieldwork. Cause: The Association did not document the history or the justification for the method of procurement selected for various consultants charged to the Federal program at the time the contracts were executed. Effect: The Association may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in ? 200.320 (f) Methods of procurement to be followed and thereby failing to full and open competition as required by the regulations. Questioned Costs: N/A Context: The audit sample consisted of eleven transactions of four consultants. The finding pertains to all items sampled. Identification as a Repeat Finding: Yes (2021-001) Recommendation: We recommend that the Association review it?s policy to ensure it clearly identifies the allowable categories of sole source justification. We also recommend that documentation is maintained to substantiate adherence to its policy on Procurement and Contacting and ensure that all instances are adequately documented according to the regulations.
Views of Responsible Officials and Planned Corrective Actions: The Association understands the need to maintain detailed procurement records at the time of the award. APA started implementing a corrective action plan effective April 1, 2022, to address audit finding 2021-001. As a result, since April 1, 2022, new contracts issued under all Federal awards, including the program finding 2022-002 pertains to, included detailed procurement justification and approval documentation. APA also started to review and approve applicable procurement justification for existing active contracts with effective dates prior to April 1, 2022. The contracts sampled for finding 2022-002 have effective dates prior to April 1, 2022, and the review of their justification was conducted in March 2023. We realize the review, justification and approval should be expedited to include all active awards. APA will continue to provide additional training and reinforcement of existing policies to all staff involved in procurement of contracts using federal funds to ensure adherence to 2 CFR 200.318 (i) General procurement standards, and 2 CFR 200.320 (f) Methods of procurement to be followed. In addition, priority will be given to complete the review, approval, and documentation of procurement justification for all active contracts with effective dates prior to April 1, 2022.
2021-001
FAC accepted this audit on May 18, 2022 — management decision was due November 18, 2022.
During our 2021 audit, we noted two consultant contractors which were charged to the Federal program under a noncompetitive (sole source) justification. We noted that the Association did not have records sufficient to detail the history and the rationale of the method of procurement at the time the contracts were executed. Additionally, no official documentation was available to justify the noncompetitive method of procurement selected according to the requirements noted in ?200.320. Cause: The Association did not document the history or the justification for the method of procurement selected for two consultants charged to the Federal program. Effect: The Association may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in ? 200.320 (f) Methods of procurement to be followed and thereby failing to full and open competition as required by the regulations. Questioned Costs: N/A Context: The audit sample consisted of five transactions of two consultants. The sample examined 100% of consultant fees charged to the major program. The finding pertains to all items sampled. Recommendation: We recommend that the Association review it?s policy to ensure it clearly identifies the allowable categories of sole source justification. We also recommend that documentation is maintained to substantiate adherence to its policy on Procurement and Contacting and ensure that all instances are adequately documented according to the regulations.
Show full finding ▾Hide full finding ▴Finding: 2021-001: Procurement (Noncompetitive Justification) Documentation Information on the Federal Programs: 93.986 - Medicare Access and CHIP Reauthorization Act (MACRA) Funding Opportunity: Measure Development for the Quality Payment Program Federal award number - 1V1CMS221640-03 Federal award date - September 13, 2020 Federal Agency - Centers for Medicare & Medicaid Services (CMS) Criteria: ? 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: ? 200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Condition: During our 2021 audit, we noted two consultant contractors which were charged to the Federal program under a noncompetitive (sole source) justification. We noted that the Association did not have records sufficient to detail the history and the rationale of the method of procurement at the time the contracts were executed. Additionally, no official documentation was available to justify the noncompetitive method of procurement selected according to the requirements noted in ?200.320. Cause: The Association did not document the history or the justification for the method of procurement selected for two consultants charged to the Federal program. Effect: The Association may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in ? 200.320 (f) Methods of procurement to be followed and thereby failing to full and open competition as required by the regulations. Questioned Costs: N/A Context: The audit sample consisted of five transactions of two consultants. The sample examined 100% of consultant fees charged to the major program. The finding pertains to all items sampled. Recommendation: We recommend that the Association review it?s policy to ensure it clearly identifies the allowable categories of sole source justification. We also recommend that documentation is maintained to substantiate adherence to its policy on Procurement and Contacting and ensure that all instances are adequately documented according to the regulations.
Views of Responsible Officials and Planned Corrective Actions: The Association understands the need to maintain contemporaneous, detailed procurement records and has historically done this for our federal grant awards. By June 30, 2022, we will provide additional training and reinforcement of existing policies to all staff involved in procurement of contracts using federal funds. In addition, effective April 1, 2022, we have expanded our documentation for procurements via noncompetitive proposals to indicate the specific requirements under ? 200.320 (f).
FAC accepted this audit on July 7, 2021 — management decision was due January 7, 2022.
FAC accepted this audit on May 17, 2020 — management decision was due November 17, 2020.
FAC accepted this audit on August 4, 2019 — management decision was due February 4, 2020.
FAC accepted this audit on September 3, 2018 — management decision was due March 3, 2019.
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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