EIN: 562638917
UEI: GSJ7MSCRJWX7
Audited by: Linked Accounting, LLP
Oversight agency: 84 [Department of Education]
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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 September 30, 2025. 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 30, 2026 (152 days ago).
What is a management decision? →FAC accepted this audit on August 19, 2024 — management decision was due February 19, 2025.
Lack of Internal Control over Financial Reporting, Native Hawaiian Education Act Program, Award Listing 84.362A
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In response to the negative finding of the prior year deficiency noted in the audits, immediate actions have been taken by L2020 to address the issues and prevent reoccurrence in the future. The individuals who were previously responsible for financial reporting and cash management during the audit are no longer employed at L2020. Going forward, Rebecca “Kawehi” Inaba, appointed as the Executive Director in late 2021, will take charge of ensuring that L2020 remains compliant with all financial requirements, including conducting audits in a timely manner. The organization expresses confidence in her ability to keep L2020 up to date with all financial obligations. In an effort to enhance control and oversight, L2020 will be instituting a quality control review process for all forthcoming report submissions. This measure aims to identify any discrepancies or delays in submissions, enabling corrective actions to be taken promptly. L2020 remains dedicated to upholding transparency and accountability in their financial practices. These proactive steps are crucial in enhancing processes and performance. The organization appreciates understanding and support as they strive for improved financial management practices at L2020.
2021-001
FAC accepted this audit on July 10, 2024 — management decision was due January 10, 2025.
Lack of Internal Control over Financial Reporting, Native Hawaiian Education Act Program, Award Listing 84.362A
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In response to the negative finding of the 2019, 2020 and 2021 audits, immediate actions have been taken by L2020 to address the issues and prevent reoccurrence in the future. The individuals who were previously responsible for financial reporting and cash management during the audit are no longer employed at L2020. Going forward, Rebecca “Kawehi” Inaba, appointed as the Executive Director in late 2021, will take charge of ensuring that L2020 remains compliant with all financial requirements, including conducting audits in a timely manner. The organization expresses confidence in her ability to keep L2020 up to date with all financial obligations. In an effort to enhance control and oversight, L2020 will be instituting a quality control review process for all forthcoming report submissions. This measure aims to identify any discrepancies or delays in submissions, enabling corrective actions to be taken promptly. L2020 remains dedicated to upholding transparency and accountability in their financial practices. These proactive steps are crucial in enhancing processes and performance. The organization appreciates understanding and support as they strive for improved financial management practices at L2020.
2020-001
FAC accepted this audit on July 10, 2024 — management decision was due January 10, 2025.
Lack of Internal Control over Financial Reporting, Native Hawaiian Education Act Program, Award Listing 84.362A and Covid Relief Funds, Award Listing 21.019
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In response to the negative finding of the 2020 audit, immediate actions have been taken by L2020 to address the issues and prevent reoccurrence in the future. The individuals who were previously responsible for financial reporting and cash management during the audit are no longer employed at L2020. Going forward, Rebecca “Kawehi” Inaba, appointed as the Executive Director in late 2021, will take charge of ensuring that L2020 remains compliant with all financial requirements, including conducting audits in a timely manner. The organization expresses confidence in her ability to keep L2020 up to date with all financial obligations. In an effort to enhance control and oversight, L2020 will be instituting a quality control review process for all forthcoming report submissions. This measure aims to identify any discrepancies or delays in submissions, enabling corrective actions to be taken promptly. L2020 remains dedicated to upholding transparency and accountability in their financial practices. These proactive steps are crucial in enhancing processes and performance. The organization appreciates understanding and support as they strive for improved financial management practices at L2020.
2019-001
FAC accepted this audit on December 19, 2022 — management decision was due June 19, 2023.
Finding 2019-001, Lack of Internal Control over Cash Management and Reporting, Native Hawaiian Education Act Program, Award Listing 84.362A Criteria: 2 CFR ? 200.305 Federal payment, (b) For non-Federal entities, payment methods must minimize the time elapsing between the transfer of funds from the United States government agency and the disbursement by the non-Federal entity. 2 CFR ? 200.512 Report submission (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Government Auditing Standards require adequate internal controls over accounting functions. These internal controls should reduce to a relatively low level the risk that noncompliance with applicable requirements of laws, regulations, contracts, and grants that would be material in relation to a federal program being audited may occur and not be detected in a timely manner by employees in the normal course of performing their assigned functions. Conditions: We noted a lack of internal control over Cash Management and noncompliance with timely expenditure of funds drawn down. We additionally noted a lack of internal control over Reporting and noncompliance with the timely on-line submission of the annual audit report to the Federal Audit Clearinghouse. Based on our review of the Organizations records we noted the following relating to Cash Management and the timing of drawing down and expending federal funds: Amount of Federal Cumulative Federal Funds Funds Drawn Down during Month Received in Advance of Expenditures Expenditures for Month the Month January 2019 $120,729 $99,984 $20,745 February 2019 200,290 29,705 191,330 March 2019 - 36,217 155,113 April 2019 - 68,096 87,017 May 2019 - 58,966 28,051 June 2019 200,000 78,453 149,598 July 2019 - 131,966 17,632 August 2019 60,000 69,847 7,785 September 2019 100,000 63,367 44,418 October 2019 - 36,223 8,195 November 2019 75,000 43,698 39,497 December 2019 50,000 51,877 37,620 Total $806,019 $768,399 $37,620 Context and Cause of Conditions: Management had not established and maintained effective internal control over cash management of program funding to ensure funds were spent as close as is administratively feasible to the actual disbursements, nor the timely reporting of the audited financial statements to the Federal Audit Clearinghouse. Potential Effect: A lack of internal controls over required compliance requirements could affect the Organization receiving future federal funding. Questioned Costs: None Recommendations: We recommend that management maintain both written procedures and financial management systems that minimize the time elapsing between the transfer of funds and disbursement as well as limit the draws to the minimum amounts needed in accordance with the actual, immediate cash requirements. We further recommend management complete all required reporting timely.
Show full finding ▾Hide full finding ▴Finding 2019-001, Lack of Internal Control over Cash Management and Reporting, Native Hawaiian Education Act Program, Award Listing 84.362A Criteria: 2 CFR ? 200.305 Federal payment, (b) For non-Federal entities, payment methods must minimize the time elapsing between the transfer of funds from the United States government agency and the disbursement by the non-Federal entity. 2 CFR ? 200.512 Report submission (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Government Auditing Standards require adequate internal controls over accounting functions. These internal controls should reduce to a relatively low level the risk that noncompliance with applicable requirements of laws, regulations, contracts, and grants that would be material in relation to a federal program being audited may occur and not be detected in a timely manner by employees in the normal course of performing their assigned functions. Conditions: We noted a lack of internal control over Cash Management and noncompliance with timely expenditure of funds drawn down. We additionally noted a lack of internal control over Reporting and noncompliance with the timely on-line submission of the annual audit report to the Federal Audit Clearinghouse. Based on our review of the Organizations records we noted the following relating to Cash Management and the timing of drawing down and expending federal funds: Amount of Federal Cumulative Federal Funds Funds Drawn Down during Month Received in Advance of Expenditures Expenditures for Month the Month January 2019 $120,729 $99,984 $20,745 February 2019 200,290 29,705 191,330 March 2019 - 36,217 155,113 April 2019 - 68,096 87,017 May 2019 - 58,966 28,051 June 2019 200,000 78,453 149,598 July 2019 - 131,966 17,632 August 2019 60,000 69,847 7,785 September 2019 100,000 63,367 44,418 October 2019 - 36,223 8,195 November 2019 75,000 43,698 39,497 December 2019 50,000 51,877 37,620 Total $806,019 $768,399 $37,620 Context and Cause of Conditions: Management had not established and maintained effective internal control over cash management of program funding to ensure funds were spent as close as is administratively feasible to the actual disbursements, nor the timely reporting of the audited financial statements to the Federal Audit Clearinghouse. Potential Effect: A lack of internal controls over required compliance requirements could affect the Organization receiving future federal funding. Questioned Costs: None Recommendations: We recommend that management maintain both written procedures and financial management systems that minimize the time elapsing between the transfer of funds and disbursement as well as limit the draws to the minimum amounts needed in accordance with the actual, immediate cash requirements. We further recommend management complete all required reporting timely.
Finding 2019-001, Lack of Internal Control over Reporting and Cash Management, Native Hawaiian Education Act Program, Award Listing 84.362A Carbonaro CPAs & Management Group, the auditor, has an opinion that the ?time elapsing between the transfer of funds from the United States government agency and the disbursement by the non-Federal entity?, as it pertains to 2 CFR ? 200.305 (b), should be 3 to 4 days. This is an assumption made by the auditor without consideration of several matters, such as the time zone between Hawaii Standard Time (HST) and Eastern (EST/EDT) Time, as a transfer of funds is impacted by the significant time difference between HST and EST/EDT zones, of which can cause a 1-to-2-day transfer of funds delay from the date in which the transfer was requested. In addition, without the delay caused by a significant difference in time between the HST and EST/EDT zones, a transfer of funds can take upwards of 3 to 5 business days. Additionally, a transfer of funds can be impacted by holidays and maintenance of the government computer system(s) (e.g. G5). Hence, attempting to meet a 3-to-4-day expectation to ?minimize the time elapsing between the transfer of funds from the United States government agency and the disbursement by the non-Federal entity? is unreasonable, as such an expectation will place an undue burden on the organization, particularly when it pertains to cash flow and meeting the organization?s payroll obligations. In addition, on December 1, 2022, after review of La?i?opua 2020?s initial Management Response and Corrective Action Plan submitted on November 21, 2022, Ms. Rozanne Connell, CFE, Principal of Carbonaro CPAs & Management Group, emailed La?i?opua 2020 stating that she spoke with a previous La?i?opua 2020 consultant pertaining to the matter of ?the draw downs of federal funds for the NHE program being done in advance of actual expenditures?. Ms. Connell, also provided an example of a ?draw of federal funds that occurred in advance of all program expenses? in 2019. The current La?i?opua 2020 Board, as is, and its current Executive Director, as is, were not present in 2019, so any statements of past practices by previous staff and/or consultants in control of the ?draw process? can not be confirmed or denied. Furthermore, as recognized by Ms. Connell, any draws ?spent down over several months? was done by persons no longer with the organization?. What the current La?i?opua 2020 Board and its Executive Director can affirm is under its leadership now and new project and program management that transitioned in April 2022, that the ?time elapsing between the transfer of funds from the United States government agency and the disbursement by the non-Federal entity?, as it pertains to 2 CFR ? 200.305 (b), is in alignment with the expectations of 2 CFR ? 200.305 (b) and no longer ?spent down over several months?, as pointed out by Ms. Rozanne Connell, as occurring in 2019. La?i?opua 2020 now has strict standards for fund control and accountability. Advance payments requested are most likely to occur within 7 days prior to payday and after timesheets are submitted. As it pertains to non-payroll expenses, said expenses are added to the current amount owed in payroll to determine cash flow prior to requesting an advance payment. Therefore, an advance payment request is submitted between 6 to 7 days prior to payday, which provides the necessary 3 to 5 business days for a transfer of funds to occur. By doing so, La?i?opua 2020 can meet its financial obligations, while minimizing the time elapsing between the transfer of funds and disbursement. This practice ensures that ?federal funds via draws are timely and not spent over several months, in accordance with the contract and federal guidelines?. Hence, the current (2022) fund control and accountability (or to address the need for a corrective action plan, in accordance to 2 CFR sections 200.511(a) and 200.511(c) and based on a draw and/or draws that occurred in 2019) is as outlined below. Advance payments requested are to occur within 7 days prior to payday and after timesheets are submitted. As it pertains to non-payroll expenses, said expenses are added to the current amount owed in payroll to determine cash flow prior to requesting an advance payment. All advance payments, as it pertains to 2 CFR ? 200.305 (b), shall be implement as follows: ? The Project/Program Director (and/or the equivalent) shall produce an ?itemized expenditure? sheet based on the project/program budget for an advance payment. The ?itemized expenditure? sheet shall reflect an estimated immediate need of funds in alignment with the project/program budget. ? The completed ?itemized expenditure? is submitted to the Executive Administrative Assistant and/or the Resource Logistical Coordinator (and/or the equivalent) who audits the ?itemized expenditure? and prepares a ?draw down authorization form? for an advance payment. ? Upon completion of the the ?draw down authorization form?, the Executive Administrative Assistant and/or the Resource Logistical Coordinator (and/or the equivalent), will sign-off (electronic signatures are acceptable) on the form and submit said form in a timely manner to the Executive Director for final review and approval. ? The Executive Director, upon receipt, will review the ?draw down authorization form? in a timely manner for accuracy (as it pertains to the budget and upcoming budget expenses), alignment with 2 CFR ? 200.305 (b), and/or any other necessitated requirements (e.g. checks and balances) prior to final authorization via a signature (electronic signatures are acceptable). ? Upon final authorization granted by the Executive Director, the authorized ?payee? (e.g. Project Director), shall properly request the advance payment via the government computer system(s) (e.g. G5) or as determined by the funder. ? Once the advance payment request is submitted via the government computer system(s) (e.g. G5) or as determined by the funder, the ?payee? shall document the request (e.g. online and/or email confirmation) and attach the confirmation(s) to the ?draw down authorization form? and submit the form to the Executive Administrative Assistant and/or the Resource Logistical Coordinator (and/or the equivalent) and the Executive Director via electronic copy for proper recordation and filing. Note: An advance payment may occur during a non-pay period, if and only if an ?itemized expense? is recognized and necessitated by a project/program need, but such an advance payment MUST adhere to all steps outlined above. Rebecca ?Kawehi? Inaba, Executive Director, is responsible for the implementation of the above steps, as it pertains to advance payments governed by 2 CFR ? 200.305 (b). The current (2022) fund control and accountability outlined above is currently in full effect and has been completed, as the development and implementation of said procedures began to occur on or shortly after April 2022 with the transition of a new project and program management team under the leadership of the new Executive Director Rebecca ?Kawehi? Inaba hired during QTR4 2021.
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