EIN: 581521475
UEI: DN2PQ51JLX25
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 9, 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 9, 2026 (16 days from today).
What is a management decision? →FINDING 2025-001 Significant Deficiency in Internal Control over Compliance – Other Matter Federal Agency: Department of Homeland Security and Department of Health and Human Services Pass through Grantor: Multiple Federal Program(s): COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters and Research and Development Cluster Assistance Listing Number(s): 97.036 and multiple for Research and Development Criteria: Uniform Guidance requires the auditee to prepare a schedule of expenditures of federal awards, (the “Schedule” or “SEFA”), for the period covered by the auditee’s financial statements that includes certain required elements, including total federal awards expended for each individual federal program and ensure the accuracy and completeness of such schedule. Condition/Context: It was identified that Federal Emergency Management Agency (“FEMA”) ALN 97.036 funds totaling approximately $1.8 million were presented on the current year SEFA relating to obligated expenditures for fiscal period from 2021 through 2024. These funds were not previously reported on prior years’ SEFAs. Additionally, there were other grant funds related to the R&D Cluster not initially presented on the current year SEFA totaling approximately $517K. Cause: Management believed FEMA expenditures should be reported on the SEFA only upon reimbursement (received in 2025). However, per the Compliance Supplement, FEMA expenditures should be included when the project is obligated and eligible costs are incurred. For the R&D expenditures, management was unaware that grant funds received on a per-patient basis should be included in the SEFA. Effect: Federal program amounts may be misstated on the Schedule, potentially affecting major program determination and leading to findings or ineligibility of future funding. Recommendation: Management should prepare the Schedule timely, record expenditures when incurred (and obligated, if applicable), reconcile to the financial statements, and implement detailed controls to review the SEFA for accuracy and completeness Repeat Finding: No. Views of Responsible Officials: The Corporation agrees with our recommendation and will implement procedures by June 30, 2026. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2025-001 Significant Deficiency in Internal Control over Compliance – Other Matter Federal Agency: Department of Homeland Security and Department of Health and Human Services Pass through Grantor: Multiple Federal Program(s): COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters and Research and Development Cluster Assistance Listing Number(s): 97.036 and multiple for Research and Development Criteria: Uniform Guidance requires the auditee to prepare a schedule of expenditures of federal awards, (the “Schedule” or “SEFA”), for the period covered by the auditee’s financial statements that includes certain required elements, including total federal awards expended for each individual federal program and ensure the accuracy and completeness of such schedule. Condition/Context: It was identified that Federal Emergency Management Agency (“FEMA”) ALN 97.036 funds totaling approximately $1.8 million were presented on the current year SEFA relating to obligated expenditures for fiscal period from 2021 through 2024. These funds were not previously reported on prior years’ SEFAs. Additionally, there were other grant funds related to the R&D Cluster not initially presented on the current year SEFA totaling approximately $517K. Cause: Management believed FEMA expenditures should be reported on the SEFA only upon reimbursement (received in 2025). However, per the Compliance Supplement, FEMA expenditures should be included when the project is obligated and eligible costs are incurred. For the R&D expenditures, management was unaware that grant funds received on a per-patient basis should be included in the SEFA. Effect: Federal program amounts may be misstated on the Schedule, potentially affecting major program determination and leading to findings or ineligibility of future funding. Recommendation: Management should prepare the Schedule timely, record expenditures when incurred (and obligated, if applicable), reconcile to the financial statements, and implement detailed controls to review the SEFA for accuracy and completeness Repeat Finding: No. Views of Responsible Officials: The Corporation agrees with our recommendation and will implement procedures by June 30, 2026. See Corrective Action Plan.
Re: Finding 2025 001 – Significant Deficiency in Internal Control Over Financial Reporting – Preparation of the Schedule of Expenditures of Federal Awards (SEFA) The Corporation agrees with the recommendation. Management acknowledges that certain federal expenditures were not initially reported on the Schedule of Expenditures of Federal Awards (SEFA) in the appropriate fiscal periods due to a misunderstanding of applicable Uniform Guidance requirements and reliance on prior audit treatment. Specifically, expenditures related to Federal Emergency Management Agency (FEMA) programs were not included on the SEFA until reimbursement was received, and certain per patient payments associated with federally funded research were not initially identified as SEFA reportable. To address this matter and strengthen internal controls over the preparation and review of the SEFA, management will implement the following corrective actions: • Future FEMA expenditures will be reported on the SEFA in the fiscal year in which the projects are obligated and eligible expenditures are incurred, regardless of the timing of reimbursement. • Per patient payments received in connection with federally funded research programs will be evaluated for SEFA reporting and included as required. • A formal Standard Operating Procedures related to the preparation of the SEFA will be developed and implemented to clarify reporting requirements for obligated expenditures, per patient grant activity, and other federal awards. • Review procedures will be enhanced to include confirmation by entity and corporate leadership that all federal awards and related expenditures have been identified, evaluated, and appropriately reported on the SEFA. • Management will evaluate opportunities to complete SEFA preparation and preliminary review earlier in the audit cycle to allow for timely identification and resolution of potential reporting issues. Management believes these actions will improve the accuracy and completeness of the SEFA and reduce the risk of similar issues in future reporting periods.
FAC accepted this audit on June 17, 2021 — management decision was due December 17, 2021.
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