EIN: 593187624
UEI: RRCZRDT5DHP1
Audited by: CliftonLarsonAllen LLP
Oversight agency: 93 [Department of Health and Human Services]
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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 April 23, 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 October 23, 2026 (56 days from today).
What is a management decision? →FAC accepted this audit on May 21, 2025 — management decision was due November 21, 2025.
Prior to October 2024 the Organization did not have a written procurement policy in place that covers the requirements noted in Section 200.318 of the Code of Federal Regulations. Questioned Costs: None Context: The new policy was implemented in October 2024. Our testing concluded that the new policy covers the requirements noted in Section 200.318 of the Code of Federal Regulations. In addition, 8 of the transactions in our sample for procurement testing fall under the new policy, and we noted no instances of noncompliance in those 8 transactions. This finding is recurring solely because the new policy was not in place prior to October 2024. Cause: The new policy was being developed during 2024 Effect: Noncompliance with federal procurement requirements Repeat Finding: Yes, 2023-001 Recommendation: We recommend that the Organization follow the new policy going forward. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.847, 93.867, & 93.103 Federal Award Identification Number and Year: Various Award Period: January 1, 2024, through December 31, 2024 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires organizations to have a written procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. Condition: Prior to October 2024 the Organization did not have a written procurement policy in place that covers the requirements noted in Section 200.318 of the Code of Federal Regulations. Questioned Costs: None Context: The new policy was implemented in October 2024. Our testing concluded that the new policy covers the requirements noted in Section 200.318 of the Code of Federal Regulations. In addition, 8 of the transactions in our sample for procurement testing fall under the new policy, and we noted no instances of noncompliance in those 8 transactions. This finding is recurring solely because the new policy was not in place prior to October 2024. Cause: The new policy was being developed during 2024 Effect: Noncompliance with federal procurement requirements Repeat Finding: Yes, 2023-001 Recommendation: We recommend that the Organization follow the new policy going forward. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.
Department of Health and Human Services 2024-001 Procurement Recommendation: We recommend that the Organization develop a written procurement policy that meets the requirements noted in Section 200.318 of the Code of Federal Regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While the Organization had a procurement policy in place for the entire year, until October 1, 2024 it was noncompliant with the requirements of Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations. The new policy was implemented on October 1, 2024 and there were no instances of noncompliance after this date. It is the opinion of the organization that this finding has therefore already been resolved. Name(s) of the contact person(s) responsible for corrective action: Erica Vogt, CFO Planned completion date for corrective action plan: Already resolved
2023-001
FAC accepted this audit on May 29, 2024 — management decision was due November 29, 2024.
During our testing, it was noted that the Organization does not have a written procurement policy in place that covers the requirements noted in Section 200.318 of the Code of Federal Regulations. Questioned costs: None Context: The new policy was being developed during 2023 Cause: The new policy was not put in place until 2024 Effect: Noncompliance with federal procurement requirements Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the Organization develop a written procurement policy that meets the requirements noted in Section 200.318 of the Code of Federal Regulations. Views of responsible officials and Planned Corrective Actions: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.847, 93.867, & 93.103 Federal Award Identification Number and Year: Various Award Period: January 1, 2023, through December 31, 2023 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires organizations to have a written procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. Condition: During our testing, it was noted that the Organization does not have a written procurement policy in place that covers the requirements noted in Section 200.318 of the Code of Federal Regulations. Questioned costs: None Context: The new policy was being developed during 2023 Cause: The new policy was not put in place until 2024 Effect: Noncompliance with federal procurement requirements Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the Organization develop a written procurement policy that meets the requirements noted in Section 200.318 of the Code of Federal Regulations. Views of responsible officials and Planned Corrective Actions: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.
Procurement Recommendation: We recommend that the Organization develop a written procurement policy that meets the requirements noted in Section 200.318 of the Code of Federal Regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While the Organization has a procurement policy in place, it is noncompliant with the requirements of Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations. The Organization has experienced substantial growth in recent years and in support of this expansion, hired an experienced CFO in early 2022. The new CFO identified the need for a compliant procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. To facilitate the adherence to the new procurement policy, the Organization purchased new ERP software and both contracted with an outside organization and hired new internal staff to oversee the implementation of this software during 2023. The implementation of this software was completed at the end of 2023 and placed into service January 2024. The new procurement policy was reviewed by the auditors during the 2022 audit and a determination was made that had the new policy been in effect and followed, the Organization’s practices would have met the requirements of Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations. With the new software now in place, this policy will become effective during 2024. A staff member had been selected and fully trained to oversee the procurement function, but then retired at the end of 2023. A new staff member is currently being hired and will be specifically trained on the federal procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Erica Vogt, CFO Planned completion date for corrective action plan: January 1, 2024
2022-002
FAC accepted this audit on June 12, 2023 — management decision was due December 12, 2023.
Noncompliance with procurement requirements under Uniform Guidance. Questioned costs: None Context: During our testing, it was noted that the Organization does not have a written procurement policy in place that covers the requirements noted in Section 200.318 of the Code of Federal Regulations. Cause: Prior to 2022, the Organization was unaware of this federal requirement. Effect: Not following proper procedure is in direct violation of Section 200.318 of the Code of Federal Regulations. Repeat Finding: No. Recommendation: We recommend that the Organization develop a written procurement policy that meets the requirements noted in Section 200.318 of the Code of Federal Regulations. Views of responsible officials and Planned Corrective Actions: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.847 & 93.867 Federal Award Identification Number and Year: Various Award Period: January 1, 2022, through December 31, 2022 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires organizations to have a written procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. Condition: Noncompliance with procurement requirements under Uniform Guidance. Questioned costs: None Context: During our testing, it was noted that the Organization does not have a written procurement policy in place that covers the requirements noted in Section 200.318 of the Code of Federal Regulations. Cause: Prior to 2022, the Organization was unaware of this federal requirement. Effect: Not following proper procedure is in direct violation of Section 200.318 of the Code of Federal Regulations. Repeat Finding: No. Recommendation: We recommend that the Organization develop a written procurement policy that meets the requirements noted in Section 200.318 of the Code of Federal Regulations. Views of responsible officials and Planned Corrective Actions: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.
2022-002 Procurement While the Organization has a procurement policy in place, it is noncompliant with the requirements of Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations. The Organization has experienced substantial growth in recent years and in support of this expansion, hired an experienced CFO in early 2022. The new CFO identified the need for a compliant procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. To facilitate the adherence to the new procurement policy, the Organization has purchased new ERP software and both contracted with an outside organization and hired new internal staff to oversee the implementation of this software during 2023. The new procurement policy was reviewed by the auditors during the 2022 audit and a determination was made that had the new policy been in effect and followed, the Organization?s practices would have met the requirements of Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations. This policy will become effective on the go-live date of the new ERP software. A staff member has already been selected to oversee the procurement function and has completed a number of training courses specific to federal procurement requirements.
The Organization did not verify whether the subject subrecipients received a required annual audit under 2 CFR Part 200. By not verifying and obtaining a copy of the most recent audit of the subrecipients, the Organization was unaware if any enforcement actions against noncompliant subrecipients had occurred. Context: During our testing, it was noted that the Organization did not have any procedures in place to monitor their subrecipients and did not secure the required annual report for any of the subrecipients tested. Cause: Prior to 2022, the Organization was unaware of this federal requirement. Effect: The Organization did not comply with subrecipient monitoring requirements relative to obtaining the annual audit reports and performing the appropriate follow-up procedures (if necessary). By not securing the required annual report of subrecipients, there is a risk that subrecipients could have instances of deficiencies or noncompliance that directly impacts the award, but the Organization is unable to respond accordingly, given it would not be aware of the issues identified. Recommendation: We recommend the Organization implement a comprehensive process (and relevant internal controls) to ensure all elements of 2 CFR Part 200, Subpart D, Section 200.332 are being met, including obtaining a copy of the subject subrecipients? annual audits and taking appropriate action on deficiencies detected through the audits. Tools, such as checklists or electronic workflows, can assist in ensuring all required elements are being met. Repeat Finding: No. Questioned Costs: None Views of Responsible Officials: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Health and Human Services Federal Program: Research and Development Cluster Assistance Listing Number: 93.847 & 93.867 Federal Award Identification Number and Year: Various Award Period: January 1, 2022, through December 31, 2022 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, Section 200.332, pass-through entities are required to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and obtaining a copy of the subrecipients? annual audit and taking appropriate action on deficiencies detected through the audits, just to name a few. Lastly, in accordance with 2 CFR Title 2, Subtitle A, Chapter 2, Part 200, Subpart D, 200.303, the non-federal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Condition: The Organization did not verify whether the subject subrecipients received a required annual audit under 2 CFR Part 200. By not verifying and obtaining a copy of the most recent audit of the subrecipients, the Organization was unaware if any enforcement actions against noncompliant subrecipients had occurred. Context: During our testing, it was noted that the Organization did not have any procedures in place to monitor their subrecipients and did not secure the required annual report for any of the subrecipients tested. Cause: Prior to 2022, the Organization was unaware of this federal requirement. Effect: The Organization did not comply with subrecipient monitoring requirements relative to obtaining the annual audit reports and performing the appropriate follow-up procedures (if necessary). By not securing the required annual report of subrecipients, there is a risk that subrecipients could have instances of deficiencies or noncompliance that directly impacts the award, but the Organization is unable to respond accordingly, given it would not be aware of the issues identified. Recommendation: We recommend the Organization implement a comprehensive process (and relevant internal controls) to ensure all elements of 2 CFR Part 200, Subpart D, Section 200.332 are being met, including obtaining a copy of the subject subrecipients? annual audits and taking appropriate action on deficiencies detected through the audits. Tools, such as checklists or electronic workflows, can assist in ensuring all required elements are being met. Repeat Finding: No. Questioned Costs: None Views of Responsible Officials: There is no disagreement with the audit finding. See Corrective Action Plan prepared by the Organization.
2022-003 Subrecipient Monitoring The Organization has created a subrecipient monitoring schedule that follows the grant cycle of each of its federal grants and has also created a template document to collect the information required by 2 CFR Part 200, Subpart D, Section 200.332. Staff time has been allocated to collecting the required information from each subrecipient during 2023, which will continue annually to complete this requirement from this point forward.
FAC accepted this audit on September 28, 2022 — management decision was due March 28, 2023.
FAC accepted this audit on September 9, 2021 — management decision was due March 9, 2022.
FAC accepted this audit on September 21, 2020 — management decision was due March 21, 2021.
FAC accepted this audit on September 30, 2019 — management decision was due March 30, 2020.
FAC accepted this audit on September 4, 2018 — management decision was due March 4, 2019.
FAC accepted this audit on September 14, 2017 — management decision was due March 14, 2018.
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