EIN: 621806324
UEI: XMN3M2NQB568
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 27, 2023. 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, 2024 (880 days ago).
What is a management decision? →The Organization does not have a formal method of identifying its base rate for an indirect cost rate, nor do they have a formal policy for charging either a negotiated indirect cost rate or the de minimis rate of 10%. Cause: There was no team member assigned to this task during the year. Effect: Potentially, unallowable costs could be charged to the federal programs. However, we did not note instances of this in our testing. Recommendation: Since the Organization does not charge over the 10% de minimis rate on any federal program, we recommend creating a formal policy to use the 10% de minimis rate on all federal programs. As part of this policy the organization should document its base rate for modified total direct costs and establish procedures for monitoring compliance of the policy. Response: The Organization has hired a part time consultant to maintain this grant schedule
Show full finding ▾Hide full finding ▴2002-04 ? Policy for indirect costs and monitoring of that policy Criteria: Non-federal entities should either obtain a negotiated indirect cost rate or elect to use a de minimis rate of 10% of modified total direct costs. Either method must be charged consistently for all federal awards. Controls over indirect policies should be monitored for compliance. Condition: The Organization does not have a formal method of identifying its base rate for an indirect cost rate, nor do they have a formal policy for charging either a negotiated indirect cost rate or the de minimis rate of 10%. Cause: There was no team member assigned to this task during the year. Effect: Potentially, unallowable costs could be charged to the federal programs. However, we did not note instances of this in our testing. Recommendation: Since the Organization does not charge over the 10% de minimis rate on any federal program, we recommend creating a formal policy to use the 10% de minimis rate on all federal programs. As part of this policy the organization should document its base rate for modified total direct costs and establish procedures for monitoring compliance of the policy. Response: The Organization has hired a part time consultant to maintain this grant schedule
Finding 4: Policy for Indirect Costs and Monitoring of that Policy (2022- 04) 4.1 Action Plan To address the identified issues regarding the policy for indirect costs and monitoring of that policy, the organization will take the following steps: ? Formalization of Policy: Develop and formalize a policy to consistently charge a de minimis rate of 10% for indirect costs on all federal programs. This policy will replace the previous practice of determining indirect costs on a case-by-case or grant-by-grant basis. ? Documentation of Base Rate: Document the base rate for modi?ed total direct costs to establish a clear and consistent basis for calculating the 10% de minimis rate. ? Monitoring and Compliance: Implement procedures for monitoring compliance with the new policy, including regular reviews to ensure that the 10% rate is being applied consistently across all federal programs. 4.2 Responsible Personnel The newly hired Grants Manager, along with the executive management team, will be responsible for ensuring compliance with the new policy. Their responsibilities will include overseeing the implementation of the policy and monitoring its adherence across all relevant programs. 4.3 Resources and Tools Page 45 The organization will leverage its existing resources, including the custom-built grant management solution and QuickBooks Online, to facilitate the implementation and monitoring of the new policy. 4.4 Implementa3on Timeline The organization plans to implement the new policy immediately, applying the 10% de minimis rate to all new grants moving forward without delay. 4.5 Training and Support The organization will provide necessary training and support to the Grants Manager and other relevant personnel to ensure a smooth transition to the new policy protocols. This will include training on the calculation and application of the 10% de minimis rate. 4.6 Monitoring and Evalua3on A monitoring and evaluation mechanism will be established to assess the e?ectiveness of the new policy. This will involve regular reviews to ensure consistent application of the 10% rate and compliance with federal requirements, thereby preventing the charging of potentially unallowable costs to federal programs.
The Organization does not have a formal policy for monitoring equipment purchases. Cause: There was no team member assigned to this task during the year. Effect: Potentially, unallowable costs could be charged to the federal programs. However, we did not note instances of this in our testing. Recommendation: The Organization should establish controls over equipment purchases for federal programs to ensure the costs are allowable and the equipment is used for activities allowed. The Organization?s policies should also include periodic physical inventory of the equipment. Response: The Organization will establish these policies and assign the appropriate program director to monitor compliance with the policy.
Show full finding ▾Hide full finding ▴2022-05 ? Controls over equipment purchases for federal programs Criteria: The Organization is required to maintain policies with internal controls over compliance with federal programs. Condition: The Organization does not have a formal policy for monitoring equipment purchases. Cause: There was no team member assigned to this task during the year. Effect: Potentially, unallowable costs could be charged to the federal programs. However, we did not note instances of this in our testing. Recommendation: The Organization should establish controls over equipment purchases for federal programs to ensure the costs are allowable and the equipment is used for activities allowed. The Organization?s policies should also include periodic physical inventory of the equipment. Response: The Organization will establish these policies and assign the appropriate program director to monitor compliance with the policy.
Finding 5: Controls over Equipment Purchases for Federal Programs (2022-05) 5.1 Ac3on Plan To address the identified issues regarding the controls over equipment purchases for federal programs, the organization will take the following steps: ? Development of Policy: Develop a flexible yet comprehensive policy that outlines the procedures and controls over equipment purchases for federal programs. This policy will provide guidelines on the allowable conditions for equipment purchases and usage, keeping in mind the diverse geographical locations of operations. The policy will be designed to accommodate long-distance equipment purchasing and monitoring, ensuring feasibility and compliance without compromising operational efficiency. ? Inventory Management: Incorporate procedures for periodic physical inventory of the equipment to ensure accurate tracking and compliance with federal requirements. ? Monitoring and Compliance: Establish mechanisms for regular monitoring of equipment purchases to prevent the charging of potentially unallowable costs to federal programs. Page 46 5.2 Responsible Personnel The newly appointed Grants Manager, who is also overseeing the corrective actions for the other findings, will be responsible for implementing and monitoring the new policy. Their extensive experience of over 20 years in grant management equips them with the necessary skills and knowledge to effectively manage this task. 5.3 Resources and Tools The organization will leverage its existing resources, including the custom-built grant management solution and QuickBooks Online, to facilitate the monitoring of equipment purchases and the management of the periodic physical inventory. 5.4 Implementa3on Timeline The organization plans to initiate the implementation of the corrective actions immediately, with the aim to have the new policy fully operational by the end of Q4 2023. 5.5 Training and Support Training programs will be developed to assist the Grants Manager and other relevant personnel in adapting to the new policy protocols. This will include training on the procedures for equipment purchases and inventory management. 5.6 Monitoring and Evalua3on A monitoring and evaluation system will be established to assess the effectiveness of the new policy. This system will involve regular reviews to ensure compliance with the policy and federal requirements, thereby safeguarding the organization from potential discrepancies and unallowable costs.
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