EIN: 660465922
UEI: WMJTSHN7MA63
Audited by: RODRIGUEZ SANABRIA & CO CPA PSC
Oversight agency: 93 [Department of Health and Human Services]
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 14, 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 May 14, 2024 (836 days ago).
What is a management decision? →During the disbursement test, we noted that compensation of employees is not distributed based on the actual time devoted or identified specifically to the performance of those awards. The Agency is currently in the process to adjust reports submitted to allocate costs to the applicable award.
Show full finding ▾Hide full finding ▴During the disbursement test, we noted that compensation of employees is not distributed based on the actual time devoted or identified specifically to the performance of those awards. The Agency is currently in the process to adjust reports submitted to allocate costs to the applicable award.
The agency has already taken significant strides in response to the auditor's recommendations. The finalization of our time distribution structure implementation is well underway, with a focus on aligning costs with the relative benefits received. Concurrently, formal procedures for payroll cost allocation have been in development, nearing completion to ensure accurate and compliant allocation. A comprehensive training program for our finance personnel will be develop, equipping them with the skills needed for effective implementation. To uphold the integrity of these measures, a robust monitoring system will be implemented to oversee adherence. Proposed Completion Date: March 30, 2024
2022-001
During our Special Conditions test we noted that forms SF-270 related to the audit period were submitted but total expenditures claimed totaled $35,661. Such amount differs significantly from the amount recorded in the Schedule of Expenditures of Federal Awards related to the Program $399,814. After consulting with Agency’s officials, the stated that forms submitted covered expenditures that has been approved by the federal program officials. The Agency’s management is evaluating the amount that will be charged to the Program accordingly.
Show full finding ▾Hide full finding ▴During our Special Conditions test we noted that forms SF-270 related to the audit period were submitted but total expenditures claimed totaled $35,661. Such amount differs significantly from the amount recorded in the Schedule of Expenditures of Federal Awards related to the Program $399,814. After consulting with Agency’s officials, the stated that forms submitted covered expenditures that has been approved by the federal program officials. The Agency’s management is evaluating the amount that will be charged to the Program accordingly.
the Agency has already taken steps to submit SF-270 forms for the total amount of $232,725.42. These forms are currently awaiting grantor approval. We will closely monitor the progress of these submissions and ensure they are processed in a timely manner. Enhanced Monitoring: To prevent such discrepancies in the future, we will strengthen our monitoring processes. While we have established a Status Report to track the filing status of SF-270 forms, we will also implement measures to ensure that these forms are submitted as required. Proposed Completion Date: March 30, 2024
2022-002
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
During the disbursement test, we noted that compensation of employees is not distributed based on the actual time devoted or identified specifically to the performance of those awards. The Agency is currently in the process to adjust reports submitted to allocate costs to the applicable award. Questioned costs: Not determined. Cause: The Agency does not have a formal time distribution plan for employees? compensation between the programs served.
Show full finding ▾Hide full finding ▴Type of finding: Material Noncompliance / Material Weakness Criteria or specific requirement: The Uniform Guidance section 200.405 - Allocable costs (a) establishes that a cost is allocable to a particular cost objective if the goods or services involved are chargeable or assignable to that Federal Award or cost objective in accordance with relative benefits received. Uniform Guidance section 200.405 - Direct cost allocation principles (d) states that if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. Condition: During the disbursement test, we noted that compensation of employees is not distributed based on the actual time devoted or identified specifically to the performance of those awards. The Agency is currently in the process to adjust reports submitted to allocate costs to the applicable award. Questioned costs: Not determined. Cause: The Agency does not have a formal time distribution plan for employees? compensation between the programs served.
Corrective Action: We are working on the implementation of a time entry tracking with timesheet generation allowing for time entries to be tied back to specific advocacy activities. As of October 2021, we implemented the time entry tracking with timesheet. We are in the phase of evaluating and improving this implementation. We stablished a Database System called Disability Advocacy Database (DAD), this system was developed by the National Disability Rights Network (NDRN) to provide the P&A network with a web-based resource for client/project management and reporting.
2020-001
During our Special Conditions test we noted that forms SF-270 related to the audit period were not submitted.
Show full finding ▾Hide full finding ▴Type of finding: Material Noncompliance / Material Weakness Criteria or specific requirement: Grant Awards notifications Terms and Conditions section establishes that for this award the SF-270 will serve as the interim expenditure report to be filed. Standard Form 270- Request for Advance or Reimbursement must be used to request grant funds. The Agency must submit, either at the end of the grant period or on a quarterly, reimbursable expenses based on actual expense incurred. Condition: During our Special Conditions test we noted that forms SF-270 related to the audit period were not submitted.
Corrective Action: We are working on the implementation of a time entry tracking with timesheet generation allowing for time entries to be tied back to specific advocacy activities. As of October 2021, we implemented the time entry tracking with timesheet. We are in the phase of evaluating and improving this implementation. We stablished a Database System called Disability Advocacy Database (DAD), this system was developed by the National Disability Rights Network (NDRN) to provide the P&A network with a web-based resource for client/project management and reporting.
2020-002
During our Special Conditions test we noted that forms SF-270 related to the audit period were submitted but total expenditures claimed totaled $35,810.95. Such amount differs significant from the amount recorded in the Schedule of Expenditures of Federal Awards related to the Program ($554,498). After consulting with Agency?s officials, the stated that forms submitted covered expenditures that has been approved by the federal program officials. The Agency?s management is evaluating the amount that will be charge to the Program accordingly.
Show full finding ▾Hide full finding ▴Grant Awards notifications Terms and Conditions section establishes that for this award the SF-270 will serve as the interim expenditure report to be filed. Standard Form 270- Request for Advance or Reimbursement must be used to request grant funds. The Agency must submit, either at the end of the grant period or on a quarterly, reimbursable expenses based on actual expense incurred. Condition: During our Special Conditions test we noted that forms SF-270 related to the audit period were submitted but total expenditures claimed totaled $35,810.95. Such amount differs significant from the amount recorded in the Schedule of Expenditures of Federal Awards related to the Program ($554,498). After consulting with Agency?s officials, the stated that forms submitted covered expenditures that has been approved by the federal program officials. The Agency?s management is evaluating the amount that will be charge to the Program accordingly.
Corrective Action: We prepared and submitted the SF 270 for the fiscal year 2020. The current goal is to submit request for reimbursement on a monthly basis no later than September 30, 2023.
FAC accepted this audit on June 24, 2021 — management decision was due December 24, 2021.
During the disbursement test, we noted that compensation of employees is not distributed based on the actual time devoted or identified specifically to the performance of those awards. The Agency is currently in the process to adjust reports submitted to allocate costs to the applicable award.
Show full finding ▾Hide full finding ▴During the disbursement test, we noted that compensation of employees is not distributed based on the actual time devoted or identified specifically to the performance of those awards. The Agency is currently in the process to adjust reports submitted to allocate costs to the applicable award.
Finding: 2020-II-01 Name of contact person: Loida Oliveras Gonzalez, Executive Director Corrective Action: Starting from October 1, 2018, we stablished a Database System called Disability Advocacy Database (DAD), this system was developed by the National Disability Rights Network (NDRN) to provide the P&A network with a web-based resource for client/project management and reporting. We are working on the implementation of a time entry tracking with timesheet generation allowing for time entries to be tied back to specific advocacy activities. We are currently in the final phase of its implementation. Proposed Completion Date: October 1, 2021 Section III ? Federal Award Findings and Questioned Costs Finding: 2020-III-01 Name of contact person: Loida Oliveras Gonzalez, Executive Director Corrective Action: Starting from October 1, 2018, we stablished a Database System called Disability Advocacy Database (DAD), this system was developed by the National Disability Rights Network (NDRN) to provide the P&A network with a web-based resource for client/project management and reporting. We are working on the implementation of a time entry tracking with timesheet generation allowing for time entries to be tied back to specific advocacy activities. We are currently in the final phase of its implementation. Proposed Completion Date: October 1, 2021
2019-001
During our Special Conditions test we noted that several SF-270 related to the audit period were not submitted. The following is a summary of it. Description Month Amount PAIMI 19-12 December 2019 $ 8,860.39 PAIMI 19-13 January 2020 $ 2,317.21 PAIMI 19-14 February 2020 $ 5,098.96 PAIMI 19-15 May 2020 $ 9,061.60 PAIMI 19-16 June 2020 $ 2,490.03
Show full finding ▾Hide full finding ▴During our Special Conditions test we noted that several SF-270 related to the audit period were not submitted. The following is a summary of it. Description Month Amount PAIMI 19-12 December 2019 $ 8,860.39 PAIMI 19-13 January 2020 $ 2,317.21 PAIMI 19-14 February 2020 $ 5,098.96 PAIMI 19-15 May 2020 $ 9,061.60 PAIMI 19-16 June 2020 $ 2,490.03
Name of contact person: Loida Oliveras Gonzalez, Executive Director Corrective Action: We are in the last phase of preparing the SF 270 for the fiscal year 2020. The goal is submit these request for reimbursement no later than September 30, 2021. Proposed Completion Date: September 30, 2021
FAC accepted this audit on August 13, 2020 — management decision was due February 13, 2021.
During the disbursement test, we noted that compensation of employees is not distributed based on the actual time devoted or identified specifically to the performance of those awards. The Agency established a formal time distribution structure and is currently in the final phase of its implementation. Questioned costs: Not determined. Cause: The Agency does not have a formal time distribution plan for employees? compensation between the programs served. Effect: The Agency is not allocating its direct costs on the time and resources devoted to each program, which may result in overcharging of it to programs that may not be benefited from the services of the employees. This situation could lead to an incorrect distribution of disbursement amounts among the programs presented in the statement of cash receipts, disbursements and net-changes (cash basis). Recommendations: We recommend the Agency to finalize its time distribution structure implementation as soon as possible in order assign costs objectives in accordance with the relative benefits received. Views of responsible officials and planned corrective action: See the Agency?s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Programs: 93.138 - Protection and Advocacy for Individuals with Mental Illness 93.630 - Developmental Disabilities Basis Support and Advocacy Grants Type of finding: Material Noncompliance / Material Weakness Criteria or specific requirement: The Uniform Guidance section 200.405 - Allocable costs (a) establishes that a cost is allocable to a particular cost objective if the goods or services involved are chargeable or assignable to that Federal Award or cost objective in accordance with relative benefits received. Uniform Guidance section 200.405 - Direct cost allocation principles (d) states that if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. Condition: During the disbursement test, we noted that compensation of employees is not distributed based on the actual time devoted or identified specifically to the performance of those awards. The Agency established a formal time distribution structure and is currently in the final phase of its implementation. Questioned costs: Not determined. Cause: The Agency does not have a formal time distribution plan for employees? compensation between the programs served. Effect: The Agency is not allocating its direct costs on the time and resources devoted to each program, which may result in overcharging of it to programs that may not be benefited from the services of the employees. This situation could lead to an incorrect distribution of disbursement amounts among the programs presented in the statement of cash receipts, disbursements and net-changes (cash basis). Recommendations: We recommend the Agency to finalize its time distribution structure implementation as soon as possible in order assign costs objectives in accordance with the relative benefits received. Views of responsible officials and planned corrective action: See the Agency?s Corrective Action Plan.
STARTING FROM OCTOBER 1 2018, WE ESTABLISHED DAD SYSTEM. WE ARE CURRENTLY IN FINAL PHASE OF IMPLEMENTATION. SEE FS CAP
2018-001
During the Eligibility Test, we noted that for a sample of fifteen (15) participants, evidence of mental illness was not found in one (1) instance at the date was determined to be eligible. The following is a summary: Social Security Number Case Number Eligibility date Medical evidence in file date 9973 SJ 2018-09-0115 August 17, 2018 October 17, 2018 Questioned costs: Not determined. Cause: The applicable official did not obtained evidence of mental illness of the participant during the eligibility determination process. Effect: The costs incurred by the Agency may be disallowed and subject to reimbursement to grantor, since services should be provided only to eligible participants. Recommendations: We recommend the Agency to stress its employees the importance to obtain such information always. In the event, that such information may not be obtained, it should deny services or suspend it until such information is obtained. Views of responsible officials and planned corrective action: See the Agency?s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Category: Eligibility Program: 93.138 - Protection and Advocacy for Individuals with Mental Illness Type of finding: Material Noncompliance / Material Weakness Criteria or specific requirement: U.S. Code - Title 42 Chapter 114 - Subchapter I Part A Section 10802 - Definitions (4) establishes in part the following: ?The term ?individual with mental illness? means an individual - who has a significant mental illness or emotional impairment, as determined by a mental health professional qualified under the laws and regulations of the State?. Condition: During the Eligibility Test, we noted that for a sample of fifteen (15) participants, evidence of mental illness was not found in one (1) instance at the date was determined to be eligible. The following is a summary: Social Security Number Case Number Eligibility date Medical evidence in file date 9973 SJ 2018-09-0115 August 17, 2018 October 17, 2018 Questioned costs: Not determined. Cause: The applicable official did not obtained evidence of mental illness of the participant during the eligibility determination process. Effect: The costs incurred by the Agency may be disallowed and subject to reimbursement to grantor, since services should be provided only to eligible participants. Recommendations: We recommend the Agency to stress its employees the importance to obtain such information always. In the event, that such information may not be obtained, it should deny services or suspend it until such information is obtained. Views of responsible officials and planned corrective action: See the Agency?s Corrective Action Plan.
WE WILL SEND MEMORANDUM TO EMPHASIZE OUR EMPLOYEES THE IMPORTANCE TO OBTAIN EVIDENCE OF MENTAL ILLNESS OF PARTICIPANTS DURING ELIGBILITY.
2018-002
FAC accepted this audit on February 15, 2017 — management decision was due August 15, 2017.
GSA_MIGRATION
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2015-001
GSA_MIGRATION
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