Civic Heart Community Services

Finding #2025-002 – Significant Deficiency. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Affordable Care Act (ACA) Personal Responsibility Education Program, Assistance Listing #93.092, Contract #90AK0075-03-03, Contract year: 09/30/23 – 09/29/25. Criteria: Reporting and allowable costs – Management of Civic Heart is responsible for establishing and maintaining an effective system of internal control over government grant billing requests to ensure all grant reimbursement requests are properly prepared and recorded and that all costs submitted for reimbursement are properly allocated, where applicable. Condition and context: Civic Heart’s internal controls over grant billing requests were not sufficient to ensure that grant billing requests were consistently independently reviewed and approved. Transaction testing for details and internal controls revealed the following: 1) 3 out of 12 grant billing requests did not have evidence of independent review and approval. 2) 3 of 3 pay period journal entries used to allocate payroll expense between departments and funding sources did not have evidence of independent review and approval. Cause and effect: Transitions in the accounting and management team resulted in independent reviews of grant billing requests and payroll allocation journal entries either not occurring or documentation of such review and approval not being retained. Failure to establish and maintain an adequate system of internal control over financial reporting adversely affects Civic Heart’s ability to prepare financial statements in accordance with GAAP and may result in improper grant billings. Questioned costs: Unknown. Recommendation: Same as finding reported as #2025-001. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2025-003 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract # NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Affordable Care Act (ACA) Personal Responsibility Education Program, Assistance Listing #93.092, Contract #90AK0075-03-03, Contract year: 09/30/23 – 09/29/25. Criteria: Allowable costs and period of performance – The Uniform Guidance, Subpart E Cost Principles, establishes costs principles which must be followed for expenditures to be allowable and requires a system of internal controls sufficient to ensure that costs are properly charged to the appropriate general ledger object and class code. The Uniform Guidance §200.309 period of performance requires expenditures be incurred during the period of the federal grant award in order to be allowable. Condition and context: During our testing of payroll, non-payroll and indirect cost pool transactions, we identified the following exceptions: Controls over allowable cost and other non-compliance: AL #93.092 Affordable Care Act (ACA) Personal Responsibility Education Program. In a sample of 40 non-payroll transactions tested for internal controls and compliance for allowable cost we found one instance of an annual subscription for the term ending May 2026 charged to a grant which ended September 29, 2025 resulting in eight months, or approximately $1,200, charged outside the period of performance. Partial repeat of finding #2024-004. Controls over period of performance and other non-compliance: AL #93.332 Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges. In a period-of-performance sample of 18 vendor transactions with grant charges close to grant beginning or ending dates during the audit period, we found 3 instances or $1,003 of vendor costs charged outside the grant period of performance. Additionally, testing of payroll charged at the end of the grant period revealed that approximately $6,693 was charged outside the period of performance. Cause and Effect: Failure to follow Civic Heart’s policies and procedures related to review of coding for charges to the grants resulted in costs charged outside the grant’s period of performance. Questioned costs: $8,896. Recommendation: Emphasize adherence to established policies and procedures to ensure maintenance and review of payroll spreadsheets and general ledger coding for all transactions. View of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2025-004 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Affordable Care Act (ACA) Personal Responsibility Education Program, Assistance Listing #93.092, Contract #90AK0075-03-03, Contract year: 09/30/23 – 09/29/25. Criteria: Reporting – The Uniform Guidance §200.508 and §200.510 requires management to prepare a schedule of expenditures of federal wards (SEFA) for the period covered by the auditee’s financial statements which must include the total federal awards expended and amounts expended by subrecipients. Management is responsible for establishing and maintaining an effective system of internal control sufficient to prepare the SEFA in accordance with Uniform Guidance. Condition and context: Civic Heart had not performed a reconciliation of federal expenditures resulting in errors in reported expenditures. Additionally, subrecipient expenditures were not identified for two programs. There was no independent review of the SEFA. During the audit of the 2025 fiscal year, it was noted that the SEFA for the year ended August 31, 2024 overstated expenditures for the HIV Prevention Activities – Non-Governmental Organizational Based program (AL #93.939) by $52,013. The 2024 SEFA included expenditures that were allowable in accordance with the grant agreement but not billed to the federal agency for reimbursement. An audit adjustment reducing the current year expenditures was required. Cause: Transitions in the accounting and management team resulted in failure to follow Civic Heart’s policies and procedures related to preparation and review of the SEFA. Effect: Adjustments of approximately $52,600 were required to properly report expenditures and adjustments of approximately $76,600 were required to properly report subrecipient expenditures on the SEFA. Recommendation: Emphasize adherence to established policies and procedures to reconcile the federal expenditures to the federal program revenue on a routine basis and formalize the independent review process for the SEFA and grant billings. View of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2024-003 – Material Weakness and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, HIV Prevention Activities Non-Governmental Organizational Based, Assistance Listing #93.939, Contract #6NU62PS924649-03-03, Contract year: 07/01/23 – 06/30/24, Contract #5NU62PS924649-04-00, Contract year: 07/01/24 – 06/30/25. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-03-03, Contract year: 08/27/23 – 08/26/24, Contract #NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Children’s Health Insurance Program, Assistance Listing #93.767, Contract #2Y2CMS331859-02-05, Contract year: 07/01/23 – 06/30/25. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/23 – 08/31/24, Contract #HHS000539700204 YPS, Contract year: 09/01/23 – 08/31/24, Contract #HHS000539700204 YPU, Contract year: 09/01/23 – 08/31/24. Criteria: Allowable costs – The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal award. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain shared costs are impacted as they are charged to the program based on the direct salary percentages. Repeat of finding #2023-001. Cause: Prior to the audit finding reported to management in May 2023, management had a lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown. Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2024-004 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, HIV Prevention Activities Non-Governmental Organizational Based, Assistance Listing #93.939, Contract #6NU62PS924649-03-03, Contract year: 07/01/23 – 06/30/24, Contract #5NU62PS924649-04-00, Contract year: 07/01/24 – 06/30/25. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-03-03, Contract year: 08/27/23 – 08/26/24, Contract #NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Children’s Health Insurance Program, Assistance Listing #93.767, Contract #2Y2CMS331859-02-05, Contract year: 07/01/23 – 06/30/25. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/23 – 08/31/24, Contract #HHS000539700204 YPS, Contract year: 09/01/23 – 08/31/24, Contract #HHS000539700204 YPU, Contract year: 09/01/23 – 08/31/24. Criteria: Allowable costs and period of performance – The Uniform Guidance, Subpart E Cost Principles, establishes costs principles which must be followed for expenditures to be allowable and requires a system of internal controls sufficient to ensure that costs are properly charged to the appropriate general ledger object and class code. The Uniform Guidance §200.309 period of performance requires expenditures be incurred during the period of the federal grant award in order to be allowable. Condition and context: During our testing of payroll, non-payroll and indirect cost pool transactions, we identified the following exceptions: Controls over allowable cost compliance – all major programs, In a sample of 59 non-payroll transactions tested for internal controls over compliance: One instance of annual advertising contract charged in full rather than establishing a prepaid expense for the eleven months after Civic Heart’s year-end of August 31, 2024. The applicable grant period is July 1, 2023 through June 30, 2025 and thus, only one month, or approximately $417, was outside the period of performance (AL #93.767 Children’s Health Insurance Program). One instance of $2,700 charged to wrong program. Allowable costs of the Navigator program were charged to Connecting Kids program due to coding to the wrong class code in the general ledger. (AL#93.767 Children’s Health Insurance Program (Connecting Kids). In a sample of 135 payroll transactions tested for internal controls over compliance: Four instances of errors in the amount of costs charged to class code due to a clerical error in the payroll allocation spreadsheet. (AL #93.959 Block Grants for Prevention and Treatment of Substance Abuse and AL #93.939 HIV Prevention Activities Non-Governmental Organizational Based). Other non-compliance: AL #93.767 Children’s Health Insurance Program: In a sample of 40 payroll or vendor charges, one instance of non-compliance with allowable cost compliance ($417). AL #93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges: In a sample of 42 payroll or vendor charges, one instance of non-compliance with allowable cost compliance ($2,700). AL #93.939 HIV Prevention Activities Non-Governmental Organizational Based: In a sample of 40 payroll or vendor charges, two instances of non-compliance with allowable costs due to charge to the wrong program. Controls over period of performance – all major programs. In a sample of 56 vendor transactions and 4 pay periods with grant beginning or ending dates during the audit period, we found: 13 instances of charging vendor costs to the wrong grant period. One instance of charging payroll costs to the wrong grant period. Other non-compliance: AL #93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges: In a sample of 14 vendor charges tested, we found 4 exceptions for charging to the wrong grant period (approximately $3,120). AL #93.939 HIV Prevention Activities Non-Governmental Organizational Based. In a sample of 27 vendor charges tested, we found 4 exceptions for charging to the wrong grant period (approximately $480). In a sample of four pay periods tested, we found one exception for charging costs to the wrong grant period (approximately $5,350). AL# 93.959 Block Grants for Prevention and Treatment of Substance Abuse. In a sample of 25 vendor charges tested, we found 5 exceptions for charging to the wrong grant period (approximately $660). Cause: Failure to follow Civic Heart’s policies and procedures related to review of coding for charges to the general ledger. Effect: Failure to follow established internal control policies and procedures resulted in errors and unallowable costs being charged to the grant. Questioned costs: $12,727. Recommendation: Emphasize adherence to established policies and procedures to ensure maintenance of payroll spreadsheets and reviews of coding for all transactions. View of responsible officials: Management agrees with the finding. See Corrective Action Plan.

Finding #2024-005 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Direct Federal Funding, HIV Prevention Activities Non-Governmental Organizational Based, Assistance Listing #93.939, Contract #6NU62PS924649-03-03, Contract year: 07/01/23 – 06/30/24, Contract #5NU62PS924649-04-00, Contract year: 07/01/24 – 06/30/25. Criteria: Special Tests and Provisions – Federal regulations require Civic Heart to provide referral services to HIV positive clients. Clients who refuse referrals must receive three documented attempts to receive the referral. If the referral is not accepted, the client must be referred to Disease Intervention Specialists (DIS) with the Centers for Disease Control and Prevention and the referral must be documented in the client’s file within 30 days. Condition and context: During our testing of 40 client case files, we noted one HIV positive client where there was no documentation of declined referrals sent to DIS. Cause: The finding occurred as a result of Civic Heart’s failure to follow its policies and procedures and federal regulations. Effect: Failure to retain referral documentation can result in unallowable costs. Recommendation: Re-emphasize procedures to ensure proper retention of referral documentation. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2023-001 – Material Weakness and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Allowable costs – The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Repeat of finding #2022-001. Cause: Prior to the audit finding reported to management in May 2023, management had a lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Management is working to implement new controls and procedures to fully comply with time and effort reporting as required by Uniform Guidance. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown. Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2023-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Direct Federal Funding, Continuum of Care Program, Assistance Listing #14.267, Contract # TX0392L6E002107, Contract year: 09/01/22 – 08/31/23. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Criteria: Procurement and Suspension and Debarment – The Uniform Guidance §180 prohibits contracting with parties that are suspended or debarred. The determination of whether the contracting party is suspended or debarred or otherwise excluded from participating in the transaction may be made by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration. Condition and context: Civic Heart amended its procurement policy in July 2023 to include a provision that Civic Heart will restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible. Although, Civic Heart was unable to provide evidence that such verification had been made during fiscal year 2023, we tested a sample of 13 vendors and found none to be suspended or debarred. Partial repeat of finding #2022-002. Cause: Civic Heart amended its procurement policy eleven months into fiscal year 2023 as a result of the 2022 audit finding. Although the policy was amended, the provision requiring verification of lack of suspension and debarment was not placed into service until after August 31, 2023. Effect: Failure to follow all requirements of Civic Heart’s procurement policy, including verification of lack of suspension and debarment could result in selecting vendors who are not eligible to be paid with federal monies. Recommendation: Implement procedures and provide training to personnel regarding verification that potential vendors are not debarred, suspended, or otherwise excluded from or ineligible for participation as required by their procurement policy. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2022-001 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Allowable costs ? The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ?200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must: 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Without sufficient controls, costs may be inappropriately charged to a federal funding stream. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Cause: Management?s lack of understanding regarding the requirements for charging payroll costs caused improper reporting of time incurred on the federal awards. Effect: Failure to establish controls for adherence with the Uniform Guidance for allowable costs may result in unallowed costs charged to the program. Questioned costs: Unknown Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2022-002 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Housing and Urban Development Direct Federal Funding Continuum of Care Program Assistance Listing #14.267 Contract #TX0392L6E002006, Contract year: 09/01/21 ? 08/31/22 U. S. Department of Health and Human Services Direct Federal Funding Sexual Risk Avoidance Education Assistance Listing #93.060 Contract #90SR0044-03-03, Contract year: 09/30/20 ? 06/30/22 Contract #90SR0120-01-00, Contract year: 09/30/20 ? 09/29/21 Contract #90SR0120-02-00, Contract year: 09/30/21 ? 09/29/22 Contract #90SR0157-01-01, Contract year: 09/30/21 ? 09/29/22 U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #HHS000539700204 YPI, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPS, Contract year: 09/01/21 ? 08/31/22 Contract #HHS000539700204 YPU, Contract year: 09/01/21 ? 08/31/22 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement decisions. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: Change Happens amended its procurement policy in 2022. The policy requires price or rate quotations for annual purchases greater than $15,000 (micro-purchase threshold), which does not comply with the Uniform Guidance micro-purchase threshold of $10,000. The policy also has no provision requiring determination of suspension or debarment of vendors as required by the Uniform Guidance. Cause: The finding occurred as a result of Change Happens adopting a policy that does not fully comply with the provisions of ?200.318 of the Uniform Guidance. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update the procurement policy to be in compliance with the Uniform Guidance with respect to the micro-purchase threshold and suspension/disbarment requirements. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2022-003 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Direct Federal Funding Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges Assistance Listing #93.332 Contract #NAVCA210403-01-01, Contract year: 08/27/21 ? 08/26/22 Contract #NAVCA210403-02-00, Contract year: 08/27/22 ? 08/26/23 Criteria: Reporting ? The Federal Funding and Transparency Act (FFATA) requires recipients of non-Recovery Act funded grants and cooperative agreements to report subawards of $30,000 or more. Condition and context: Change Happens did not file the required FFATA reporting for the 7 subawards over $30,000. Repeat of finding #2021-010 for the 2021 major program, Assistance Listing #93.092. Cause: The Corrective Action Plan for finding #2021-010 was not implemented for this program. Effect: Non-compliance with federal reporting requirements. Questioned costs: None Recommendation: Develop a process for FFATA reporting to ensure timely reporting for all federal programs, where applicable, and provide training to personnel regarding FFATA reporting requirements. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2021-005 ? Significant Deficiency in Cash Disbursements Applicable federal programs: U. S. Department of Health and Human Services Affordable Care Act (ACA) Personal Responsibility Education Program Assistance Listing #93.092 Contract #?s: 90AK0051-05-00 and 90AK0051-06-03 Contract years: 09/30/19 ? 09/29/20 and 09/30/20 ? 06/30/22 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission: Block Grants for Prevention & Treatment of Substance Abuse Assistance Listing #93.959 Contract #?s: HHS000539700008, HHS000077600004, HHS000539700103, HHS000539700180, and HHS000539700052 Contract year: 09/01/20 ? 08/31/21 U. S. Department of Housing and Urban Development Continuum of Care Program Assistance Listing #14.267 Contract #: TX0392L6E001905 Contract year: 09/01/20 ? 08/31/21 Criteria: Financial Management ? The management of Change Happens is responsible for establishing and maintaining an effective system of internal control to ensure adequate segregation of duties is maintained over the cash disbursement process so that authorization, recording, custody of and access to assets, and supervisory reviews be assigned to different individuals. Condition and context: The finding reported as #2021-002 applies to the federal awards. Cause and effect: See finding #2021-002. Repeat of finding #2020-003. Questioned costs: Unknown Recommendation: See finding 2021-002. Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2021-006 ? Significant Deficiency in Government Grant Revenue Applicable federal programs: U. S. Department of Health and Human Services Affordable Care Act (ACA) Personal Responsibility Education Program Assistance Listing #93.092 Contract #?s: 90AK0051-05-00 and 90AK0051-06-03 Contract years: 09/30/19 ? 09/29/20 and 09/30/20 ? 06/30/22 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #?s: HHS000539700008, HHS000077600004, HHS000539700103, HHS000539700180, and HHS000539700052 Contract year: 09/01/20 ? 08/31/21 U. S. Department of Housing and Urban Development Continuum of Care Program Assistance Listing #14.267 Contract #: TX0392L6E001905 Contract year: 09/01/20 ? 08/31/21 Criteria: Financial Management ? The Uniform Guidance ?200.303(a) states that Change Happens must establish and maintain effective internal control over the federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the award. Condition and context: The finding reported as #2021-004 applies to the federal awards. Cause and effect: See finding #2021-004. Questioned costs: Unknown Recommendation: See finding #2021-004. Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2021-007 ? Material Weakness and Other Noncompliance for Assistance Listing #93.092 and #14.267 Applicable federal programs: U. S. Department of Health and Human Services Affordable Care Act (ACA) Personal Responsibility Education Program Assistance Listing #93.092 Contract #?s: 90AK0051-05-00 and 90AK0051-06-03 Contract years: 09/30/19 ? 09/29/20 and 09/30/20 ? 06/30/22 U. S. Department of Housing and Urban Development Continuum of Care Program Assistance Listing #14.267 Contract #: TX0392L6E001905 Contract year: 09/01/20 ? 08/31/21 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: We reviewed all fiscal year vendor expenditures and found one annual purchase that exceeded the Uniform Guidance small purchase threshold of $250,000; testing of the expenditure revealed that office rent of approximately $373,000 had not been competitively procured in a manner consistent with the requirements of the Uniform Guidance. Rent reimbursed under Assistance Listing #93.092 related to this contract was $11,456 during the grant period. Rent reimbursed under Assistance Listing #14.267 related to this contract was $13,870 during the grant period. Additionally, in a sample of 15 expenditures greater than $1,000, we found no documentation of performance of procurement procedures in accordance with Change Happens? procurement policy. Repeat of finding #2020-008. Cause: Change Happens? procurement policies make reference to buying from a frequent buyer catalog or using competitive purchasing. The policy states that vendors listed in this catalog are those that the organization has found to have quality products, good pricing, timely delivery and have a good reputation within the community. For all purchases greater than $1,000 that are not in the frequent buyer catalog, three bids must be obtained. There does not appear to be a procurement process to determine which vendors are included in the listing, nor do the vendors appear to be determined from inclusion on a state or local intergovernmental agreement. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance and a lack of documented procurement decisions could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update procurement policy to be in compliance with the Uniform Guidance. Document procurement decisions reflecting the rationale for the method of procurement, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2021-008 ? Material Weakness and Material Noncompliance for Assistance Listing #93.959 Applicable federal program: U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #?s: HHS000539700008, HHS000077600004, HHS000539700103, HHS000539700180, and HHS000539700052 Contract year: 09/01/20 ? 08/31/21 Criteria: See finding #2021-007. Condition and context: See finding #2021-007. The finding reported as #2021-008 is considered material noncompliance for Assistance Listing #93.959 and thus, must be reported separately for purposes of filing with the Federal Audit Clearinghouse. Rent reimbursed under Assistance Listing #93.959 was $158,697 during the grant period. Cause: See finding #2021-007. Effect: See finding #2021-007. Questioned costs: Unknown Recommendation: See finding #2021-007. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2021-009 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Health and Human Services Affordable Care Act (ACA) Personal Responsibility Education Program Assistance Listing #93.092 Contract #?s: 90AK0051-05-00 and 90AK0051-06-03 Contract years: 09/30/19 ? 09/29/20 and 09/30/20 ? 06/30/22 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.959 Contract #?s: HHS000539700008, HHS000077600004, HHS000539700103, HHS000539700180, and HHS000539700052 Contract year: 09/01/20 ? 08/31/21 U. S. Department of Housing and Urban Development Continuum of Care Program Assistance Listing #14.267 Contract #: TX0392L6E001905 Contract year: 09/01/20 ? 08/31/21 Criteria: Allowable Costs ? Section 200.303 of the Uniform Guidance indicates that the organization must 1) establish and maintain an effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal awards and 2) evaluate and monitor the compliance with statutes, regulations, and terms and conditions of the federal awards. Take prompt action when instances of noncompliance are identified. Condition and context: Change Happens utilizes timesheets and square footage to prepare monthly salary allocations to allocate monthly shared facility allocations to each grant. A sample of 2 monthly facility allocations revealed 1 instance where the amount charged to Assistance Listing #93.959 was not consistent with the hours charged on the timesheet. Cause: The percentages used to prepare the monthly facility allocation journal entry were different from the hours allocated on the timesheet. Journal entry review procedures did not identify the allocation errors. Effect: Failure to appropriately update and review allocation worksheets could result in unallowed costs. Questioned costs: $22 Recommendation: Strengthen journal entry review controls to ensure that percentages used for charges to the grant are supported by the underlying timesheets that match the allocation. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2021-010 ? Significant Deficiency and Other Noncompliance Applicable federal programs: U. S. Department of Health and Human Services Affordable Care Act (ACA) Personal Responsibility Education Program Assistance Listing #93.092 Contract #?s: 90AK0051-05-00 and 90AK0051-06-03 Contract years: 09/30/19 ? 09/29/20 and 09/30/20 ? 06/30/22 Criteria: Reporting ? The Federal Funding and Transparency Act (FFATA) requires recipients of non-Recovery Act funded grants and cooperative agreements to report subawards of $25,000 or more. Condition and context: Change Happens did not file the required FFATA reporting for a subaward over $25,000. Cause: Program personnel were not aware of the FFATA reporting requirement. Effect: Non-compliance with federal reporting requirements. Questioned costs: None Recommendation: Provide additional training to personnel to understand FFATA reporting requirements. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2020-005 ? Material Weakness in Preparation of the Schedule of Expenditures of Federal Awards (SEFA) This finding impacts all federal awards. Criteria: Management is responsible for establishing and maintaining an effective system of internal control over financial reporting, including preparation of the SEFA. Condition and context: Change Happens? procedures for financial reporting of the SEFA are not sufficient to ensure that errors would be detected and corrected in a timely manner. Audit revisions to the SEFA were required to include expenditures for three new federal grants. Additionally, revisions of approximately $165,000 were required to increase current year expenditures due to errors in reversal of prior year accrued receivables that were never actually submitted for reimbursement. Repeat of finding #2019-002. Cause and effect: Procedures are not sufficient to ensure that the SEFA includes all federal grants and all expenditures. As a result, adjustments were identified to properly report expenditures reported on the SEFA. The failure to adequately establish and maintain effective internal controls over financial reporting resulted in misstatements to Change Happens? SEFA. Recommendation: Policies and procedures should be developed to ensure that all federal expenditures are properly reflected on the SEFA. Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2020-006 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Health and Human Services Teenage Pregnancy Prevention Program CFDA #93.297 Contract #?s: 1 TP1AH000187-01-00 and 1 TP1AH000187-02-00 Contract years: 07/01/19 ? 06/30/20 and 07/01/20 ? 06/30/21 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission: Block Grants for Prevention & Treatment of Substance Abuse CFDA #93.959 Contract #?s: HHS000539700008, HHS000077600004, HHS000539700103, HHS000539700180, HHS000539700052, and 2016-048205-003 Contract year: 09/01/19 ? 08/31/20 U. S. Department of Housing and Urban Development Continuum of Care Program CFDA #14.267 Contract #: TX0392L6E01804 Contract year: 09/01/19 ? 08/31/20 Criteria: Reporting ? Management is responsible for establishing and maintaining an effective system of internal control over government grant reporting to ensure all expenditures are properly stated in the various required grant reports in the correct period and that government grant revenue and receivables are properly reflected in the financial statements. Condition and context: The finding reported as #2020-001 resulted in adjustments to reported grant expenditures for the year ended August 31, 2020. Cause and effect: See finding #2020-001. Questioned costs: None Recommendation: See finding #2020-001. Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2020-007 ? Significant Deficiency in Cash Disbursements Applicable federal programs: U. S. Department of Housing and Urban Development Continuum of Care Program CFDA #14.267 Contract #: TX0392L6E01804 Contract year: 09/01/19 ? 08/31/20 U. S. Department of Health and Human Services Teenage Pregnancy Prevention Program CFDA #93.297 Contract #?s: 1 TP1AH000187-01-00 and 1 TP1AH000187-02-00 Contract years: 07/01/19 ? 06/30/20 and 07/01/20 ? 06/30/21 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission: Block Grants for Prevention & Treatment of Substance Abuse CFDA #93.959 Contract #?s: HHS000539700008, HHS000077600004, HHS000539700103, HHS000539700180, HHS000539700052, and 2016-048205-003 Contract year: 09/01/19 ? 08/31/20 Criteria: Effective internal control requires that certain responsibilities such as authorization of transactions, recording of transactions in the accounting records, custody of and access to assets, and supervisory reviews be assigned to separate individuals. Such duties have not been segregated with respect to vendor cash disbursements and could result in unauthorized disbursements due to fraud or error. Condition and context: The finding reported as #2020-003 applies to the federal awards. Cause and effect: See finding #2020-003. Questioned costs: Unknown Recommendation: See finding 2020-003. Views of responsible officers and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2020-008 ? Material Weakness and Other Noncompliance Applicable federal programs: U. S. Department of Health and Human Services Teenage Pregnancy Prevention Program CFDA #93.297 Contract #?s: 1 TP1AH000187-01-00 and 1 TP1AH000187-02-00 Contract years: 07/01/19 ? 06/30/20 and 07/01/20 ? 06/30/21 U. S. Department of Housing and Urban Development Continuum of Care Program CFDA #14.267 Contract #: TX0392L6E01804 Contract year: 09/01/19 ? 08/31/20 Criteria: Procurement ? The Uniform Guidance ?200.318 states that nonprofit organizations must: ? Have written procurement procedures that conform to federal and state laws and regulations as identified in the Uniform Guidance, Subtitle III Procurement Standards and other specific contractual requirements. ? Maintain records sufficient to detail the history of procurement. The records must include the rationale for the procurement method, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Condition and context: We reviewed all fiscal year vendor expenditures and found one annual purchase that met the Uniform Guidance small purchase threshold of $250,000; testing of the expenditure revealed that office rent in the amount of approximately $373,000 had not been competitively procured in a manner consistent with the requirements of the Uniform Guidance. Rent to CFDA #93.297 related to this contract during the grant period was $9,518. Rent to CFDA #14.267 related to this contract during the grant period was $12,809. Additionally, in a sample of 15 expenditures greater than $1,000, we found no documentation of performance of procurement procedures in accordance with Change Happens? procurement policy. Cause: Change Happens? procurement policies make reference to buying from a frequent buyer catalog or using competitive purchasing. The policy states that vendors listed in this catalog are those that the organization has found to have quality products, good pricing, timely delivery and have a good reputation within the community. There does not appear to be a procurement process to determine which vendors are included in the listing, nor do the vendors appear to be determined from inclusion on a state or local intergovernmental agreement. For all purchases greater than $1,000 that are not in the frequent buyer catalog, three bids must be obtained. Effect: Failure to have a procurement policy that is in accordance with the Uniform Guidance and a lack of documented procurement decisions could result in non-compliance and lack of competition in selected vendors. Questioned costs: Unknown Recommendation: Update procurement policy to be in compliance with the Uniform Guidance. Document procurement decisions reflecting the rationale for the method of procurement, selection of contract type, contractor or vendor selection or rejection, and the basis for the contracted price. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2020-009 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Teenage Pregnancy Prevention Program CFDA #93.297 Contract #?s: 1 TP1AH000187-01-00 and 1 TP1AH000187-02-00 Contract years: 07/01/19 ? 06/30/20 and 07/01/20 ? 06/30/21 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission: Block Grants for Prevention & Treatment of Substance Abuse CFDA #93.959 Contract #?s: HHS000539700008, HHS000077600004, HHS000539700103, HHS000539700180, HHS000539700052, and 2016-048205-003 Contract year: 09/01/19 ? 08/31/20 Criteria: Allowable costs ? Management is responsible for having an internal control system in place to ensure that only allowable costs in accordance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ?200.400 are recorded and allocated to federal awards. An effective internal control system includes a review of transactions for verification of accuracy as to amount and period and also requires retention of documentation, supporting the transaction to evidence proper approval, and to provide accurate reporting of transactions. Condition and context: In a sample of 46 vendor expenditures (24 from CFDA #93.297 and 22 from CFDA #93.959 and #93.788), we identified 1 sample unit was recorded as expended based on quotes received from the vendor but never purchased, and 1 sample unit where the amount recorded as expended was based on a quote, but the actual invoice was less than the quote provided. Cause: Expenditures were accrued at year end based on quotes received from vendors instead of actual invoices. In one case, the purchase never occurred and in the other case the invoice paid after year end was less than the quote that was provided and accrued. Effect: Failure to accrue expenditures based on invoices provided resulted in amounts being billed erroneously to the grants. Questioned costs: $3,816 Recommendation: Implement policies and procedures to only accrue as payable those goods and services received and accrue amounts supported by vendor invoices. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2020-010 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Health and Human Services Teenage Pregnancy Prevention Program CFDA #93.297 Contract #?s: 1 TP1AH000187-01-00 and 1 TP1AH000187-02-00 Contract years: 07/01/19 ? 06/30/20 and 07/01/20 ? 06/30/21 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission: Block Grants for Prevention & Treatment of Substance Abuse CFDA #93.959 Contract #?s: HHS000539700008, HHS000077600004, HHS000539700103, HHS000539700180, HHS000539700052, and 2016-048205-003 Contract year: 09/01/19 ? 08/31/20 U. S. Department of Housing and Urban Development Continuum of Care Program CFDA #14.267 Contract #: TX0392L6E01804 Contract year: 09/01/19 ? 08/31/20 Criteria: Allowable costs ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), ?200.430 requires that charges to awards for salaries and wages be based on records that accurately reflect the work performed. These records must 1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; 2) reasonably reflect the total activity for which the employee is compensated; 3) comply with the established accounting policies and practices of the agency; and 4) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one activity. Change Happens? procedures for allocating costs are not sufficient to ensure that costs are appropriately allocated amongst federal funding streams. Condition and context: Change Happens utilizes timesheets to prepare monthly salary allocations to each grant. A sample of 66 payroll charges to the general ledger revealed 1 instance where the amount charged to CFDA #93.297 was not consistent with the hours charged on the timesheet. Journal entry review procedures are not sufficient to identify allocation errors. Cause: The percentages used to prepare the monthly allocation journal entry were different from the hours allocated on the timesheet. The explanation indicated that there was a change in the individual?s budgeted time that was not reflected on the timesheet and the amount charged to the grant was based on budget instead of actual time spent. Effect: Failure to charge awards for salaries and wages based on records that accurately reflect the work performed could result in unallowed costs. Questioned costs: $41 Recommendation: Strengthen journal entry review controls to ensure that percentages used for charges to the grant are supported by the underlying timesheets that match the allocation and are based on actual time spent. Views of responsible officers and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2020-011 ? Significant Deficiency and Other Noncompliance Applicable federal program: U. S. Department of Housing and Urban Development Continuum of Care Program CFDA #14.267 Contract #: TX0392L6E01804 Contract year: 09/01/19 ? 08/31/20 U. S. Department of Health and Human Services Teenage Pregnancy Prevention Program CFDA #93.297 Contract #?s: 1 TP1AH000187-01-00 and 1 TP1AH000187-02-00 Contract years: 07/01/19 ? 06/30/20 and 07/01/20 ? 06/30/21 U. S. Department of Health and Human Services Passed through Texas Health and Human Services Commission: Block Grants for Prevention & Treatment of Substance Abuse CFDA #93.959 Contract #?s: HHS000539700008, HHS000077600004, HHS000539700103, HHS000539700180, HHS000539700052, and 2016-048205-003 Contract year: 09/01/19 ? 08/31/20 Criteria: Period of Performance ? Uniform Guidance ?200.309 indicates that only allowable costs incurred during the period of performance may be charged to the federal award. Costs incurred before the start date and after the end date of the federal award may not be charged to the award without prior approval. Condition and context: During our testing of 46 federal grant vendor expenditures, we identified 3 expenditures coded to an incorrect period based on when the goods and services were received resulting in charges to the grant outside the contract period. Cause: There is not an effective system of internal controls to ensure that expenses are recorded in the appropriate period. Two of the expenditures were credit card charges that had been incurred in the previous fiscal year, but were not recorded until the following fiscal year when the credit card statement was processed. One expenditure was for equipment purchases that were improperly accrued at the end of the year, but not received or paid until the following fiscal year. Effect: Failure to have effective internal controls over recording expenses to the correct period resulted in costs charged to grants outside of the period of performance. Questioned costs: $3,000 Recommendation: Provide additional training on the review of proper period for recognition of expense transactions. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

U.S. Department of Housing and Urban Development 14.267 ? Office of Community Planning and Development ? Continuum of Care Program Federal Award: TX0392L6E001703 2018-2019 Funding Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 24 CFR Section 578.78 and 24 CFR Section 578.59, the Organization must have internal controls to ensure the compliance with matching and earmarking requirements, to ensure that those requirements are met for each grant. Condition: The Organization did not have proper procedures in place to timely review that matching costs incurred were recorded in the financial statements based on grant requirements. Although the matching requirements had been met based upon timesheets prepared by contract staff, staff and volunteers, the costs were not completely recorded in the financial records. As a result, the Organization?s financial statements did not reflect that the Organization had met the matching requirement required by the grants. In addition, there was no control in place to review budget to actual costs to ensure the earmarking requirement was met. Effect: Without internal controls operating effectively, it is possible that the Organization would be at risk to be out of compliance with the matching and earmarking compliance requirements of the program which could result in return of grant funds or inability to utilize all available grant funding. Cause: Turnover in the Organization?s CFO position caused a lack of proper close-out procedures, including no reconciliation of matching and in-kind expenses between the detail records, financial records and the grants reports being performed. In addition, there were no reconciliations performed during the fiscal year related to this compliance area. Questioned Costs: None. Auditors? Recommendation: The Organization should timely review and reconcile program reports to financial reporting to ensure that matching costs are recorded accurately and timely. Management should review the budget to actual in its financial reporting to ensure that the Organization is in compliance with matching and earmarking requirements. Views of Responsible Officials: The match reporting has been added to the month end checklist as well as the monthly budget summary and is reviewed and approved by the CEO and the CFO in preparation for the monthly budget meetings. The monthly journal entries will be reviewed and approved by the CFO.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION