EIN: 821852606
UEI: Y2KNANNC9FK5
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 29, 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 December 29, 2023, which was (965 days ago).
What is a management decision? →Finding 2022-001 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917 and 21NU2RGH001917C6 Material Weakness/ Material Noncompliance Reporting Condition: During our testing of reporting, we noted that no formal review process was in place to independently review the FFR SF-425 (grant numbers 21NU2RGH001917 and 21NU2RGH001917C6 filed October 18, 2022) prior to filing the report with the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of the FFR SF-425 prior to report submission. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed FFR SF-425 report. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the FFR SF-425 report filing to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-001: Reporting - Material Weakness/Material Noncompliance Management?s Response: Our commitment to maintaining strong financial controls and compliance with grant reporting requirements remains unwavering. In response to the audit finding and in our ongoing efforts to continually improve our internal controls and procedures, we have taken the following corrective actions to address the identified lack of a formal review process for the FFR SF-425 prior to filing the report with the U.S. Department of Health and Human Services, Centers for Disease Control: Design and Implementation of Review Process: We have developed a structured review process for all FFR SF-425 reports before their submission to the U.S. Department of Health and Human Services, Centers for Disease Control. The process includes a comprehensive review by an independent party who possesses the necessary expertise and knowledge in grant reporting requirements. Reviewer Qualifications and Training: We have identified individuals within our organization who possess the requisite knowledge and experience to conduct a thorough review of the FFR SF-425 reports. These reviewers have received specialized training to ensure they understand the specific grant reporting requirements, compliance regulations, and relevant policies. Documentation and Tracking: To ensure accountability and a transparent review process, we have implemented a system for documenting and tracking the review activities performed on each FFR SF-425 report. This allows us to monitor the completion of reviews, track any identified issues or concerns, and maintain an audit trail for future reference. Review Completion Timeline: We have established a specific timeline for completing the review of FFR SF-425 reports. This ensures that the review process occurs in a timely manner, minimizing any delays in submitting accurate and compliant reports to the funding agency. Continuous Improvement and Monitoring: We recognize the importance of continuously improving our processes and maintaining ongoing compliance. Therefore, we will conduct periodic reviews and assessments of our review process to identify any areas for enhancement. Additionally, we will closely monitor the effectiveness of the new process to ensure its efficiency and adherence to the required standards. Anticipated Completion Date: Already Implemented Responsible Contact Person: Dr Malik Mamoon Munir, Global Operations Officer, +1 678-580-0853
Finding 2022-002 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Procurement and Suspension and Debarment Condition: During our testing of procurement, suspension, and debarment, we noted that the Organization?s procurement policy was not in compliance with Uniform Guidance Procurement Standards. Our testing also revealed no documentation was provided to verify that the vendor was reviewed within the SAM Exclusion system prior to contracting. Criteria: Since the Organization receives federal funding, it must update its procurement policy to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart D ? 200.317-32. Additionally, it must review vendor debarment or suspension status prior to contracting to ensure compliance with the Uniform Guidance Procurement Standards, government regulations 2 CFR Part 200 Subpart C ? 200.214 and 2 CFR Part 180. Cause: Oversight of updating the Organization?s established procurement policies and procedures, and oversight in reviewing vendor suspension and debarment status within the SAM Exclusion website. Effect: Failure to update the Corporation?s policies and procedures may result in procurement and purchases not meeting compliance requirements, and failure to review vendor suspension and debarment status within the SAM Exclusion website may result in payments to ineligible vendors. Accordingly, the Organization will not being in compliance with the requirements per Uniform Guidance Procurement Standards. Questioned Costs: None noted. Recommendation: We recommend that the Organization review and update its established policies, procedures and controls to ensure the procurement policy is in alignment with Uniform Guidance Procurement Standards, and we also recommend that the Organization verify vendor status within the SAM Exclusion website for debarment or suspension status. Management?s Response: See Corrective Action Plan
Finding 2022-002: Procurement and Suspension and Debarment - Material Noncompliance Management?s Response: Our commitment to maintaining strong financial controls and compliance with grant reporting requirements remains unwavering. In response to the audit finding and in our ongoing efforts to continually improve our internal controls and procedures, we have developed a comprehensive corrective action plan to address the noncompliance and strengthen our procurement and suspension/debarment processes: Procurement Policy Update: We have initiated a review and update of our procurement policy to ensure alignment with the Uniform Guidance Procurement Standards. This updated policy will incorporate the necessary provisions and requirements outlined in government regulations. Vendor Review Process: We have implemented a formal process to review vendor suspension and debarment status within the SAM Exclusion system prior to contracting. This process will be integrated into our procurement procedures to ensure compliance with the Uniform Guidance Procurement Standards. Training and Awareness: We will provide training sessions to staff involved in procurement processes, emphasizing the importance of adhering to the updated procurement policy and conducting thorough vendor reviews within the SAM Exclusion system. This training will enhance their understanding of the regulatory requirements and their roles in compliance. Documentation and Record-Keeping: We have established procedures for documenting and retaining records of vendor reviews within the SAM Exclusion system. This documentation will serve as evidence of our due diligence and compliance with the Uniform Guidance Procurement Standards. Monitoring and Internal Controls: We will strengthen our monitoring procedures and internal controls to ensure ongoing compliance with procurement and suspension/debarment requirements. Regular reviews will be conducted to verify adherence to the updated procurement policy and vendor review processes. Continuous Improvement: We are committed to continuous improvement in our procurement and suspension/debarment processes. We will establish a mechanism for periodic reviews of our policies, procedures, and controls to identify areas for enhancement and ensure they remain effective and aligned with the Uniform Guidance Procurement Standards. Anticipated Completion Date: Already Implemented Responsible Contact Person: Dr Malik Mamoon Munir, Global Operations Officer, +1 678-580-0853
Finding 2022-003 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Cash Management Condition: During our testing of cash management, we noted that no formal control process was in place to independently review cost reimbursement reports and submissions to the Payment Management Station (PMS) for reimbursement from the U.S. Department of Health and Human Services, Centers for Disease Control. Criteria: Uniform Guidance requires that internal controls be established and followed for the financial reporting process (2 CFR ? 200.303(a)). Cause: No established control process for independent review of cost reimbursement reports and submissions to the PMS. Effect: Errors may not be caught on a timely basis resulting in an incorrectly filed reports and cost reimbursements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish and document policies, procedures and controls regarding the preparation of the cost reimbursement reports and submission to the PMS to ensure compliance with Uniform Guidance. Management?s Response: See Corrective Action Plan
Finding 2022-003: Cash Management - Material Noncompliance Management?s Response: Our commitment to maintaining strong financial controls and compliance with grant reporting requirements remains unwavering. In response to the audit finding and in our ongoing efforts to continually improve our internal controls and procedures, we have taken the following corrective actions to address the identified noncompliance and strengthen our cash management controls: Development and Implementation of Control Process: We have developed a formal control process to ensure the independent review of all cost reimbursement reports and submissions to the PMS. This process includes assigning qualified individuals who possess the necessary expertise and knowledge to conduct a thorough review of the reports and submissions. Reviewer Qualifications and Training: We have identified individuals within our organization who have the required knowledge and experience in cash management processes and grant reporting. These reviewers have undergone specialized training to enhance their understanding of the Uniform Guidance requirements, compliance regulations, and relevant policies. Documentation and Tracking: To ensure accountability and transparency, we have implemented a system for documenting and tracking the review activities performed on each cost reimbursement report and submission. This enables us to monitor the completion of reviews, track identified issues or errors, and maintain an audit trail for future reference. Timely Review and Reporting: We have established a specific timeline for completing the review of cost reimbursement reports and submissions. This ensures that any errors or discrepancies are identified and rectified promptly, minimizing the risk of incorrectly filed reports and cost reimbursements. Ongoing Monitoring and Improvement: We recognize the importance of continuous monitoring and improvement of our cash management controls. We will conduct periodic reviews and assessments of the control process to identify areas for enhancement and ensure its effectiveness and adherence to the required standards. Anticipated Completion Date: Already Implemented Responsible Contact Person: Dr Malik Mamoon Munir, Global Operations Officer, +1 678-580-0853
Finding 2022-004 U.S. Department of Health and Human Services, Centers for Disease Control and Prevention - Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security, CFDA #?s 93.318, Grant Numbers 21NU2RGH001917, 21NU2RGH001917C6 and Contract Number PO20-00454 Noncompliance Written Documentation of Uniform Guidance Policies and Procedures Condition: During our review of controls, we noted no formal written policies for compliance with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Criteria: Uniform Guidance requires that internal controls be established for compliance requirements (2 CFR 200 ?Post Federal Award Requirements, and Subpart E?Cost Principles) Cause: No established written documentation for compliance with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. Effect: Possible non-compliance with grant agreements. Questioned Costs: None noted. Recommendation: We recommend that the Organization establish written policies and procedures with 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles to ensure compliance with Uniform Guidance, as applicable. Management?s Response: See Corrective Action Plan
Finding 2022-004: Written Documentation of Uniform Guidance Policies and Procedures - Material Noncompliance Management?s Response: Our commitment to maintaining strong financial controls and compliance with grant reporting requirements remains unwavering. In response to the audit finding and in our ongoing efforts to continually improve our internal controls and procedures, we have taken the following corrective actions to address the identified noncompliance and strengthen our internal controls for compliance: Policy Development: We have initiated the development of comprehensive written policies and procedures that align with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. These policies will outline the necessary steps and guidelines for compliance with grant agreements and cost principles. Policy Review and Approval Process: We have established a formal process for reviewing and approving the written policies and procedures. This process includes involving relevant stakeholders, such as legal counsel, finance, program management, and other key departments, to ensure comprehensive coverage of the requirements and adequate alignment with our operations. Policy Implementation and Training: As the policies and procedures are finalized and approved, we will implement a robust communication and training program to ensure awareness and understanding of the requirements among our staff. This will include training sessions, workshops, and clear dissemination of the written policies throughout the organization. Policy Maintenance and Review: We recognize the importance of regularly maintaining and reviewing our policies and procedures to keep them up to date with any changes in the regulatory environment. We will establish a periodic review process to ensure ongoing compliance and make necessary updates as required. Documentation and Record-Keeping: As part of our enhanced internal controls, we will implement a system for 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. This will provide evidence of our adherence to the written policies and procedures. Anticipated Completion Date: Already Implemented Responsible Contact Person: Dr Malik Mamoon Munir, Global Operations Officer, +1 678-580-0853
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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