EIN: 824302000
UEI: UTKXMW296FB4
Audited by: Pile CPAs
Oversight agency: 21 [Department of the Treasury]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 14, 2025. 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 April 14, 2026 (142 days ago).
What is a management decision? →Finding 2024-001 Financial Close Process Type of Finding Material Weakness in Internal Control over Financial Reporting Condition During the audit, it was noted that the Organization lacked a robust financial close and review process. This deficiency resulted in material audit adjustments across key financial statement accounts, including revenue, accounts payable, accrued expenses, deferred revenue, nets assets, and related activity accounts. These adjustments were proposed by the auditors and subsequently recorded by management in order to fairly present the financial statements in accordance with generally accepted accounting principles. The extent and materiality of the adjustments indicate that the Organization's existing closing procedures were insufficient to identify and correct errors prior to the audit. Criteria Management is responsible for adopting sound accounting policies and establishing and maintaining a system of internal control for the fair presentation of the basis financial statements in accordance with accounting principles generally accepted in the United States of America. Cause The underlying cause appears to be a combination of a lack of formalized month-end and year-end close procedures. Without clearly defined timelines, responsibilities, and communication protocols, important financial information may not have been shared or reviewed in a timely manner, increasing the risk of errors or omissions during the close process. Possible of Known Effect Because of this gap in process and communication, material misstatements were present in the Organization’s financial records and required auditor-proposed adjustments to ensure the financial statements were fairly stated. While these corrections were made before issuance, the absence of a consistent and well-coordinated close process creates a risk that financial statements could be misstated in future periods if similar issues are not identified in advance. Recommendation We recommend that the Organization develop and implement a formal financial close process that includes clear timelines, assigned responsibilities, and review steps for all key account areas. In addition, improving communication protocols between program staff and accounting staff particularly around the timing and completeness of financial information will help ensure that the financial records are accurate and complete prior to the start of the audit. Views of Responsible Officials The Organization acknowledges this finding and agrees with the auditor’s assessment regarding the need for a more robust financial close and review process. We recognize that the absence of such a process contributed to the material audit adjustments noted during the engagement. Management and the Board are committed to strengthening internal controls and financial oversight to ensure that future financial statements are materially accurate and compliant with GAAP prior to audit. We are confident that the measures underway will address the deficiency and prevent recurrence.
Show full finding ▾Hide full finding ▴Finding 2024-001 Financial Close Process Type of Finding Material Weakness in Internal Control over Financial Reporting Condition During the audit, it was noted that the Organization lacked a robust financial close and review process. This deficiency resulted in material audit adjustments across key financial statement accounts, including revenue, accounts payable, accrued expenses, deferred revenue, nets assets, and related activity accounts. These adjustments were proposed by the auditors and subsequently recorded by management in order to fairly present the financial statements in accordance with generally accepted accounting principles. The extent and materiality of the adjustments indicate that the Organization's existing closing procedures were insufficient to identify and correct errors prior to the audit. Criteria Management is responsible for adopting sound accounting policies and establishing and maintaining a system of internal control for the fair presentation of the basis financial statements in accordance with accounting principles generally accepted in the United States of America. Cause The underlying cause appears to be a combination of a lack of formalized month-end and year-end close procedures. Without clearly defined timelines, responsibilities, and communication protocols, important financial information may not have been shared or reviewed in a timely manner, increasing the risk of errors or omissions during the close process. Possible of Known Effect Because of this gap in process and communication, material misstatements were present in the Organization’s financial records and required auditor-proposed adjustments to ensure the financial statements were fairly stated. While these corrections were made before issuance, the absence of a consistent and well-coordinated close process creates a risk that financial statements could be misstated in future periods if similar issues are not identified in advance. Recommendation We recommend that the Organization develop and implement a formal financial close process that includes clear timelines, assigned responsibilities, and review steps for all key account areas. In addition, improving communication protocols between program staff and accounting staff particularly around the timing and completeness of financial information will help ensure that the financial records are accurate and complete prior to the start of the audit. Views of Responsible Officials The Organization acknowledges this finding and agrees with the auditor’s assessment regarding the need for a more robust financial close and review process. We recognize that the absence of such a process contributed to the material audit adjustments noted during the engagement. Management and the Board are committed to strengthening internal controls and financial oversight to ensure that future financial statements are materially accurate and compliant with GAAP prior to audit. We are confident that the measures underway will address the deficiency and prevent recurrence.
Finding 2024-01 Financial Close Process Condition: During the audit, it was noted that the Organization lacked a robust financial close and review process. This deficiency resulted in material audit adjustments across key financial statement accounts, including revenue, accounts payable, accrued expenses, deferred revenue, nets assets, and related activity accounts. These adjustments were proposed by the auditors and subsequently recorded by management in order to fairly present the financial statements in accordance with generally accepted accounting principles. The extent and materiality of the adjustments indicate that the Organization's existing closing procedures were insufficient to identify and correct errors prior to the audit. Corrective Actions Taken or Planned: The Organization acknowledges this finding and agrees with the auditor’s assessment regarding the need for a more robust financial close and review process. We recognize that the absence of such a process contributed to the material audit adjustments noted during the engagement. Management and the Board are committed to strengthening internal controls and financial oversight to ensure that future financial statements are materially accurate and compliant with GAAP prior to audit. We are confident that the measures underway will address the deficiency and prevent recurrence. To address this finding, the Organization will implement a comprehensive monthly and quarterly financial close and review process to ensure accuracy, timeliness, and compliance with GAAP prior to the annual audit. Specific actions include: 1. Monthly Close Procedures - Develop and document a formal month-end closing checklist. - Reconcile all key accounts monthly (cash, accounts payable, receivables, accrued expenses, deferred revenue, and net assets). - Require dual review and sign-off from the Accountant (FTM) and Co-Executive Director. 2. Quarterly Financial Review - Conduct quarterly reviews of financial statements and reconciliations with the Treasurer of the Board. - Compare actual results against budget and prior-year trends to identify anomalies early. - Engage an external accountant (FTM) quarterly (if feasible) for review and guidance. 3. Training & Capacity Building - Provide finance staff with training in GAAP reporting and nonprofit accounting best practices. - Implement cross-training to ensure continuity if staffing changes occur. 4. Documentation & Controls - Maintain detailed documentation of all reconciliations and adjusting entries. - Establish a clear approval hierarchy for journal entries, ensuring all significant entries are reviewed by leadership prior to posting. 5. Audit Readiness - By implementing these processes, management will be positioned to present materially accurate financial statements prior to auditor review. - The goal is to minimize, if not eliminate, material audit adjustments in future years. Progress will be tracked by requiring the Finance Committee to review and approve quarterly financial packages. Any discrepancies or deficiencies will be documented and corrective steps taken promptly.
Finding 2024-002 Failure to Follow Procurement Policy Type of Finding Noncompliance and Significant Deficiency in Internal Control over Compliance Condition The Organization maintains a procurement policy that establishes spending thresholds and outlines the requirements for obtaining rate quotations at each of these levels. During audit procedures, it was noted that the Organization did not follow the policy’s requirements for obtaining and documenting rate quotations for two of the transactions reviewed. The Organization explained that the vendor was considered a unique partner, and competition was intentionally limited based on the specialized nature of the services provided. However, no documentation was retained to justify this decision to limit competition, as required by federal procurement standards. The absence of such documentation resulted in questioned costs for these transactions. Criteria: Federal regulations require non-federal entities to maintain written procurement procedures that are consistent with applicable laws and standards, including the requirement to conduct procurement transactions in a manner that provides full and open competition, except in limited circumstances, as specifically defined in 2 CFR 200.320. When competition is restricted, entities are required to document the basis for their determination, including the rationale for selecting a particular vendor. Additionally, entities must maintain documentation to support procurement actions and decisions to ensure compliance with applicable requirements. Cause This issue appears to stem from a lack of adherence to the Organization’s procurement policy and an underdeveloped process for documenting exceptions to competitive procurement requirements. While management considered the vendor relationship justified, there was no formal documentation of the rationale, resulting in noncompliance with both internal policy and federal procurement requirements. Possible of Known Effect As a result of this deficiency, the Organization cannot demonstrate that the procurement process complied with the federal requirements under 2 CFR 200.320, nor can it substantiate its rationale for limiting competition. This lack of documentation increases the risk of unsupported or inappropriate expenditures, and in this instance, led to questioned costs related to the two transactions tested. Questioned Costs Known questioned costs of $29,164 were identified. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Organization strengthen its procurement practices by ensuring that all procurements, including those where competition is intentionally limited, are fully documented in accordance with federal requirements and the Organization’s procurement policy. Documentation should include the rationale for limiting competition and evidence of compliance with the applicable procurement threshold requirements. Implementing a review process to ensure procurement files are complete prior to payment or grant charging would further reduce the risk of noncompliance. Views of Responsible Officials Prior to the award of ARPA grant funding in 2023, the Organization did not have a formal procurement policy in place. Implementation of such a policy was required to receive the award. At the time of implementation, however, partnerships had already been established and were identified in the original grant proposal. With respect to legal services, the Organization engaged the two primary organizations in Indianapolis that provide expungement assistance. Indiana Legal Services ("ILS") was the first entity contacted, but after multiple attempts, no response was received from the designated point of contact. Subsequently, the Organization engaged with another nonprofit organization, which responded promptly and agreed to serve as a partner under the grant. For grant compliance services, the Organization engaged a third party. This decision was based on recommendations from community partners, as well as her demonstrated work quality, professional reliability, and commitment to serving the target population.
Show full finding ▾Hide full finding ▴Finding 2024-002 Failure to Follow Procurement Policy Type of Finding Noncompliance and Significant Deficiency in Internal Control over Compliance Condition The Organization maintains a procurement policy that establishes spending thresholds and outlines the requirements for obtaining rate quotations at each of these levels. During audit procedures, it was noted that the Organization did not follow the policy’s requirements for obtaining and documenting rate quotations for two of the transactions reviewed. The Organization explained that the vendor was considered a unique partner, and competition was intentionally limited based on the specialized nature of the services provided. However, no documentation was retained to justify this decision to limit competition, as required by federal procurement standards. The absence of such documentation resulted in questioned costs for these transactions. Criteria: Federal regulations require non-federal entities to maintain written procurement procedures that are consistent with applicable laws and standards, including the requirement to conduct procurement transactions in a manner that provides full and open competition, except in limited circumstances, as specifically defined in 2 CFR 200.320. When competition is restricted, entities are required to document the basis for their determination, including the rationale for selecting a particular vendor. Additionally, entities must maintain documentation to support procurement actions and decisions to ensure compliance with applicable requirements. Cause This issue appears to stem from a lack of adherence to the Organization’s procurement policy and an underdeveloped process for documenting exceptions to competitive procurement requirements. While management considered the vendor relationship justified, there was no formal documentation of the rationale, resulting in noncompliance with both internal policy and federal procurement requirements. Possible of Known Effect As a result of this deficiency, the Organization cannot demonstrate that the procurement process complied with the federal requirements under 2 CFR 200.320, nor can it substantiate its rationale for limiting competition. This lack of documentation increases the risk of unsupported or inappropriate expenditures, and in this instance, led to questioned costs related to the two transactions tested. Questioned Costs Known questioned costs of $29,164 were identified. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Organization strengthen its procurement practices by ensuring that all procurements, including those where competition is intentionally limited, are fully documented in accordance with federal requirements and the Organization’s procurement policy. Documentation should include the rationale for limiting competition and evidence of compliance with the applicable procurement threshold requirements. Implementing a review process to ensure procurement files are complete prior to payment or grant charging would further reduce the risk of noncompliance. Views of Responsible Officials Prior to the award of ARPA grant funding in 2023, the Organization did not have a formal procurement policy in place. Implementation of such a policy was required to receive the award. At the time of implementation, however, partnerships had already been established and were identified in the original grant proposal. With respect to legal services, the Organization engaged the two primary organizations in Indianapolis that provide expungement assistance. Indiana Legal Services ("ILS") was the first entity contacted, but after multiple attempts, no response was received from the designated point of contact. Subsequently, the Organization engaged with another nonprofit organization, which responded promptly and agreed to serve as a partner under the grant. For grant compliance services, the Organization engaged a third party. This decision was based on recommendations from community partners, as well as her demonstrated work quality, professional reliability, and commitment to serving the target population.
Finding 2024-02 Failure to Follow Procurement Policy Condition: The Organization maintains a procurement policy that establishes spending thresholds and outlines the requirements for obtaining rate quotations at each of these levels. During audit procedures, it was noted that the Organization did not follow the policy’s requirements for obtaining and documenting rate quotations for two of the transactions reviewed. The Organization explained that the vendor was considered a unique partner, and competition was intentionally limited based on the specialized nature of the services provided. However, no documentation was retained to justify this decision to limit competition, as required by federal procurement standards. The absence of such documentation resulted in questioned costs for these transactions. Corrective Actions Taken or Planned: Prior to the award of ARPA grant funding in 2023, The Organization did not have a formal procurement policy in place. Implementation of such a policy was required to receive the award. At the time of implementation, however, partnerships had already been established and were identified in the original grant proposal. With respect to legal services, the Organization engaged the two primary organizations in Indianapolis that provide expungement assistance. Indiana Legal Services (“ILS”) was the first entity contacted, but after multiple attempts, no response was received from the designated point of contact. Subsequently, the Organization engaged another nonprofit organization, which responded promptly and agreed to serve as a partner under the grant. For grant compliance services, the Organization engaged a third party. This decision was based on recommendations from community partners, as well as her demonstrated work quality, professional reliability, and commitment to serving the target population. The Organization plans to execute the following: 1. Immediate Remediation - For the two transactions in question, the Organization will prepare and retain retroactive documentation outlining the rationale for limiting competition, citing the vendor’s unique qualifications and specialized services. This documentation will be added to the procurement files to ensure transparency and compliance. 2. Procurement Policy Enforcement - The Organization will reinforce its procurement policy with staff responsible for purchasing, emphasizing the following requirements: - Obtain and document at least three rate quotations when required. - When limiting competition, prepare a written justification memo explaining the rationale (e.g., sole source, specialized expertise, emergency procurement). - Retain all procurement documentation in a centralized file accessible for future audits. 3. Documentation Standardization - A Procurement Justification Form will be developed for instances where competition is intentionally limited. This form will include: + Vendor name and description of services + Reason competition is limited (sole source, unique expertise, etc.) + Approval signatures from both the requesting program lead and the Co-Executive Director - This form will be required for all procurements exceeding the competitive threshold where quotations are not obtained. 4. Staff Training - The Organization will provide refresher training to all staff involved in procurement to ensure they fully understand documentation requirements under both organizational policy and federal standards. - Training will specifically address scenarios involving sole source or unique vendor selections. 5. Oversight & Monitoring - All procurements exceeding $5,000 will require review and approval by the Board. - Quarterly internal audits will be performed by the Finance Manager to ensure procurement files include proper quotations or justification forms. The Board will receive quarterly procurement compliance reports from the Finance Manager. Any deviations will be documented and addressed immediately. Progress will be tracked as part of the Organization’s annual internal control review.
During testing of payroll claims, we noted that the Organization did not consistently maintain documentation of approved pay rates. Some employees had offer letters on file, while others did not. In certain cases, the offer letters on file contained pay rates that did not match the actual pay rates being paid. Although our procedures and inquiries confirmed that employees were paid the correct amounts in accordance with approved procedures, the approved documentation was not consistently retained. In addition, we noted that the Organization did not maintain properly completed and approved I-9 forms for all employees during the year. Criteria: The Organization is required to maintain sufficient personnel documentation, including accurate records of approved pay rates and current I-9 forms, to demonstrate compliance with applicable employment laws and to support proper payroll processing. Federal law requires employers to retain completed Form I-9 for each employee to verify employment eligibility. Cause: The Organization’s personnel file maintenance procedures were not consistently followed. There was not an established process to ensure that all pay rate approvals and I-9 forms were documented, reviewed, and retained in employee personnel files. Possible of Known Effect: Failure to maintain accurate personnel records creates a risk that employees’ pay rates are not properly authorized and increases the risk of noncompliance with federal employment eligibility requirements. While compensating payroll controls reduced the risk of payroll errors, the lack of documentation represents a breakdown in internal control over human resources and payroll compliance. Questioned Costs: There were no questioned costs identified. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization implement and enforce procedures to ensure that personnel files contain complete and accurate documentation. Specifically, all employee files should include an approved record of pay rates (e.g., executed offer letters or updated personnel rate forms) and current I-9 forms. Management should designate responsibility for maintaining these records and periodically review personnel files to ensure compliance. Views of Responsible Officials: The organization recognizes the importance of maintaining complete and accurate payroll documentation and acknowledges the deficiencies identified during the audit. While payroll payments were made accurately, we recognize that inconsistent retention of supporting documentation created a compliance risk. Certain documentation had been maintained in digital form by a former staff member. Due to staff turnover, these records were not readily accessible or able to be located during the audit period. Management has since initiated a process to update all employee files with current, complete, and properly executed documentation to ensure compliance and improve recordkeeping practices. Management and leadership remain committed to strengthening personnel file management, maintaining all required documentation in accordance with applicable regulations, and reinforcing oversight to prevent recurrence in future audit periods.
Show full finding ▾Hide full finding ▴Finding 2024-003 Insufficient Documentation Supporting Payroll Activity Type of Finding Significant Deficiency in Internal Control over Compliance Condition: During testing of payroll claims, we noted that the Organization did not consistently maintain documentation of approved pay rates. Some employees had offer letters on file, while others did not. In certain cases, the offer letters on file contained pay rates that did not match the actual pay rates being paid. Although our procedures and inquiries confirmed that employees were paid the correct amounts in accordance with approved procedures, the approved documentation was not consistently retained. In addition, we noted that the Organization did not maintain properly completed and approved I-9 forms for all employees during the year. Criteria: The Organization is required to maintain sufficient personnel documentation, including accurate records of approved pay rates and current I-9 forms, to demonstrate compliance with applicable employment laws and to support proper payroll processing. Federal law requires employers to retain completed Form I-9 for each employee to verify employment eligibility. Cause: The Organization’s personnel file maintenance procedures were not consistently followed. There was not an established process to ensure that all pay rate approvals and I-9 forms were documented, reviewed, and retained in employee personnel files. Possible of Known Effect: Failure to maintain accurate personnel records creates a risk that employees’ pay rates are not properly authorized and increases the risk of noncompliance with federal employment eligibility requirements. While compensating payroll controls reduced the risk of payroll errors, the lack of documentation represents a breakdown in internal control over human resources and payroll compliance. Questioned Costs: There were no questioned costs identified. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization implement and enforce procedures to ensure that personnel files contain complete and accurate documentation. Specifically, all employee files should include an approved record of pay rates (e.g., executed offer letters or updated personnel rate forms) and current I-9 forms. Management should designate responsibility for maintaining these records and periodically review personnel files to ensure compliance. Views of Responsible Officials: The organization recognizes the importance of maintaining complete and accurate payroll documentation and acknowledges the deficiencies identified during the audit. While payroll payments were made accurately, we recognize that inconsistent retention of supporting documentation created a compliance risk. Certain documentation had been maintained in digital form by a former staff member. Due to staff turnover, these records were not readily accessible or able to be located during the audit period. Management has since initiated a process to update all employee files with current, complete, and properly executed documentation to ensure compliance and improve recordkeeping practices. Management and leadership remain committed to strengthening personnel file management, maintaining all required documentation in accordance with applicable regulations, and reinforcing oversight to prevent recurrence in future audit periods.
Finding 2024-03 Insufficient Documentation Supporting Payroll Activity Condition: During testing of payroll claims, we noted that the Organization did not consistently maintain documentation of approved pay rates. Some employees had offer letters on file, while others did not. In certain cases, the offer letters on file contained pay rates that did not match the actual pay rates being paid. Although our procedures and inquiries confirmed that employees were paid the correct amounts in accordance with approved procedures, the approved documentation was not consistently retained. In addition, we noted that the Organization did not maintain properly completed and approved I-9 forms for all employees during the year. Corrective Actions Taken or Planned: The organization recognizes the importance of maintaining complete and accurate payroll documentation and acknowledges the deficiencies identified during the audit. While payroll payments were made accurately, we recognize that inconsistent retention of supporting documentation created a compliance risk. Certain documentation had been maintained in digital form by a former staff member. Due to staff turnover, these records were not readily accessible or able to be located during the audit period. Management has since initiated a process to update all employee files with current, complete, and properly executed documentation to ensure compliance and improve recordkeeping practices. Management and leadership remain committed to strengthening personnel file management, maintaining all required documentation in accordance with applicable regulations, and reinforcing oversight to prevent recurrence in future audit periods. The Organization plans to execute the following: 1. Standardization of Employee Files - The Organization has implemented a standardized checklist for all employee personnel files to ensure the presence of: + Signed offer letters with approved pay rates + Completed and verified I-9 forms + Any subsequent pay rate change approvals - Co-Executive Directors will be required to complete and sign the checklist for each employee file upon hire, and again during annual compliance reviews. 2. Offer Letter and Pay Rate Documentation - Effective immediately, all employees (existing and new) will have a signed offer letter or addendum on file reflecting their current pay rate. - For employees where discrepancies exist between historical offer letters and current pay, updated pay rate addendums will be drafted, signed by both employee and management, and placed in their personnel files. 3. I-9 Form Compliance - The organization will perform a full review of all current employee I-9 documentation to identify and correct any missing or incomplete forms. - Going forward, I-9 forms will be completed and verified on or before the employee’s first day of work, in accordance with federal requirements. - An annual HR compliance audit will be conducted to ensure all I-9’s are up to date and retained properly. 4. Training & Accountability - Administrative staff will receive refresher training on employment documentation requirements, including I-9 compliance and payroll authorization documentation. - The Co-Executive Directors will review a sample of personnel files quarterly to verify compliance and hold Co-Executive Directors accountable for maintaining accurate documentation. To ensure continued compliance, the Organization will maintain a centralized file tracking system, updated quarterly, and report results to the Board. Corrective actions will be taken immediately if gaps are identified.
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