EIN: 843236198
UEI: LPLJXMC3QTA3
Audit also covers 3 related EINs: 132574963, 522112460, 824219629 · unlinked EINs have no separate FAC filing
Audited by: BDO USA, P.C.
Cognizant agency: 98 [U.S. Agency for International Development]
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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 June 18, 2026. 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 18, 2026 (103 days from today).
What is a management decision? →2025-006 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirement (Significant Deficiency) Information on the Major Federal Program - Federal Agency: United States Agency for International Development (USAID) Program Name: USAID Foreign Assistance for Program Overseas Assistance Listing Number: 98.001 Award Number: 72052122CA00007 Award Period: June 13, 2022 – February 26, 2025 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.403, “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. (g) Be adequately documented.” Condition – During our testing of expenses charged to the federal program, we identified three (3) out of 43 sampled transactions where full supporting documentation, including evidence of transaction approval, were not available for our review. Based on discussions with management, the source documentation was shipped from the Haiti program location and was lost in transit. As a result, complete records to support the three expenses and evidence of approval of expenses were not readily available. Cause – This appears to have resulted from insufficient controls over the transfer, retention, and tracking of project documentation during closeout, particularly for records originating from Haiti, where significant security and logistical challenges increase the risk associated with transporting original hard-copy files. Effect - Without adequate internal controls in place to ensure costs are properly reviewed for allowability and documentation, Corus could be noncompliant with the allowability requirement and could request funds for costs that are unallowed. Questioned Costs – Below reportable threshold. Context – This is a condition identified per review of Corus’ compliance with the specified requirements. Repeat Finding - This is not a repeat finding. Recommendation – We recommend that management strengthen controls over the transfer, retention, and accessibility of project documentation during closeout, particularly for records originating from Haiti, which is currently operating in a distressed location with significant security and logistical challenges. Given the heightened risk of loss, delay, or inaccessibility of hard-copy records in a war zone–like environment, management should implement procedures to scan and retain electronic copies of all critical financial, contractual, and approval documentation, including signed journal vouchers, before shipment; maintain a detailed shipping manifest of all files transferred; and track shipments through receipt and inventory confirmation at headquarters. These steps would help mitigate the elevated risk associated with transporting original records from a high-risk environment and support timely access to documentation for accounting, audit, and compliance purposes. Views of Responsible Officials - Corus management agrees with the findings and recommendations. The planned corrective actions are presented in Corus management’s corrective action plan attached as Appendix B to the Single Audit Report.
Show full finding ▾Hide full finding ▴2025-006 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirement (Significant Deficiency) Information on the Major Federal Program - Federal Agency: United States Agency for International Development (USAID) Program Name: USAID Foreign Assistance for Program Overseas Assistance Listing Number: 98.001 Award Number: 72052122CA00007 Award Period: June 13, 2022 – February 26, 2025 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.403, “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. (g) Be adequately documented.” Condition – During our testing of expenses charged to the federal program, we identified three (3) out of 43 sampled transactions where full supporting documentation, including evidence of transaction approval, were not available for our review. Based on discussions with management, the source documentation was shipped from the Haiti program location and was lost in transit. As a result, complete records to support the three expenses and evidence of approval of expenses were not readily available. Cause – This appears to have resulted from insufficient controls over the transfer, retention, and tracking of project documentation during closeout, particularly for records originating from Haiti, where significant security and logistical challenges increase the risk associated with transporting original hard-copy files. Effect - Without adequate internal controls in place to ensure costs are properly reviewed for allowability and documentation, Corus could be noncompliant with the allowability requirement and could request funds for costs that are unallowed. Questioned Costs – Below reportable threshold. Context – This is a condition identified per review of Corus’ compliance with the specified requirements. Repeat Finding - This is not a repeat finding. Recommendation – We recommend that management strengthen controls over the transfer, retention, and accessibility of project documentation during closeout, particularly for records originating from Haiti, which is currently operating in a distressed location with significant security and logistical challenges. Given the heightened risk of loss, delay, or inaccessibility of hard-copy records in a war zone–like environment, management should implement procedures to scan and retain electronic copies of all critical financial, contractual, and approval documentation, including signed journal vouchers, before shipment; maintain a detailed shipping manifest of all files transferred; and track shipments through receipt and inventory confirmation at headquarters. These steps would help mitigate the elevated risk associated with transporting original records from a high-risk environment and support timely access to documentation for accounting, audit, and compliance purposes. Views of Responsible Officials - Corus management agrees with the findings and recommendations. The planned corrective actions are presented in Corus management’s corrective action plan attached as Appendix B to the Single Audit Report.
2025-006 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirement (Significant Deficiency) Contact Name – Robert Mooney Position – Chief Financial Officer Phone Number – rmooney@corusinternational.org Estimated date of completion – September 30, 2026 Corrective Action Plan – Corus management concurs with this finding. In early 2025 Corus’ USAID funded project in Haiti was terminated and we were required to close down the project within two months. At that time, the security situation in Haiti was volatile and our Haiti employees were unable to regularly access the office and none of our US-based employees were permitted to travel to Haiti to assist with the project close out. As part of the close-out, Corus employed the services of a local courier company (none of the US-based courier companies were operating in Haiti at that time due to the security issues) to ship all physical supporting documentation to our offices in the US. Unfortunately, those documents were never received and despite several follow ups with the courier company, we were unable to locate the documents. The key learning was that we need to ensure that going forward all physical accounting related supporting documentation is digitized in a timely manner. This requirement was already a part of our document management policies and procedures. However, we were not regularly tracking compliance. It is important to note that the new Finance & Accounting solutions will enforce staff to digitally capture supporting documentation at the point of transaction entry, thereby transitioning us to a digital first organization.
FAC accepted this audit on June 30, 2025 — management decision was due December 30, 2025.
2024-002 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirement (Significant Deficiency) Information on the Major Federal Program - Federal Agency: United States Agency for International Development (USAID) Program Name: USAID Foreign Assistance for Program Overseas Assistance Listing Number: 98.001 Award Number: 72052122CA00007 Award Period: June 13, 2022 – June 21, 2027 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.403, “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. (g) Be adequately documented.” Condition – During our testing, we identified one (1) out of forty (40) sampled transactions where expenses were charged to the federal program, however, certain health care workers were not authorized to work on the program as there was no valid contract in place. Although Corus did not pay the two health care workers, expenses were still charged to the federal expenditures for the year ended September 30, 2024. Cause – Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained correctly to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - Without adequate internal controls in place to ensure costs are properly reviewed for allowability and documentation, Corus could be noncompliant with the allowability requirement and could request funds for costs that are unallowed. Questioned Costs – Below reportable threshold. Context – This is a condition identified per review of Corus’ compliance with the specified requirements. Repeat Finding - This is not a repeat finding. Recommendation – We recommend Corus strictly follow its own policies, procedures and control to ensure that signed contract or authorization is obtained, and transactions are properly supported on a consistent basis. Views of Responsible Officials - Corus management agrees with the findings and recommendations. The planned corrective actions are presented in Corus management’s corrective action plan attached as Appendix B to the Single Audit Report.
Show full finding ▾Hide full finding ▴2024-002 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirement (Significant Deficiency) Information on the Major Federal Program - Federal Agency: United States Agency for International Development (USAID) Program Name: USAID Foreign Assistance for Program Overseas Assistance Listing Number: 98.001 Award Number: 72052122CA00007 Award Period: June 13, 2022 – June 21, 2027 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.403, “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. (g) Be adequately documented.” Condition – During our testing, we identified one (1) out of forty (40) sampled transactions where expenses were charged to the federal program, however, certain health care workers were not authorized to work on the program as there was no valid contract in place. Although Corus did not pay the two health care workers, expenses were still charged to the federal expenditures for the year ended September 30, 2024. Cause – Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained correctly to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - Without adequate internal controls in place to ensure costs are properly reviewed for allowability and documentation, Corus could be noncompliant with the allowability requirement and could request funds for costs that are unallowed. Questioned Costs – Below reportable threshold. Context – This is a condition identified per review of Corus’ compliance with the specified requirements. Repeat Finding - This is not a repeat finding. Recommendation – We recommend Corus strictly follow its own policies, procedures and control to ensure that signed contract or authorization is obtained, and transactions are properly supported on a consistent basis. Views of Responsible Officials - Corus management agrees with the findings and recommendations. The planned corrective actions are presented in Corus management’s corrective action plan attached as Appendix B to the Single Audit Report.
Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirement Contact Name – Robert Mooney Position – Chief Financial Officer Phone Number – rmooney@corusinternational.org Estimated date of completion – September 30, 2025 Corrective Action Plan – Corus is committed to strengthening its internal controls and documentation standards. The combination of updated policies, enhanced reviews, and targeted training is designed to prevent future instances of unallowable costs being charged to federal programs. Management will continue to monitor compliance through internal audits and periodic donor monitoring visits. Action steps to be implemented during the 2025 fiscal year include: • Effective immediately, all project field offices must verify that contracts or personnel agreements are fully executed prior to any engagement or cost allocation. • A pre-disbursement checklist will be updated to require confirmation of signed employment contracts or consulting agreements prior to processing payroll or labor charges. • Enhanced secondary reviews of country office transactions by International Finance directors will be instituted as part of monthly close process to verify documentation supporting labor charges to federal awards. • A mandatory refresher training session will be delivered by the Grants and Contracts Team to all project finance professionals and program managers globally. Topics will include cost allowability, supporting documentation standards, Uniform Guidance requirements under 2 CFR 200.403 and 200.303, and contract compliance. This training will be included in the onboarding process for new hires and will also be provided to all relevant staff prior to the start date of any new Federal Award.
2024-003 – Internal Control over Compliance and Compliance with Subrecipient Monitoring Requirement (Significant Deficiency) Information on the Major Federal Program - Federal Agency: United States Agency for International Development (USAID) Program Name: USAID Foreign Assistance for Program Overseas Assistance Listing Number: 98.001 Award Number: 7200AA20CA00005, 72052122CA00007, 72052723CA00001 Award Period: May 22, 2020 – June 30, 2026 June 13, 2022 – June 21, 2027 April 3, 2023 – April 2, 2026 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §200.332(b) and §200.332(d), Requirements for Pass-Through Entities, entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. The entity must also monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial and performance reports required by the pass-through entity; (2) following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and (3) issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity. Condition – During our review of seven (7) subrecipient samples, we noted the following: • For two (2) subrecipients, there was no evidence that the subrecipient was monitored if the required Single Audit is conducted, or any documentation of follow-up on the reported findings in the subrecipient’s audit report and ensuring that the subrecipient takes timely corrective action to remediate the finding, if any. • For one (1) subrecipient, there was no documentation that the subrecipient was monitored to ensure that the subaward was used for authorized purposes and in compliance with the terms and conditions of the subaward. Cause – There is lack of sufficient documentary evidence to support that the controls are operating as designed related to subrecipient monitoring compliance. Effect - Subrecipients may not be properly monitored, which may result in subawards being used for unauthorized purposes in violation of the terms and conditions of the subawards or that the subaward performance goals were not achieved. Questioned Costs – None. Context – This is a condition identified per review of Corus’ compliance with the specified requirements. Repeat Finding - This is not a repeat finding. Recommendation – BDO recommends that Corus adhere to their established policies and procedures to ensure that the subrecipient monitoring process from identification of subrecipient through monitoring of subrecipient occurs to ensure compliance with the requirements. To address the many compliance requirements when dealing with subrecipients, most organizations have developed pre-award assessment toolkits, site visit toolkits, monitoring toolkits and other types of subrecipient management aids to assist in ensuring the steps are performed as required. Views of Responsible Officials - Corus management agrees with the findings and recommendations. The planned corrective actions are presented in Corus management’s corrective action plan attached as Appendix B to the Single Audit Report.
Show full finding ▾Hide full finding ▴2024-003 – Internal Control over Compliance and Compliance with Subrecipient Monitoring Requirement (Significant Deficiency) Information on the Major Federal Program - Federal Agency: United States Agency for International Development (USAID) Program Name: USAID Foreign Assistance for Program Overseas Assistance Listing Number: 98.001 Award Number: 7200AA20CA00005, 72052122CA00007, 72052723CA00001 Award Period: May 22, 2020 – June 30, 2026 June 13, 2022 – June 21, 2027 April 3, 2023 – April 2, 2026 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §200.332(b) and §200.332(d), Requirements for Pass-Through Entities, entity must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. The entity must also monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial and performance reports required by the pass-through entity; (2) following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and (3) issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the pass-through entity. Condition – During our review of seven (7) subrecipient samples, we noted the following: • For two (2) subrecipients, there was no evidence that the subrecipient was monitored if the required Single Audit is conducted, or any documentation of follow-up on the reported findings in the subrecipient’s audit report and ensuring that the subrecipient takes timely corrective action to remediate the finding, if any. • For one (1) subrecipient, there was no documentation that the subrecipient was monitored to ensure that the subaward was used for authorized purposes and in compliance with the terms and conditions of the subaward. Cause – There is lack of sufficient documentary evidence to support that the controls are operating as designed related to subrecipient monitoring compliance. Effect - Subrecipients may not be properly monitored, which may result in subawards being used for unauthorized purposes in violation of the terms and conditions of the subawards or that the subaward performance goals were not achieved. Questioned Costs – None. Context – This is a condition identified per review of Corus’ compliance with the specified requirements. Repeat Finding - This is not a repeat finding. Recommendation – BDO recommends that Corus adhere to their established policies and procedures to ensure that the subrecipient monitoring process from identification of subrecipient through monitoring of subrecipient occurs to ensure compliance with the requirements. To address the many compliance requirements when dealing with subrecipients, most organizations have developed pre-award assessment toolkits, site visit toolkits, monitoring toolkits and other types of subrecipient management aids to assist in ensuring the steps are performed as required. Views of Responsible Officials - Corus management agrees with the findings and recommendations. The planned corrective actions are presented in Corus management’s corrective action plan attached as Appendix B to the Single Audit Report.
Internal Control over Compliance and Compliance with Subrecipient Monitoring Requirement Contact Name – Robert Mooney Position – Chief Financial Officer Phone Number – rmooney@corusinternational.org Estimated date of completion - September 30, 2025 Corrective Action Plan – Corus recognizes that effective subrecipient monitoring is a critical component of sound grants management and compliance with federal requirements. By implementing structured tracking tools, enhancing documentation expectations, conducting training, and strengthening oversight through internal audits, Corus will ensure sustained compliance and mitigate the risk of unsupported or noncompliant subrecipient activity. Action steps to be implemented during the 2025 fiscal year include: • Implementation of subrecipient monitoring tool to track subrecipient risk assessments, due dates for single audit reports, monitoring activities such as desk reviews, and follow-up actions on cited findings. • The policy and procedures narrative is updated to clarify expectations for the project team and dictate responsibilities for vetting subrecipients organizations. This includes a timely review of Bridger reports, reassessing risk profiles and continuous monitoring of partner single audits for findings and misstatements. • Mandatory annual training sessions will be facilitated by the Grants and Contracts office to present why and how the organization adheres to this compliance requirement and provide resources for project team members to consult as questions or issues arise. • Internal Audit and/or Grants and Contracts will perform semiannual spot checks of subrecipient monitoring documentation and risk assessments beginning in the 4th quarter of fiscal year 2025, reporting results to members of senior leadership.
2024-004 – Internal Control over Compliance and Compliance with Special Tests and Provisions Requirement (Significant Deficiency) Information on the Major Federal Program - Federal Agency: United States Agency for International Development (USAID) Program Name: USAID Foreign Assistance for Program Overseas Assistance Listing Number: 98.001 Award Number: 72066018CA00001 Award Period: November 14, 2017 – October 13, 2023 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with compliance supplement on key personnel testing, applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The non-federal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award but may be required to obtain federal awarding agency approval of changes in key personnel. Further, in accordance with the grant agreement, USAID requires approval for key personnel and future changes. Condition – During our review, we noted that for one (1) out of four (4) samples tested, a change in key personnel was not approved as required by the award. While Corus notified USAID, prior written approval was not obtained before the change was implemented. Further, a timesheet to verify key personnel’s involvement in the award was not available for review. Cause – Management did not adhere to its existing internal control policies and procedures around communicating to the employees that they are being assigned to the program. Effect - There is a risk that employees are working on the program that are not approved by the granting agency. Questioned Costs – None. Context – This is a condition identified per review of Corus’ compliance with the specified requirements. Repeat Finding - This is not a repeat finding. Recommendation – We recommend Corus implement its existing policies, procedures and controls to ensure proper approval is obtained where required, and documentation to support actual time and effort from key employees is maintained. Views of Responsible Officials - Corus management agrees with the findings and recommendations. The planned corrective actions are presented in Corus management’s corrective action plan attached as Appendix B to the Single Audit Report.
Show full finding ▾Hide full finding ▴2024-004 – Internal Control over Compliance and Compliance with Special Tests and Provisions Requirement (Significant Deficiency) Information on the Major Federal Program - Federal Agency: United States Agency for International Development (USAID) Program Name: USAID Foreign Assistance for Program Overseas Assistance Listing Number: 98.001 Award Number: 72066018CA00001 Award Period: November 14, 2017 – October 13, 2023 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with compliance supplement on key personnel testing, applications/proposals or awards may include staffing proposals that specify individuals who will work on the project and the extent of the planned involvement of personnel. The non-federal entity may change the staffing mix and level of involvement within limits specified by agency policy or in the award but may be required to obtain federal awarding agency approval of changes in key personnel. Further, in accordance with the grant agreement, USAID requires approval for key personnel and future changes. Condition – During our review, we noted that for one (1) out of four (4) samples tested, a change in key personnel was not approved as required by the award. While Corus notified USAID, prior written approval was not obtained before the change was implemented. Further, a timesheet to verify key personnel’s involvement in the award was not available for review. Cause – Management did not adhere to its existing internal control policies and procedures around communicating to the employees that they are being assigned to the program. Effect - There is a risk that employees are working on the program that are not approved by the granting agency. Questioned Costs – None. Context – This is a condition identified per review of Corus’ compliance with the specified requirements. Repeat Finding - This is not a repeat finding. Recommendation – We recommend Corus implement its existing policies, procedures and controls to ensure proper approval is obtained where required, and documentation to support actual time and effort from key employees is maintained. Views of Responsible Officials - Corus management agrees with the findings and recommendations. The planned corrective actions are presented in Corus management’s corrective action plan attached as Appendix B to the Single Audit Report.
Internal Control over Compliance and Compliance with Special Tests and Provisions Requirement Contact Name – Robert Mooney Position – Chief Financial Officer Phone Number – rmooney@corusinternational.org Estimated date of completion – September 30, 2025 Corrective Action Plan – Corus management concurs with this finding and is committed to timely, effective remediation to prevent future instances of noncompliance. Corus recognizes the importance of full compliance with the USAID approval requirements for key personnel. These corrective actions will ensure internal controls are robust, documentation is complete, and changes in staffing are compliant with federal and award-specific regulations. Moving forward, enhanced review and tracking processes will be used to prevent recurrence. Action steps to be implemented during the Corus 2025 fiscal year include: • Effective immediately, key personnel may not commence work on USAID awards until written agency approval is received and documented. • A centralized Key Personnel Compliance Tracker will be created and maintained by the Awards & Compliance Team to track current and proposed key personnel across all USAID-funded programs and record dates of Agency notification and receipt of written approvals. • HR will not activate key personnel in the payroll system for cost charging to the award until Agency approval documentation is uploaded to the project SharePoint folder. • General Finance will verify the presence of approval documentation before approving and releasing the first payroll cycle for new key personnel. • Timesheet audits will be incorporated into quarterly internal compliance checks starting 4th quarter of fiscal year 2025.
FAC accepted this audit on June 21, 2024 — management decision was due December 21, 2024.
2023-002 – Internal Control over Compliance and Compliance with Period of Performance Information on the Major Federal Program - Federal Agency: United States Agency for International Development (USAID) Program Name: USAID Foreign Assistance for Program Overseas Assistance Listing Number: 98.001 Award Number: Various Award Period: Various Criteria – A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Additionally, the Uniform Guidance in 2 CFR Section 200.344(b), states that unless the federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Further, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires the non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonable ensure compliance with Federal statutes, regulations, and other terms and conditions of the Federal Award. The Uniform Guidance in 2 CFR Section 200.510 (b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR Section 200.502 Basis for determining Federal awards expended.” The SEFA must provide total Federal awards expended for each individual Federal program. Condition – During our testing, we identified one (1) out of 40 sampled transactions was incurred outside the period of performance. Corus did not obtain written approval from the federal awarding agency for the specific project. As a result, total expenditure totaling $106,400 was improperly included in the SEFA. Cause - The internal controls established for the review and reconciliation of the SEFA to the underlying accounting records were not consistently followed to ensure accurate charging of expenditures to the SEFA in the correct period. Questioned Costs - None. Context – This is a condition identified per review of Corus’ compliance with the specified requirements. Total expenditures of the specific project charged to the program was $106,400. These charges were removed from the SEFA presented for the year ended September 30, 2023. Effect - Failure to properly review and support expenditures reported in the SEFA can result in inaccurate reporting and non-compliance with laws and regulations. Repeat Finding - This is not a repeat finding. Recommendation - Internal controls should be designed to prevent, detect and correct errors and/or omissions in a timely manner. Without adequate controls, Corus cannot provide reasonable assurance that the SEFA is fairly presented. We recommend management to strengthen its internal control to ensure complete and accurate SEFA. Views of Responsible Officials - Corus management agrees with the findings and recommendations. The planned corrective actions are presented in Corus management’s corrective action plan attached as Appendix B to the Single Audit Report.
Show full finding ▾Hide full finding ▴2023-002 – Internal Control over Compliance and Compliance with Period of Performance Information on the Major Federal Program - Federal Agency: United States Agency for International Development (USAID) Program Name: USAID Foreign Assistance for Program Overseas Assistance Listing Number: 98.001 Award Number: Various Award Period: Various Criteria – A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Additionally, the Uniform Guidance in 2 CFR Section 200.344(b), states that unless the federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Further, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires the non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonable ensure compliance with Federal statutes, regulations, and other terms and conditions of the Federal Award. The Uniform Guidance in 2 CFR Section 200.510 (b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR Section 200.502 Basis for determining Federal awards expended.” The SEFA must provide total Federal awards expended for each individual Federal program. Condition – During our testing, we identified one (1) out of 40 sampled transactions was incurred outside the period of performance. Corus did not obtain written approval from the federal awarding agency for the specific project. As a result, total expenditure totaling $106,400 was improperly included in the SEFA. Cause - The internal controls established for the review and reconciliation of the SEFA to the underlying accounting records were not consistently followed to ensure accurate charging of expenditures to the SEFA in the correct period. Questioned Costs - None. Context – This is a condition identified per review of Corus’ compliance with the specified requirements. Total expenditures of the specific project charged to the program was $106,400. These charges were removed from the SEFA presented for the year ended September 30, 2023. Effect - Failure to properly review and support expenditures reported in the SEFA can result in inaccurate reporting and non-compliance with laws and regulations. Repeat Finding - This is not a repeat finding. Recommendation - Internal controls should be designed to prevent, detect and correct errors and/or omissions in a timely manner. Without adequate controls, Corus cannot provide reasonable assurance that the SEFA is fairly presented. We recommend management to strengthen its internal control to ensure complete and accurate SEFA. Views of Responsible Officials - Corus management agrees with the findings and recommendations. The planned corrective actions are presented in Corus management’s corrective action plan attached as Appendix B to the Single Audit Report.
2023-002 – Internal Control over Compliance and Compliance with Period of Performance Contact Name – Jeff Kaufman Position – Global Controller Contact – jkaufman@corusinternational.org Estimated date of completion: September 30, 2024 Corrective Action Plan – Corus management concurs with this finding and reaffirms its commitment to responsible stewardship of funding awarded to Corus by the United States Government and other donors. There are occasions when Corus may anticipate successfully negotiating a program extension with the USG or other donors. In the event there are immediate needs of the program’s potential beneficiaries, Corus may decide to utilize its own unrestricted funds in expectation that if the extension is obtained, these funds will be reimbursable under the terms of the extension. Corus recognizes that there is no guarantee that the program will be extended; thus, it understands that it incurs the expenses at its own risk. As a point of emphasis, while the expenses referenced in this finding were incorrectly coded such that this spending was erroneously included on the SEFA, Corus did not draw on USG funding to recover these expenses, the expenses were funded by Corus’ own unrestricted resources. Action steps to be implemented during the Corus 2024 fiscal year include: • The steps outlined in response to 2023-01 should also ensure proper account coding of expenses and timely monitoring of program spending against available obligated funds as well as program expiration dates.
FAC accepted this audit on March 5, 2023 — management decision was due September 5, 2023.
FAC accepted this audit on April 7, 2022 — management decision was due October 7, 2022.
FAC accepted this audit on March 14, 2021 — management decision was due September 14, 2021.
Criteria - CFR Section ?200.510(b) states in part: ?The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section ?200.502 Basis for determining Federal awards expended.? The schedule must provide total Federal awards expended for each individual Federal program. In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition - During 2020, Corus experienced turnover in certain accounting and finance positions with the responsibility for reviewing the accuracy of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, Corus management was unable to fully execute on its documented internal control policies regarding SEFA preparation. The SEFA review and approval process did not identify, until after audit sampling was performed, that 4 (four) agreements were incorrectly reported on the SEFA provided to the auditors. Cause - The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the accounting department responsible for the SEFA. Effect - The SEFA provided for the audit was inaccurate for the reason outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs - There are no questioned costs related to this finding. Context - The conditions outlined above are based on our testing of Corus? major program and our overall testing of the completeness and accuracy of the SEFA. Any samples selected as part of the overall SEFA review and testing of expenses and donated commodities were performed using a nonstatistical method. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed. This will ensure that Federal funds are reported accurately on the SEFA and that programs are reported under the correct CFDA number. Views of Responsible Officials ? Corus management agrees with the findings and recommendations.
Show full finding ▾Hide full finding ▴Criteria - CFR Section ?200.510(b) states in part: ?The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section ?200.502 Basis for determining Federal awards expended.? The schedule must provide total Federal awards expended for each individual Federal program. In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition - During 2020, Corus experienced turnover in certain accounting and finance positions with the responsibility for reviewing the accuracy of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, Corus management was unable to fully execute on its documented internal control policies regarding SEFA preparation. The SEFA review and approval process did not identify, until after audit sampling was performed, that 4 (four) agreements were incorrectly reported on the SEFA provided to the auditors. Cause - The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the accounting department responsible for the SEFA. Effect - The SEFA provided for the audit was inaccurate for the reason outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs - There are no questioned costs related to this finding. Context - The conditions outlined above are based on our testing of Corus? major program and our overall testing of the completeness and accuracy of the SEFA. Any samples selected as part of the overall SEFA review and testing of expenses and donated commodities were performed using a nonstatistical method. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed. This will ensure that Federal funds are reported accurately on the SEFA and that programs are reported under the correct CFDA number. Views of Responsible Officials ? Corus management agrees with the findings and recommendations.
IMA World Health (IMA) and Lutheran World Health (LWR) under Corus International are committed to responsible stewardship and reporting of United States Government (USG) funds. With the onboarding of the new IMA finance and accounting staff, training has now been provided to ensure appropriate completion of the SEFA and all the necessary schedules. Additionally, a specific team member has been assigned as the future point person who will be completing the SEFA schedule monthly and reviewing it with their supervisor so that this is a routine exercise, not just an annual audit exercise of determining the SEFA is complete and accurate. With the new Senior Director of International Finance hired and now onboarded, that individual will also be actively reviewing the monthly SEFA schedules and identifying any documentation errors or incorrect / missing USG funding awards requiring inclusion prior to year-end.
Criteria - The Uniform Guidance in 2 CFR Section 200.303, Internal control, requires that non- Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition - During our review of 10 (ten) samples for subrecipient monitoring requirements, we identified that four of the 10 subrecipients tested submitted non-timely liquidation reports. The delay in receipt of the liquidation reports resulted in incorrect reporting of expenditures by Corus as the expenses reported were determined to have occurred over multiple fiscal years. Cause - Subrecipient monitoring controls were not operating as designed. This condition resulted from Corus personnel not obtaining and reviewing liquidation reports timely. If subrecipients are not providing timely reporting, further monitoring and evaluation of the subrecipient should occur. Timely remittance and review of liquidation reports reduces the risk of incorrect financial reporting and ensures timely corrective action can occur for any matters identified during the liquidation report review process. Effect - Failure to properly monitor subrecipients could lead to inappropriate use of Federal funds and/or inaccurate reporting of federal expenditures. Questioned Costs - Not determinable. Context - This is a condition identified per review of Corus? compliance with specified requirements. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that Corus ensure compliance with its internal control procedures over subrecipient monitoring. We recommend that quarterly, finance and program personnel perform a review of advances outstanding to ensure all related financial reporting matters have been liquidated timely and reported correctly within the appropriate fiscal year so that accurate financial reporting can occur as required under federal award guidelines. Views of Responsible Officials ? Corus management agrees with the findings and recommendations.
Show full finding ▾Hide full finding ▴Criteria - The Uniform Guidance in 2 CFR Section 200.303, Internal control, requires that non- Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition - During our review of 10 (ten) samples for subrecipient monitoring requirements, we identified that four of the 10 subrecipients tested submitted non-timely liquidation reports. The delay in receipt of the liquidation reports resulted in incorrect reporting of expenditures by Corus as the expenses reported were determined to have occurred over multiple fiscal years. Cause - Subrecipient monitoring controls were not operating as designed. This condition resulted from Corus personnel not obtaining and reviewing liquidation reports timely. If subrecipients are not providing timely reporting, further monitoring and evaluation of the subrecipient should occur. Timely remittance and review of liquidation reports reduces the risk of incorrect financial reporting and ensures timely corrective action can occur for any matters identified during the liquidation report review process. Effect - Failure to properly monitor subrecipients could lead to inappropriate use of Federal funds and/or inaccurate reporting of federal expenditures. Questioned Costs - Not determinable. Context - This is a condition identified per review of Corus? compliance with specified requirements. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that Corus ensure compliance with its internal control procedures over subrecipient monitoring. We recommend that quarterly, finance and program personnel perform a review of advances outstanding to ensure all related financial reporting matters have been liquidated timely and reported correctly within the appropriate fiscal year so that accurate financial reporting can occur as required under federal award guidelines. Views of Responsible Officials ? Corus management agrees with the findings and recommendations.
IMA World Health (IMA) and Lutheran World Health (LWR) under Corus International are committed to responsible stewardship of United States Government (USG) funds and with the joining of the two organizations have developed strong joint internal controls and procedures to ensure compliance and minimize the risk of loss. We believe that the identified instances of non-compliance in IMA's USG projects/awards are not indicative of our overall subgrantee monitoring. Furthermore, the instances noted did not result in any questioned costs and/or losses. However,we do recognize the importance of the submission of timely subrecipient expense reports and the impact such actions have on both our financial reporting to the US Government and our own corporate financial reporting and have immediately taken steps to prevent a recurrence of this reporting delay into the Home Office by the country office(s). As the overwhelming Dollar value of this finding (70%) pertains to IMA's office in the Democratic Republic of the Congo (DRC), we have implemented, effective immediately, a quarterly partner advance reporting and review process in addition to monthly and weekly subgrantee status updates which will include the Senior Director, Accounting and Finance in the DRC (hired in June 2020 and directly reporting up to the global Corus Chief Financial Officer), the Senior Director of International Finance, the Associate Vice President of General Accounting and Finance, and the Chief Financial Officer at the Home Office. Along with this review process, the country office finance and compliance teams are working more closely with the subrecipients on the timeliness of submitting their expense reports to ensure compliance with the documented policies and procedures for subrecipient monitoring.
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