EIN: 850204963
UEI: K4V1DYKLKKA5
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 16, 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 January 16, 2026 (220 days ago).
What is a management decision? →The Organization did not conduct a physical inventory in current year or prior year and, in additional, requested reimbursement from the Department of Health and Human services for repair costs for which insurance proceeds were received. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. 2 CFR 200.406 requires that any recoveries on losses, such as insurance proceeds, be credited to the Federal award as a cost reduction or a cash refund. Questioned costs: $16,033 Effect: The Organization could dispose of, lose, or encumber federally funded equipment without following Federal guidelines. Cause: The Organization does not have policies and procedures to ensure that a physical inventory of equipment is performed at a minimum frequency of every two years. Additionally, the Entity filed a claim for damages to asset(s) purchased with Federal funds and did not offset the insurance proceeds against the repair costs charged to the Federal program, resulting in reimbursement of unallowable costs.
Show full finding ▾Hide full finding ▴2024-002 (2023-001) – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance (Repeat Finding) Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Head Start CFDA Number: 93.600 Federal Award Identification number: 06CH012005 Pass Through Entity: N/A Award Year: 2024 & 2023 Condition: The Organization did not conduct a physical inventory in current year or prior year and, in additional, requested reimbursement from the Department of Health and Human services for repair costs for which insurance proceeds were received. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. 2 CFR 200.406 requires that any recoveries on losses, such as insurance proceeds, be credited to the Federal award as a cost reduction or a cash refund. Questioned costs: $16,033 Effect: The Organization could dispose of, lose, or encumber federally funded equipment without following Federal guidelines. Cause: The Organization does not have policies and procedures to ensure that a physical inventory of equipment is performed at a minimum frequency of every two years. Additionally, the Entity filed a claim for damages to asset(s) purchased with Federal funds and did not offset the insurance proceeds against the repair costs charged to the Federal program, resulting in reimbursement of unallowable costs.
Physical inventory has been completed, and this process was added to our monitoring calendar to be completed in May of each year. Regarding insurance reimbursement, our policies and procedures are updated to reflect this requirement, and the fiscal staff has been trained on this requirement.
2023-001
The Organization did not conduct the monthly board and policy council meetings. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). A HSA must share accurate and regular financial information with the governing body and the policy council, including monthly financial statements, credit card expenditures, and the financial audit (42 USC 9837(d)(2)(A) and (E)). Questioned costs: None Effect: The Organization could be unaware of important events or financial updates that could affect the Organization if there is no timely discussion. Cause: The Organization is not following its policies and procedures to ensure board meetings and policy council meetings occur every month.
Show full finding ▾Hide full finding ▴2024-003 – Special Tests and Provisions; Program Governance - Significant Deficiency in Internal Controls over Compliance Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Head Start CFDA Number: 93.600 Federal Award Identification number: 06CH012005 Pass Through Entity: N/A Award Year: 2024 Condition: The Organization did not conduct the monthly board and policy council meetings. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). A HSA must share accurate and regular financial information with the governing body and the policy council, including monthly financial statements, credit card expenditures, and the financial audit (42 USC 9837(d)(2)(A) and (E)). Questioned costs: None Effect: The Organization could be unaware of important events or financial updates that could affect the Organization if there is no timely discussion. Cause: The Organization is not following its policies and procedures to ensure board meetings and policy council meetings occur every month.
We have never had monthly board or policy council meetings, but we upload monthly reports including financials to our portal for board and policy council members to reveiw and comment. Our meetings have always been quarterly. In addition, we already have the EPCAA Governance Program Planning Policy in place to correct this finding that was approved by the board on August 9, 2024.
FAC accepted this audit on August 22, 2024 — management decision was due February 22, 2025.
The Organization did not conduct a physical inventory in current year or prior year. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. Questioned costs: None Effect: The Organization could dispose of, lose, or encumber federally funded equipment without following Federal guidelines. Cause: The Organization does not have policies and procedures to ensure that a physical inventory of equipment is performed at a minimum frequency of every two years.
Show full finding ▾Hide full finding ▴2023‐001 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance (Repeat Finding) Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Head Start CFDA Number: 93.600 Federal Award Identification number: N/A Pass Through Entity: N/A Award Year: 2023 Condition: The Organization did not conduct a physical inventory in current year or prior year. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. Questioned costs: None Effect: The Organization could dispose of, lose, or encumber federally funded equipment without following Federal guidelines. Cause: The Organization does not have policies and procedures to ensure that a physical inventory of equipment is performed at a minimum frequency of every two years.
Recommendation: We recommend the Entity enhance the design of its control activities and policies and procedures should be developed to ensure physical inventories are taken at least once every two years. Action Taken: The Organization understands the importance of regular physical inventories and will implement this control activity for the June 30, 2023 fiscal year end. Responsible Person: John Clemons, Chief Financial Officer Timelines for implementation: July 31, 2023
2022-001
During our review of the SF‐429 report, we noted that the EIN number was incorrect, there was no certifying signature, and the report was submitted after the due date. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under 45 CFR 75.319(a), Title to Federally‐owned property remains vested in the Federal Government, and the non‐Federal entity must submit annually an inventory listing of Federallyowned property in its custody to the HHS awarding agency. The Form SF‐429 is used for this reporting. Questioned costs: None Effect: The Organization’s real property may not be appropriately tracked by the Organization and the Federal government without current and accurate reporting. Use of an incorrect identifying number could cause discrepancies in Federal oversight of real property held by the Organization’s Federal program. Cause: The Organization does not have policies and procedures in place to ensure information is accurate and approved and submitted in a timely manner. System problems prevented submittal when attempted.
Show full finding ▾Hide full finding ▴2023‐002 – Real Property Status Special Reporting – Significant Deficiency in Internal Controls over Compliance (Repeat Finding) Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Head Start CFDA Number: 93.600 Federal Award Identification number: N/A Pass Through Entity: N/A Award Year: 2022 & 2023 Condition: During our review of the SF‐429 report, we noted that the EIN number was incorrect, there was no certifying signature, and the report was submitted after the due date. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under 45 CFR 75.319(a), Title to Federally‐owned property remains vested in the Federal Government, and the non‐Federal entity must submit annually an inventory listing of Federallyowned property in its custody to the HHS awarding agency. The Form SF‐429 is used for this reporting. Questioned costs: None Effect: The Organization’s real property may not be appropriately tracked by the Organization and the Federal government without current and accurate reporting. Use of an incorrect identifying number could cause discrepancies in Federal oversight of real property held by the Organization’s Federal program. Cause: The Organization does not have policies and procedures in place to ensure information is accurate and approved and submitted in a timely manner. System problems prevented submittal when attempted.
Recommendation: We recommend the Entity implement adequate controls to ensure the accuracy of the information reported to the Grantor Agency in a timely manner. Action Taken: The Organization will create an electronic calendar with reminders for all reporting requirements and respective due dates. Responsible Person: John Clemons, Chief Financial Officer Timelines for implementation: July 31, 2023
2022-002
During our review of transactions, appropriate approval was not included in supporting documents. The following were noted: In 7 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after the expenditure was paid out. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: None Effect: Review of payroll amounts significantly after the pay period could result in over‐ or under‐pay not being caught in a timely manner; or in misallocations to grants not being caught in a timely manner. This could result in adjustments to employee pay required, or in inaccurate grant tracking account account. Cause: The Organization is not following its policies and procedures to ensure the appropriate approvals are conducted in a timely manner.
Show full finding ▾Hide full finding ▴2023‐003 – Activities Allowed and Allowable Costs over Payroll Expenditures – Significant Deficiency in Internal Controls over Compliance (Repeat Finding) Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Head Start CFDA Number: 93.600 Federal Award Identification number: N/A Pass Through Entity: N/A Award Year: 2023 Condition: During our review of transactions, appropriate approval was not included in supporting documents. The following were noted: In 7 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after the expenditure was paid out. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non‐federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: None Effect: Review of payroll amounts significantly after the pay period could result in over‐ or under‐pay not being caught in a timely manner; or in misallocations to grants not being caught in a timely manner. This could result in adjustments to employee pay required, or in inaccurate grant tracking account account. Cause: The Organization is not following its policies and procedures to ensure the appropriate approvals are conducted in a timely manner.
Recommendation: We recommend the Entity follow their policy and procedures related to purchases. Action Taken: The Organization understands the importance of following current, written policies and procedures for both employees and members of management. Policies and procedures will be reviewed to ensure the appropriate approvals and signatures are obtained. Responsible Person: John Clemons, Chief Financial Officer Timelines for implementation: July 31, 2023
2022-003
FAC accepted this audit on January 22, 2024 — management decision was due July 22, 2024.
The Entity did not conduct a physical inventory in current year or prior year. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. Questioned costs: None Effect: The Entity could dispose of or lose federally funded equipment without following federal guidelines. Cause: The Entity does not have policies and procedures to ensure that the Entity is performing a physical inventory at a minimum of every two years.
Show full finding ▾Hide full finding ▴2022-001 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Headstart Cluster CFDA Number: 93.600 Federal Award Identification number: N/A Pass Through Entity: N/A Award Year: 2022 Condition: The Entity did not conduct a physical inventory in current year or prior year. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. Questioned costs: None Effect: The Entity could dispose of or lose federally funded equipment without following federal guidelines. Cause: The Entity does not have policies and procedures to ensure that the Entity is performing a physical inventory at a minimum of every two years.
Auditor's Recommendation: We recommend the Entity enhance the design of its control activities and policies and procedures should be developed to ensure physical inventories are taken at least once every two years. Action Taken: The Organization understands the importance of regular physical inventories and will implement this control activity for the June 30, 2023 fiscal year end. Responsible Person: John Clemons, Chief Financial Officer Timeline for Implementation: July 31, 2023
The Entity did not conduct a physical inventory in current year or prior year. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. Questioned costs: None Effect: The Entity could dispose of or lose federally funded equipment without following federal guidelines. Cause: The Entity does not have policies and procedures to ensure that the Entity is performing a physical inventory at a minimum of every two years.
Show full finding ▾Hide full finding ▴2022-001 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Headstart Cluster CFDA Number: 93.600 Federal Award Identification number: N/A Pass Through Entity: N/A Award Year: 2022 Condition: The Entity did not conduct a physical inventory in current year or prior year. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years. Questioned costs: None Effect: The Entity could dispose of or lose federally funded equipment without following federal guidelines. Cause: The Entity does not have policies and procedures to ensure that the Entity is performing a physical inventory at a minimum of every two years.
Auditor's Recommendation: We recommend the Entity enhance the design of its control activities and policies and procedures should be developed to ensure physical inventories are taken at least once every two years. Action Taken: The Organization understands the importance of regular physical inventories and will implement this control activity for the June 30, 2023 fiscal year end. Responsible Person: John Clemons, Chief Financial Officer Timeline for Implementation: July 31, 2023
During our review of the SF-429 report, the EIN number was incorrect, there was no certifying signature, and the report was submitted after the due date. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under 45 CFR 75.319(a), Title to Federally-owned property remains vested in the Federal Government, and the non-Federal entity must submit annually an inventory listing of Federally-owned property in its custody to the HHS awarding agency. The Form SF-429 is used for this reporting. Questioned costs: None Effect: The Entity’s real property may not be appropriately tracked by the Entity and the Federal government without current and accurate reporting. Use of an incorrect identifying number could cause discrepancies in Federal oversight of real property held by the Entity’s Federal program. Cause: The Entity does not have policies and procedures in place to ensure information is accurate and approved and submitted in a timely manner.
Show full finding ▾Hide full finding ▴2022-002 – Real Property Status Special Reporting – Significant Deficiency in Internal Controls over Compliance Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Headstart Cluster CFDA Number: 93.600 Federal Award Identification number: N/A Pass Through Entity: N/A Award Year: 2022 Condition: During our review of the SF-429 report, the EIN number was incorrect, there was no certifying signature, and the report was submitted after the due date. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under 45 CFR 75.319(a), Title to Federally-owned property remains vested in the Federal Government, and the non-Federal entity must submit annually an inventory listing of Federally-owned property in its custody to the HHS awarding agency. The Form SF-429 is used for this reporting. Questioned costs: None Effect: The Entity’s real property may not be appropriately tracked by the Entity and the Federal government without current and accurate reporting. Use of an incorrect identifying number could cause discrepancies in Federal oversight of real property held by the Entity’s Federal program. Cause: The Entity does not have policies and procedures in place to ensure information is accurate and approved and submitted in a timely manner.
Auditor's Recommendation: We recommend the Entity implement adequate controls to ensure the accuracy of the information reported to the Grantor Agency in a timely manner. Action Taken: The Organization will create an electronic calendar with reminders for all reporting requirements and respective due dates. Responsible Official: John Clemons, Chief Financial Officer Timeline for Implementation: July 31, 2023
During our review of the SF-429 report, the EIN number was incorrect, there was no certifying signature, and the report was submitted after the due date. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under 45 CFR 75.319(a), Title to Federally-owned property remains vested in the Federal Government, and the non-Federal entity must submit annually an inventory listing of Federally-owned property in its custody to the HHS awarding agency. The Form SF-429 is used for this reporting. Questioned costs: None Effect: The Entity’s real property may not be appropriately tracked by the Entity and the Federal government without current and accurate reporting. Use of an incorrect identifying number could cause discrepancies in Federal oversight of real property held by the Entity’s Federal program. Cause: The Entity does not have policies and procedures in place to ensure information is accurate and approved and submitted in a timely manner.
Show full finding ▾Hide full finding ▴2022-002 – Real Property Status Special Reporting – Significant Deficiency in Internal Controls over Compliance Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Headstart Cluster CFDA Number: 93.600 Federal Award Identification number: N/A Pass Through Entity: N/A Award Year: 2022 Condition: During our review of the SF-429 report, the EIN number was incorrect, there was no certifying signature, and the report was submitted after the due date. Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under 45 CFR 75.319(a), Title to Federally-owned property remains vested in the Federal Government, and the non-Federal entity must submit annually an inventory listing of Federally-owned property in its custody to the HHS awarding agency. The Form SF-429 is used for this reporting. Questioned costs: None Effect: The Entity’s real property may not be appropriately tracked by the Entity and the Federal government without current and accurate reporting. Use of an incorrect identifying number could cause discrepancies in Federal oversight of real property held by the Entity’s Federal program. Cause: The Entity does not have policies and procedures in place to ensure information is accurate and approved and submitted in a timely manner.
Auditor's Recommendation: We recommend the Entity implement adequate controls to ensure the accuracy of the information reported to the Grantor Agency in a timely manner. Action Taken: The Organization will create an electronic calendar with reminders for all reporting requirements and respective due dates. Responsible Official: John Clemons, Chief Financial Officer Timeline for Implementation: July 31, 2023
During our review of transactions, appropriate approval was not included in supporting documents. The following were noted: • In 40 of 40 nonpayroll transactions tested, there was no indication of review by the Fiscal Officer on the GL report now was there any indication of review and approval by the Headstart Director on the Check Register. • In 17 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after the expenditure was paid out. • In 11 of 40 payroll transactions tested, there was no indication that the Fiscal Officer reviewed payroll hours and pay rates on the Payroll Review Form Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: None Effect: The Entity may unintentionally make a purchase with federal funds that does not qualify which could lead to questioned costs and/or repayment to the Grantor agency. Cause: The Entity is not following its policies and procedures to ensure the appropriate approvals are being conducted prior to expenditure and documented.
Show full finding ▾Hide full finding ▴2022-003 – Activities Allowed and Allowable Costs over Non-payroll and Payroll Expenditures – Significant Deficiency in Internal Controls over Compliance Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Headstart Cluster CFDA Number: 93.600 Federal Award Identification number: N/A Pass Through Entity: N/A Award Year: 2022 Condition: During our review of transactions, appropriate approval was not included in supporting documents. The following were noted: • In 40 of 40 nonpayroll transactions tested, there was no indication of review by the Fiscal Officer on the GL report now was there any indication of review and approval by the Headstart Director on the Check Register. • In 17 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after the expenditure was paid out. • In 11 of 40 payroll transactions tested, there was no indication that the Fiscal Officer reviewed payroll hours and pay rates on the Payroll Review Form Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: None Effect: The Entity may unintentionally make a purchase with federal funds that does not qualify which could lead to questioned costs and/or repayment to the Grantor agency. Cause: The Entity is not following its policies and procedures to ensure the appropriate approvals are being conducted prior to expenditure and documented.
Auditor's Recommendation: We recommend the Entity follow their policy and procedures related to purchases. Action Taken: The Organization understands the importance of following current, written policies and procedures for both employees and members of management. Policies and procedures will be reviewed to ensure the appropriate approvals and signatures are obtained. Responsible Official: John Clemons, Chief Financial Officer Timeline for Implementation: July 31, 2023
During our review of transactions, appropriate approval was not included in supporting documents. The following were noted: • In 40 of 40 nonpayroll transactions tested, there was no indication of review by the Fiscal Officer on the GL report now was there any indication of review and approval by the Headstart Director on the Check Register. • In 17 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after the expenditure was paid out. • In 11 of 40 payroll transactions tested, there was no indication that the Fiscal Officer reviewed payroll hours and pay rates on the Payroll Review Form Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: None Effect: The Entity may unintentionally make a purchase with federal funds that does not qualify which could lead to questioned costs and/or repayment to the Grantor agency. Cause: The Entity is not following its policies and procedures to ensure the appropriate approvals are being conducted prior to expenditure and documented.
Show full finding ▾Hide full finding ▴2022-003 – Activities Allowed and Allowable Costs over Non-payroll and Payroll Expenditures – Significant Deficiency in Internal Controls over Compliance Federal Program Information: Funding Agency: U. S. Department of Health and Human Services Title: Headstart Cluster CFDA Number: 93.600 Federal Award Identification number: N/A Pass Through Entity: N/A Award Year: 2022 Condition: During our review of transactions, appropriate approval was not included in supporting documents. The following were noted: • In 40 of 40 nonpayroll transactions tested, there was no indication of review by the Fiscal Officer on the GL report now was there any indication of review and approval by the Headstart Director on the Check Register. • In 17 of 40 payroll transactions tested, the Fiscal Officer reviewed payroll hours and pay rates on the Payroll Review Form however this was dated on April 3rd or 4th of 2023 which is after the expenditure was paid out. • In 11 of 40 payroll transactions tested, there was no indication that the Fiscal Officer reviewed payroll hours and pay rates on the Payroll Review Form Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: None Effect: The Entity may unintentionally make a purchase with federal funds that does not qualify which could lead to questioned costs and/or repayment to the Grantor agency. Cause: The Entity is not following its policies and procedures to ensure the appropriate approvals are being conducted prior to expenditure and documented.
Auditor's Recommendation: We recommend the Entity follow their policy and procedures related to purchases. Action Taken: The Organization understands the importance of following current, written policies and procedures for both employees and members of management. Policies and procedures will be reviewed to ensure the appropriate approvals and signatures are obtained. Responsible Official: John Clemons, Chief Financial Officer Timeline for Implementation: July 31, 2023
FAC accepted this audit on March 24, 2019 — management decision was due September 24, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
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