EIN: 860809052
UEI: LQ39U51Y6K19
Audited by: CapinCrouse LLC
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 31, 2022. 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 May 1, 2023 (1215 days ago).
What is a management decision? →During the audit of the Unaccompanied Alien Children Program (UACP), there were several instances of expenditures that required multiple bids or sole source justification because they exceeded the micro-purchases threshold as defined by procurement regulations included in Uniform Guidance 2 CFR subpart D 200.318 through 200.327. The Organization did not always have sufficient supporting documentation to show compliance with 2 CFR subpart D 200.318 through 200.327. 2 CFR 200.318 (c)(2)(i) specifically requires the Organization to maintain records sufficient to detail the history of procurement. Criteria: 2 CFR 200 subpart D 200.318 through 200.327 Questioned Costs: $0 Context: Out of 9 vendors tested for procurement compliance, 6 did not have the proper documentation to support the Organization?s selection of that vendor. Cause: Lack of consistent documentation processes for expenses that exceed the micro-purchases threshold. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the Organization designate an individual to review all purchases over the micro-purchases threshold and review procurement documentation to ensure it is sufficient before expenses are approved for payment. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Federal Procurement Regulations Significant Deficiency U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES ALN #: 93.676 Federal Award Identification #: 90ZU0404 and 90ZU0272 Condition: During the audit of the Unaccompanied Alien Children Program (UACP), there were several instances of expenditures that required multiple bids or sole source justification because they exceeded the micro-purchases threshold as defined by procurement regulations included in Uniform Guidance 2 CFR subpart D 200.318 through 200.327. The Organization did not always have sufficient supporting documentation to show compliance with 2 CFR subpart D 200.318 through 200.327. 2 CFR 200.318 (c)(2)(i) specifically requires the Organization to maintain records sufficient to detail the history of procurement. Criteria: 2 CFR 200 subpart D 200.318 through 200.327 Questioned Costs: $0 Context: Out of 9 vendors tested for procurement compliance, 6 did not have the proper documentation to support the Organization?s selection of that vendor. Cause: Lack of consistent documentation processes for expenses that exceed the micro-purchases threshold. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the Organization designate an individual to review all purchases over the micro-purchases threshold and review procurement documentation to ensure it is sufficient before expenses are approved for payment. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Procurement Regulations Planned Corrective Action: Since the implementation of Concur in mid-2021, the procurement processes within Neighborhood Ministries have been updated to ensure compliance with uniform guidance. The procurement policy will be revisited again in Q4 of 2022 for further streamlining, updating, and ensuring compliance. A Procurement Specialist for the Unaccompanied Alien Children Program was also hired in September 2022 and is creating processes and documentation repositories to improve the procurement and competitive bidding process. Person Responsible for Corrective Action Plan: Melba Davidson Anticipated Date of Completion: 12/1/22
During the audit of the Unaccompanied Alien Children Program (UACP), the SF-425 reporting was tested for both grant agreements. Reported amounts could not be tied to underlying support for actual disbursements and cash receipts during the period reported on based on the definitions provided in 45 CFR 75.2. Criteria: 45 CFR 75.2 Questioned Costs: $0 Context: Out of 3 quarterly reports tested, 2 could not be tied to underlying accounting books and records. Cause: Lack of proper review and approval of reporting before submission to ensure accuracy. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the Organization review the definitions for each line item in the required quarterly reporting to ensure proper reporting. Additionally, we recommend that the Organization maintain underlying accounting records for each report. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Inaccurate Reporting Significant Deficiency U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES ALN #: 93.676 Federal Award Identification #: 90ZU0404 and 90ZU0272 Condition: During the audit of the Unaccompanied Alien Children Program (UACP), the SF-425 reporting was tested for both grant agreements. Reported amounts could not be tied to underlying support for actual disbursements and cash receipts during the period reported on based on the definitions provided in 45 CFR 75.2. Criteria: 45 CFR 75.2 Questioned Costs: $0 Context: Out of 3 quarterly reports tested, 2 could not be tied to underlying accounting books and records. Cause: Lack of proper review and approval of reporting before submission to ensure accuracy. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the Organization review the definitions for each line item in the required quarterly reporting to ensure proper reporting. Additionally, we recommend that the Organization maintain underlying accounting records for each report. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate Reporting Planned Corrective Action: The error in reporting for the Nueva Camino grant was a result of timing, with total expenses reported for the period crossing calendar years. In order to eliminate errors on reporting moving forward, all SF-425s will be reviewed by a member of the finance team familiar with FFRs before filing. We will also train all staff with SF-425 reporting responsibilities on the proper definitions of line items, timing and grant periods for reporting, and processes for determining reporting figures. Documentation will be maintained to support the accuracy of reported numbers. Person Responsible for Corrective Action Plan: Suzi Howk, 100 Degrees Consulting Anticipated Date of Completion: 11/30/22
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