EIN: 860965120
UEI: GSA_MIGRATION
Audited by: BEACHFLEISCHMAN PLLC
Oversight agency: 59 [Small Business Administration]
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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 August 15, 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 February 15, 2023 (1300 days ago).
What is a management decision? →Lack of segregation of duties in the cash disbursements process. During parts of the year, while the Executive Director was working remotely in another state, the individual authorized to sign checks also had access to prepare the checks and record the transactions in the accounting system. Further, not all disbursements had documentation of approval prior to payment. Cause: The Organization did not have the resources for enough staff due to the negative impact of the pandemic on their operations. Effect: Inappropriate disbursements could be initiated without adequate segregation of duties or proper documentation of approval. Context: Four disbursements out of a sample of 40 were signed by the individual preparing the checks. Further, ten out of a sample of 40 disbursements did not have any documentation of approval prior to payment. Recommendation: We recommend the Organization improve its segregation of duties. If the Executive Director is not available to sign checks, someone else with knowledge of the business that does not have access to the accounting system should be a signor. The individual that mails out the checks should be different than the individual that prepares the checks. Further, documentation of approval should be obtained with every disbursement, and policies should document any types of recurring payments that do not need approval beyond the check signor.
Show full finding ▾Hide full finding ▴Criteria: Internal controls should be set up to include adequate segregation of duties and all disbursements should have documentation of approval. Condition: Lack of segregation of duties in the cash disbursements process. During parts of the year, while the Executive Director was working remotely in another state, the individual authorized to sign checks also had access to prepare the checks and record the transactions in the accounting system. Further, not all disbursements had documentation of approval prior to payment. Cause: The Organization did not have the resources for enough staff due to the negative impact of the pandemic on their operations. Effect: Inappropriate disbursements could be initiated without adequate segregation of duties or proper documentation of approval. Context: Four disbursements out of a sample of 40 were signed by the individual preparing the checks. Further, ten out of a sample of 40 disbursements did not have any documentation of approval prior to payment. Recommendation: We recommend the Organization improve its segregation of duties. If the Executive Director is not available to sign checks, someone else with knowledge of the business that does not have access to the accounting system should be a signor. The individual that mails out the checks should be different than the individual that prepares the checks. Further, documentation of approval should be obtained with every disbursement, and policies should document any types of recurring payments that do not need approval beyond the check signor.
Unprecedented, emergency circumstances connected to required shutdown of the theatre?s operations due to COVID-19 were impacting the business at the time this material weakness was identified. The samples noted are isolated to the first quarter of 2021 when the organization was functioning with a skeleton staff that was working entirely remotely. Standard separation of duties was not a viable option given the circumstances. The issues noted were corrected within the same year, as soon as staffing and public health conditions allowed for a return to more typical operations. The Organization agrees with the finding and has implemented procedures to provide for adequate segregation of duties as well as consistent documentation of approvals for all transactions.
We found one instance of hours paid to an employee that did not match the time sheet. Per management, the difference is due to fixing an error from the prior pay period; however, no documentation could be located to support that position. Cause: Limited staff resources and time to adequately maintain all necessary documentation. Effect: Employees could be over or under paid if adequate documentation is not maintained to support pay. Context: In a sample of 40 payroll transactions, one instance did not have adequate documentation to support 4.95 hours. A total of 1,706 hours were tested over the 40 employees. Recommendation: We recommend the Organization put in place procedures that require adequate documentation and allocate necessary staff time to follow those procedures.
Show full finding ▾Hide full finding ▴Criteria: Payroll exceptions should be adequately documented. Condition: We found one instance of hours paid to an employee that did not match the time sheet. Per management, the difference is due to fixing an error from the prior pay period; however, no documentation could be located to support that position. Cause: Limited staff resources and time to adequately maintain all necessary documentation. Effect: Employees could be over or under paid if adequate documentation is not maintained to support pay. Context: In a sample of 40 payroll transactions, one instance did not have adequate documentation to support 4.95 hours. A total of 1,706 hours were tested over the 40 employees. Recommendation: We recommend the Organization put in place procedures that require adequate documentation and allocate necessary staff time to follow those procedures.
The single issue noted coincides with implementation of electronic time tracking software at the organization, with a learning curve for supervisory staff on documenting corrections of errors. Management asserts that it is not indicative of an ongoing issue or lack of procedure. The issue noted was corrected within the audit year, as staff were trained on the new system. The Organization agrees with the finding and has already implemented procedures to maintain documentation for exceptions to payroll transactions.
Criteria: Non-Federal entities are required to have written policies, procedures, and standards of conduct. Condition/Context: The Organization does not have any written policies, including those for procurement, allowable costs, payment management, etc. as required by 2 CFR 200, Subparts D and E. Cause: This is the first year the Organization has received any Federal funding, and did not have the staff resources to document their policies and procedures in writing. Effect: Employees could be unclear of Federal contract requirements without documented policies and procedures. Recommendation: We recommend the Organization document formal policies and procedures as required by 2 CFR 200, Subparts D and E.
Show full finding ▾Hide full finding ▴Criteria: Non-Federal entities are required to have written policies, procedures, and standards of conduct. Condition/Context: The Organization does not have any written policies, including those for procurement, allowable costs, payment management, etc. as required by 2 CFR 200, Subparts D and E. Cause: This is the first year the Organization has received any Federal funding, and did not have the staff resources to document their policies and procedures in writing. Effect: Employees could be unclear of Federal contract requirements without documented policies and procedures. Recommendation: We recommend the Organization document formal policies and procedures as required by 2 CFR 200, Subparts D and E.
The Organization has no prior history of Federal funds, and received notice of emergency, COVID relief funds in June of the audit year. At time of notice, the Organization was still shuttered due to COVID-19 impacts, and functioning on skeleton staff. There was no prior need to have written policies and no realistic opportunity to develop written policies with respect to 2 CFR 200, Subparts D and E in the given circumstances. The Organization agrees with the finding, and will allocate staff resources to document policies and procedures related to compliance with Federal funding regulations as needed in the future.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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