EIN: 910575954
UEI: PJADH2CJKML7
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 17, 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 August 17, 2025, which was (369 days ago).
What is a management decision? →Finding 2024-001 Material noncompliance and material weakness in internal control over compliance with procurement and suspension and debarment procedures meeting the requirements of 2 CFR Part 200. Federal Agency: United States Department Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Entity: King County Regional Homeless Authority Award Numbers: DA-202305-01899 Award Periods: January 1, 2023 through December 31, 2023 Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.327, require that a non‐Federal entity use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirement identified in 2 CFR Part 200. Condition/Context The Organization has a procurement policy, which includes procedures to include documenting the history of the procurement, including justification of the procurement method utilized. For 2 of 2 procurements selected for testing over the micro-purchase threshold the Organization could not produce contemporaneous documentation supporting the history of the procurement including justification for utilization of the noncompetitive procurement method of procurement and performance of suspension and debarment search. The Organization determined at the time of procurement that due to a state of public emergency the noncompetitive procurement methodology was in compliance with the Uniform Guidance. Subsequent to procurement the Organization received approval from the pass-through funder that a noncompetitive procurement methodology was authorized. Additionally, the Organization documented the vendor justification and performance of suspension and debarment search subsequent to entering into the procurement, as part of preparation for the annual audit. Cause The Organization did not have internal controls in place to ensure that the Organization’s procurement policy was followed by retaining documentation of the history of the procurement. Effect The Organization entered into agreements to procure goods and services for which no documentation was retained to support the history of the procurement. Questioned Costs $0 Repeat Finding Repeat of finding 2023-002 Recommendation We recommend the Organization implement internal controls to ensure that documentation is retained to support procurements in accordance with its procurement policy. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.
Finding Number 2024-001 Contact Person(s): Mansour Camara, CFO, Carmelle Palomino, Controller Corrective Action Planned: Management completed the documentation for vendor selection, justification and suspension and debarment search for the vendors selected in FY 24 audit prior to the commencement of the audit. These documents were provided to the auditors upon request. However, the auditors determined that since this was a finding in FY 23 and the approval from the funder was received during that audit, the finding would automatically have to be repeated because of the timing of the last audit. ULMS created a procurement form that streamlines the selection, justification suspension and debarment search and documentation of the process in March 2024. Additionally, management transitioned the form online in August 2024 for document retention purposes so that a copy of the completed form is automatically sent to ULMS’s procurement email. Management also provided procurement training to all employees involved in the procurement process. Anticipated Completion Date: Date completed 3/19/2024
2023-002
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 16, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by April 16, 2025, which was (492 days ago).
What is a management decision? →Material noncompliance and material weakness in internal control over compliance with procurement and suspension and debarment procedures meeting the requirements of 2 CFR Part 200. Federal Agency: United States Department Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Entity: King County Regional Homeless Authority Award Numbers: DA-202303-01737 Award Periods: March 15, 2023 through August 31, 2023 Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326 Internal Controls, require that a non‐Federal entity use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirement identified in 2 CFR Part 200. Condition/Context The Organization has a procurement policy, which includes procedures to include documenting the history of the procurement, including justification of the procurement method utilized. For 3 of 3 procurements selected for testing over the micro-purchase threshold the Organization could not produce contemporaneous documentation supporting the history of the procurement including justification for utilization of the noncompetitive procurement method of procurement and performance of suspension and debarment search. The Organization determined at the time of procurement that due to a state of public emergency the noncompetitive procurement methodology was in compliance with the Uniform Guidance. Further, subsequent to audit testing the Organization received approval from the pass-through funder that a noncompetitive procurement methodology was authorized. Cause The Organization did not have internal controls in place to ensure that the Organization’s procurement policy was followed by retaining documentation of management consideration and conclusion when procuring goods and services. Effect The Organization entered into agreements to procure goods and services for which no documentation was retained to support the history of the procurement. Questioned Costs $0 Repeat Finding Not a repeat finding. Recommendation We recommend the Organization implement internal controls to ensure that documentation is retained to support procurements in accordance with its procurement policy. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.
Finding Number 2023-002 Contact Person(s): Mansour Camara, CFO, Carmelle Palomino, Controller Corrective Action Planned: ULMS’s policy on procurement outlines the process and documentation required to select vendors for contracts over the micro-purchase threshold. The policy was followed, but documentation could not be retrieved as it was not submitted to accounting and some of the decision makers of the contract are no longer with ULMS. Management recognized this issue and created a procurement form that streamlines the selection, justification and documentation of the process in March 2024 which was before the organization was informed of this finding. Additionally, management transitioned the form online in August 2024 and a copy of the completed form is automatically sent to ULMS’s procurement email. Management also provided procurement training to all employees involved in the procurement process. Anticipated Completion Date: Date completed 3/19/2024
Finding 2023-003 Instance of noncompliance and significant deficiency in internal controls over compliance for reporting related to the Submission of Single Audit reporting package. Federal Agency: All Awards reported on the schedule of expenditures of federal awards. Program Title: All Awards reported on the schedule of expenditures of federal awards. Assistance Listing Number: All Awards reported on the schedule of expenditures of federal awards. Award Number: All Awards reported on the schedule of expenditures of federal awards. Award Period: All Awards reported on the schedule of expenditures of federal awards. Criteria In accordance with 2 CFR 200.512, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. Internal control systems over financial reporting are to prevent late submission of the Single Audit reporting package, including the data collection form to the Federal Audit Clearinghouse. Condition, Context for Evaluation, and Effect The Single Audit reporting package and related data collection form for the year ended June 30, 2023 was not submitted within nine months after the end of the audit period. Questioned Costs Not applicable. Cause Internal controls over year-end closing were not in place to ensure timely filing. Repeat Finding Repeat of finding 2022-004. Recommendation We recommend that the Organization review the internal controls in place over year-end closing to ensure the data collection form and reporting package can be submitted timely to the Federal Audit Clearinghouse. Views of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.
inding Number 2023-003 Contact Person(s): Mansour Camara, CFO, Carmelle Palomino, Controller Corrective Action Planned: The delay in submitting the audit on time is mainly due to changes with the SEFA reporting. Management created a closing process which includes contract review to ensure accurate SEFA reporting. Anticipated Completion Date: Date completed 9/10/2024
2022-004
Finding 2023-004 Significant deficiency in internal controls over compliance related to allowable costs and cost principles compliance requirements. Federal Agency: All Awards reported on the schedule of expenditures of federal awards. Program Title: All Awards reported on the schedule of expenditures of federal awards. Assistance Listing Number: All Awards reported on the schedule of expenditures of federal awards. Award Number: All Awards reported on the schedule of expenditures of federal awards. Award Period: All Awards reported on the schedule of expenditures of federal awards. Criteria In accordance with 2 CFR 200.434, costs related to contributions and donations are unallowable costs. Condition/Context for Evaluation During the year ended June 30, 2023, we identified costs related to donations to other not-for-profit entities and organizations totaling approximately $143,350 that were included in the indirect cost pool. Effect or Potential Effect The Organization did not fully comply with the allowable cost principles as outlined in 2 CFR 200, Subpart E. As a result, the indirect cost pool for 2023 included unallowable costs. Questioned Costs Not determinable Cause The Organization’s internal controls did not ensure that all costs included in the indirect cost pool were allowable. Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization implement the necessary internal controls to ensure that only allowable costs are included in the indirect cost pool. Views of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.
Finding Number 2023-004 Contact Person(s): Mansour Camara, CFO, Carmelle Palomino, Controller Corrective Action Planned: ULMS reached out to the funder after it was informed of this Finding to address the issue, the funder stated that ULMS’s NICRA rate is not overcharged because certain exclusions were made that were discretionary and were more than the awards and grants amount. ULMS will work with the funder in subsequent NICRA calculations to make sure awards and grants are excluded. Anticipated Completion Date: Date completed 9/6/24
Finding 2023-005 Instance of noncompliance and significant deficiency in internal controls over eligibility. Federal Agency: Department of Labor Program Title: WIOA Cluster Assistance Listing Number: 17.259, 17.258 Award Numbers: 22-111-ISY, 22-115-ADU Award Periods: July 1, 2022 through June 30, 2023 Criteria Per the standards contained in Title 2 US Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303, non‐federal entities are required to 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. The Federal award referenced requires that eligible beneficiaries be in-school, or out-of-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504). Condition/Context for Evaluation During the year ended June 30, 2023, out of a sample of five beneficiaries, one selection did not have a supporting self-attestation and Youth Program Eligibility Criteria checklist form completed supporting that the beneficiary was in-school, or out-of-school youth and went through the eligibility verification process. The Organization had retained the individuals transcript supporting the compliance requirements that the youth was attending school and between the age of 14 and 21. Effect or Potential Effect Beneficiaries served by the Organization may not be eligible to participate in the program. Questioned Costs Not applicable. Cause The Organization’s internal controls did not ensure that documentation was retained to support the complete eligibility determination of all individuals participating in the program. Repeat Finding Not a repeat finding. Recommendation We recommend that the Organization implement the necessary internal controls to ensure that documentation is retained to support the eligibility of all beneficiaries served. Views of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.
Finding Number 2023-005 Contact Person(s): Mansour Camara, CFO, Carmelle Palomino, Controller Corrective Action Planned: Management reviewed the document retention policy with all program managers and directors and IT created online files for each department to retain program documents as per the policy. Management will conduct implementation audits for each department. Anticipated Completion Date: Date completed 10/31/2024
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 7, 2023. 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 March 7, 2024, which was (897 days ago).
What is a management decision? →2022-001 Accounting System, Processes and Reporting Identification as a Repeat Finding: Repeat of Finding 2021-001Finding:Internal control processes over financial accounting did not ensure that all transactions were properly recorded in accordance with U.S. GAAP on a timely basis.Criteria:The Urban League is responsible for day-to-day transactional accounting as well as annual financial statement reporting. As such, the Organization is responsible for implementing adequate procedures to ensure that such information and reports are accurate and complete.Uniform Guidance Section 2 CFR 200.303(a), Internal Controls, requires that non-federal entities must establish and maintain effective internal controls over the federal award that provides reasonable assurance that the non-federal entity is managing the award in compliance with federal statutes, regulations and the terms and conditions of the federal award.Sample Size and Population:Sampling was not applicable to this finding.Condition and Context:The Organization experienced turnover in its accounting and finance department at the beginning of the fiscal year. In the midst of the transition in staffing, historic knowledge of accounting for certain transactions was lost and reconciliations prepared did not use accurate accounting records and lacked clerical accuracy.Effect:Interim financial statements utilized by the Board of Directors for decision making in FY2022 did not accurately reflect the financial condition of the Organization on a U.S. GAAP basis. The Organization?s internal controls failed to identify material errors in accounting including the following:? 18 months of operating activities were recorded within the consolidating Partnership?s accounting records for the 12 month period ended June 30, 2022.? $704,017 in advanced payments of federal funds that were received in the year ended June 30, 2021 were recognized as revenue during that year and were not appropriately reflected as refundable advances as of that date as disclosed in Note 20 of the financial statements.? Material adjustments were identified in the Organization?s accounting for restricted revenue and net assets with donor restrictions.? The Organization's accounting for a fiscal sponsor relationship did not appropriately reflect accounting for such relationships under ASC 958, Not-For-Profit Entities.Cause:The errors identified in the Partnership?s accounting records reflect errors in the design of reconciliations. The errors in accounting for advanced payments of federal funds reflect documentation retention matters addressed in Finding 2021-006. Additionally, the errors in accounting for advanced payments, restricted revenue, and fiscal sponsor relationships reflect errors in identifying the accounting treatment for contract terms.Recommendations:? Perform analytics of financial data at least quarterly to identify unusual activity that may indicate errors in accounting.? Establish a process for reviewing contract terms and evaluating, communicating, and documenting the appropriate accounting treatment.? Obtain training on ASC 958, Not-for-Profit Entities.? Engage a third-party CPA to review accounting reconciliations on a quarterly basis.Questioned Costs: NoneManagement Response and Corrective Action Plan: See Corrective Action PlanContact Person: Mansour Camara, CFO
ULMS Corrective Action Plan for FY 21-22 Audit FindingsULMS faced significant challenges with the departure of its longtime CFO two months post fiscal year 2021. In addition, the third-party management company who had been responsible for the Partnership accounting, ceased the relationship abruptly without opportunity to smoothly transition the responsibility in-house to ULMS. Our external auditor does not prepare a Management Letter typically used to communicate with the Board of Directors and Governance issues that may not elevate to a finding. As such, significant findings are reflected in Section III ? Federal Award Findings and Questioned Costs.FY 2021 was the organization?s first single audit reporting requirement. ULMS engaged a third-party CPA to review past audit and current documents needed to commence the FY 2022 audit. However, due to an emergency there was limited independent review of documents prior to being submitted to the auditor due to time constraints. ULMS continues to strengthen its accounting team and has hired a new Controller in July 2023. The new Controller is a licensed CPA with over 30 years accounting experience and over 10 years? experience as an independent auditor for a range of organizations including non-profits. The Controller will collaborate with the CFO to ensure there is accuracy in reporting, especially for major federal programs. Finding #: 2022-001Contact Person: Mansour Camara? It is important to note that this error had no impact on the Urban League Village at Coleman School LP?s (?Partnership?) standalone financials or their audit, nor does it affect ULMS?s standalone financials. The error only affects the consolidating financials for the entities, mainly because ULMS and ULV at Colman School LP have different fiscal year periods. The total impact of the additional 6 months of operating activities recorded within the consolidating financials for FY 2022 was less than 1% of operating activities. The error was corrected and not reflected in the audited financial statements for FY 2022.The interim financial statements provided to the Board of Directors during FY 2022 for decision making did not include consolidated financial statements. Interim financial statements provided to the Board only included standalone financial statements. Consequently, there were no inaccurate financial statements provided to the Board for decision making.Actions to be taken: The error in preparing consolidated financials was corrected and not reflected in the audited financial statements for FY 2022. Management will perform quarterly analytics of financial data for the partnership and close its books in alignment with the consolidated financials.Finding #: 2022-001Contact Person: Mansour Camara? The $704,017 was recorded in temp restricted net assets based on a proposed adjusting journal entry from the auditors during FY 2021 audit. $388,728 was refunded to the grantor and should have been recorded as accounts payable at year end FY 2021 and the remainder $304,177 should be classified as deferred revenue as the grantor extended the time period for earning the revenue. $11,112 was earned and the expenses were accrued during the period of performance of the contract in FY 2021 and should not have been included in the auditor?s total of $704,017. The practice of ULMS was to record forward funded contracts in revenue and record an adjustment at year end to temporary restricted funds. Net spendings for each program was communicated to the grantor and appropriate actions taken based on grantor?s instruction. The grantor was informed of the underspent funds prior to the commencement of the audit and management refunded the underspent funds as requested by the funder in compliance with contract terms.It is Management?s position that these Findings should be withdrawn. The longstanding practice of the organization was to record revenue upon receipt of funds and at year end prepare an adjustment to net asset with donor restriction. Consistency in accounting presentation is an essential concept to financial statement preparation. The accounting staff followed the recommendation of the auditor in FY 2021 audit by recording AJE 23. Now the organization is being critiqued in FY 2022 for recording the proposed adjustment and following the recommendation of the auditor.Actions to be taken: The organization?s policy has changed to record all unearned revenue as deferred revenue. ULMS hired a professional CPA with over 10 years? experience in nonprofit auditing as the new Financial Controller.? Management disagrees with auditors? recommendation to impound the funds of Black Lives Matter Seattle King County (BLMSKC) received through the fiscal sponsorship agreement. However, ULMS executed the auditor?s recommendation.Actions to be taken: ULMS will hold the funds of BLMSKC until the organization receives documentation allowing the legal release of the funds.
2021-001
2022-002 Reporting ? Schedule of Expenditures of Federal AwardsIdentification as a Repeat Finding: Repeat of Finding 2021-004.Finding:The SEFA provided for audit contained errors in identifying programs, program clusters and expenditures of federal awards.Criteria:The Organization is responsible for maintaining accurate information about all federal programs and reporting requirements. The Organization is responsible for using this information to comply with the Uniform Guidance in carrying out federal programs.Sample Size and Population: N/ACondition and Context:The original SEFA provided for audit contained errors in identifying programs, program clusters and expenditures of federal awards including the following:? 21.019 Coronavirus Relief Fund excluded. Contracts 4120 & 8328 passed through by the United Way of King County & the contract passed through by the Washington State Housing Finance Commission (WSHFC) totaled $205,822 but were not included in the original SEFA provided.? 21.023 Emergency Rental Assistance Program Contract 9395 passed through by the United Way of King County understated by $341,000.? 21.023 Emergency Rental Assistance Program Contract excluded. Contract 8366 passed through by the United Way of King County included $8,274,601 of federal funds that were not included on the original SEFA provided for audit.? 21.026 Homeowner Assistance Fund contact #HAF0025 passed through by WSHFC overstated by $124,710.? 91.024 Emergency Food and Shelter contract #889000-033 passed through by United Way of King County overstated by $66,542.? 17.258 WIOA Title 1b Adult Services contract #21-115-ADU passed through by Workforce Development Council of King County not identified as part of the WIOA Cluster.Additionally, the prior year SEFA was overstated by $704,017 for the 20.019 Coronavirus Relief Fund Contracts #4120 and #8328 passed through by the United Way of King County due to the accounting error identified in Finding 2022-001.Effect:Inaccurate identification of programs subject to the Single Audit increases the risk that the Organization will not comply with the terms and conditions of federal programs.Cause:As noted in Finding 2022-001, the Organization did not correctly account for advanced federal funds and as noted in Finding 2022-003, the Organization has not implemented a policy for advanced federal funds that complies with 2 CFR 200.305. These gaps in internal control resulted in cut-off errors in SEFA reporting for FY21 & FY22. Additionally, the Organization has not been applying the guidance of Section 200.502 of the Uniform Guidance in preparing the SEFA. Lastly, the program manager of the pass through agency of the 21.023 Emergency Rental Assistance Program Contract #8366 incorrectly informed the Organization that it had no responsibility for reporting the contract as a subrecipient of federal funds.Recommendation:The Organization must continue to increase its familiarity with federal grant compliance requirements and establish a process for timely identification of federal programs and a system for tracking contracts in order to ensure compliance with federal award programs and to completeness and accuracy in SEFA reporting.Questioned Costs: NoneManagement Response and Corrective Action Plan: See Corrective Action PlanContact Person: Mansour Camara, CFO
ULMS Corrective Action Plan for FY 21-22 Audit FindingsULMS faced significant challenges with the departure of its longtime CFO two months post fiscal year 2021. In addition, the third-party management company who had been responsible for the Partnership accounting, ceased the relationship abruptly without opportunity to smoothly transition the responsibility in-house to ULMS. Our external auditor does not prepare a Management Letter typically used to communicate with the Board of Directors and Governance issues that may not elevate to a finding. As such, significant findings are reflected in Section III ? Federal Award Findings and Questioned Costs.FY 2021 was the organization?s first single audit reporting requirement. ULMS engaged a third-party CPA to review past audit and current documents needed to commence the FY 2022 audit. However, due to an emergency there was limited independent review of documents prior to being submitted to the auditor due to time constraints. ULMS continues to strengthen its accounting team and has hired a new Controller in July 2023. The new Controller is a licensed CPA with over 30 years accounting experience and over 10 years? experience as an independent auditor for a range of organizations including non-profits. The Controller will collaborate with the CFO to ensure there is accuracy in reporting, especially for major federal programs. Finding #: 2022-002Contact Person: Mansour Camara? Management has determined that the finding as written is misleading. The Schedule of Expenditures of Federal Awards (SEFA) prepared by ULMS initially contained errors. However, all errors were corrected by the time the draft financial statements were presented. There was no financial impact on the organization and the most significant issue on the SEFA schedule was a result of miscommunication with ULMS? funding source including the lack of clear identification of the funding source within the contract.Actions to be taken: ULMS migrated to a new and more sophisticated accounting system. This new system has more reporting and tracking capabilities which will enhance grant tracking and review of activities. These additional tools will aid management in overseeing future endeavors. In addition, ULMS will proactively contact the CFO or contract signer of the funding entity and confirm the source of funding for all grants over $100,000. ULMS will participate in more nonprofit conferences on a regional and national level.
2021-004
2022 ? 003 Federal Payment Policy Identification as a Repeat Finding: Repeat of Finding 2021-005Finding:The Organization does not have a written policy that complies with the federal payment standards established in 2 CFR 200.305.Criteria:Non-Federal entities other than States must follow the federal payment standards set out at 2 CFR 200.305. They must maintain written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability. Other criteria include but are not limited to consolidating advanced payments to cover anticipated cash needs for all awards, utilizing resources before requesting advanced payments and depositing advanced payments in insured accounts whenever possible.Condition and context:The Urban League has not adopted a federal payment policy that complies with federal standards. The written advance payment of federal funds procedure document utilized by the Organization does not address the criteria of 2 CFR 200.305.Cause:The Organization did not review 2 CFR 200.305 when drafting its federal payment procedures to ensure all required components were incorporated.Sample size and population:Sampling was not applicable to this finding.Effect:The result of the finding is that the Urban League is not in compliance with federal payment standards.Recommendation:Incorporate 2 CFR 200.305 into federal payment procedures.Question Costs:NoneManagement Response and Corrective Action Plan:See Corrective Action PlanContact Person: Mansour Camara, CFO
ULMS Corrective Action Plan for FY 21-22 Audit FindingsULMS faced significant challenges with the departure of its longtime CFO two months post fiscal year 2021. In addition, the third-party management company who had been responsible for the Partnership accounting, ceased the relationship abruptly without opportunity to smoothly transition the responsibility in-house to ULMS. Our external auditor does not prepare a Management Letter typically used to communicate with the Board of Directors and Governance issues that may not elevate to a finding. As such, significant findings are reflected in Section III ? Federal Award Findings and Questioned Costs.FY 2021 was the organization?s first single audit reporting requirement. ULMS engaged a third-party CPA to review past audit and current documents needed to commence the FY 2022 audit. However, due to an emergency there was limited independent review of documents prior to being submitted to the auditor due to time constraints. ULMS continues to strengthen its accounting team and has hired a new Controller in July 2023. The new Controller is a licensed CPA with over 30 years accounting experience and over 10 years? experience as an independent auditor for a range of organizations including non-profits. The Controller will collaborate with the CFO to ensure there is accuracy in reporting, especially for major federal programs. Finding #: 2022-003Contact Person: Mansour Camara? During the FY 2021 audit, the auditor recommended that ULMS formalize written federal payment procedures in compliance with required standards. ULMS developed procedures for advance federal payment which was sent to the auditor for feedback. There was no feedback proposing ULMS update its advance federal payment procedure until the issuance of this finding. The finding states a lack of written policy that complies with the federal payment standard per CFR 200.305. However, the recommendation instructs ULMS to formalize written procedures. Such procedures were in place during FY 2022.Actions to be taken: Notwithstanding the inconsistency between the finding and the recommendation provided by the auditor, ULMS prepared written procedures consistent with CFR 200.305 and recorded transactions consistent with that procedure for FY 2022. ULMS will update its accounting policy and procedures manual to create a written policy in addition to the procedures that have already been in place consistent with CFR 200.305.
2021-005
2022-004 Reporting ? Late submission of the Single Audit Reporting Package and Data Collection Form to the Federal Audit Clearinghouse (FAC)Federal program and award identification: AllIdentification as a Repeat Finding: Not a repeat findingFinding:The Organization did not file its annual 2022 Single Audit and Data Collection form timely.Criteria:The Single Audit Reporting Package and Data Collection Form shall be submitted to the Federal Audit Clearinghouse 30 days after receipt of the auditor?s report, or 9 months after the end of the fiscal year, whichever comes first.Condition and context:Submission of the Single Audit Reporting Package and Data Collection Form to the FAC was not completed within the timeframe required by the Uniform Guidance.During the audit we noted that the Single Audit Reporting Package and Data Collection Form is expected to be submitted to the FAC during September 2023 for the fiscal year ended June 30, 2022.Cause:The Organization hired a contracted CPA to assist in audit preparation. However, the CPA was unavailable due to emergency leave. As a result, the start of the audit was delayed by two months. Additionally, the matters reported in Findings 2022?001 and 2022-002 prolonged the time required to complete the audit.Sample size and population:Sampling was not applicable to this finding.Effect:Noncompliance with the Uniform Guidance could reduce access to future funding from Federal sources.Recommendation:While emergencies cannot be prevented, applying the recommendations in Findings 2022-001 and 2022-002 could help alleviate future delays.Question Costs:NoneManagement Response and Corrective Action Plan:See Corrective Action PlanContact Person:Mansour Camara, CFO
ULMS Corrective Action Plan for FY 21-22 Audit FindingsULMS faced significant challenges with the departure of its longtime CFO two months post fiscal year 2021. In addition, the third-party management company who had been responsible for the Partnership accounting, ceased the relationship abruptly without opportunity to smoothly transition the responsibility in-house to ULMS. Our external auditor does not prepare a Management Letter typically used to communicate with the Board of Directors and Governance issues that may not elevate to a finding. As such, significant findings are reflected in Section III ? Federal Award Findings and Questioned Costs.FY 2021 was the organization?s first single audit reporting requirement. ULMS engaged a third-party CPA to review past audit and current documents needed to commence the FY 2022 audit. However, due to an emergency there was limited independent review of documents prior to being submitted to the auditor due to time constraints. ULMS continues to strengthen its accounting team and has hired a new Controller in July 2023. The new Controller is a licensed CPA with over 30 years accounting experience and over 10 years? experience as an independent auditor for a range of organizations including non-profits. The Controller will collaborate with the CFO to ensure there is accuracy in reporting, especially for major federal programs. Finding #: 2022-004Contact Person: Mansour Camara? Management does not agree that this finding should be noted. As indicated in the beginning of the response, the auditor does not produce a management letter and as such, issues such as late submission to FAC are included as a finding instead of being included in management letter. Management had requested a September 2022 audit start date, but the auditor was only available until October 2022. The Board decided to delay the audit until a CPA could be hired in November 2022 to review the findings of previously issued audit report. The audit was rescheduled to start in December 2022 for an agreed upon March 2023 completion date. Management forwarded the audit schedules to the auditors in January 2023. The auditor further delayed the commencement of ULMS audit to focus on the audit of Urban League Village at Coleman School causing at least an additional 2-month delay. Next, the auditors waited an additional 2 months for a confirmation receipt from a grantor.Actions to be taken: Management will file the audited financials to FAC within 30 days of issuance of the financial statements. Management will ensure subsequent audits are submitted to FAC in a timely manner.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 28, 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 December 28, 2022, which was (1332 days ago).
What is a management decision? →Criteria:The Organization is responsible for maintaining accurate information about all federal programs and reporting requirements. The Organization is responsible for using this information to comply with the Uniform Guidance in carrying out federal programs.Sample Size and Population: N/ACondition and Context:The SEFA provided for audit contained errors in identifying program clusters and incomplete data regarding CFDA numbers for two non-major programs.Effect:Identifying information about programs informs the Organization as to compliance requirements that it must adhere to in carrying out the federal program it is contracted to perform.Cause:Grantor did not provide complete CFDA identifiers.Recommendation:The Organization must continue to increase its familiarity with federal grant compliance requirements and establish a process for timely identification of federal programs in order to ensure compliance with federal award programs and to ensure completeness and accuracy in SEFA reporting.Questioned Costs: NoneManagement Response:Management response is reported in the ?Corrective Action Plan? at the end of this report.Contact Person: Mansour Camara, CFO
The grantor indicated that they have not received the contract from the federal agency.Therefore, they could not provide a complete CFDA # to ULMS. ULMS is still yet to have acontract on file for one of the programs because the grantor still did not get the contract from thefederal agency.Actions to be taken: ULMS will continue to request CFDA numbers for federal programs fromthe grantor.
Identification as a Repeat Finding: Not a repeat finding.Finding:The Organization does not have a written policy that complies with the federal payment standards established in 2 CFR 200.305.Criteria:Non-Federal entities other than States must follow the federal payment standards set out at 2 CFR 200.305. They must maintain written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability.Condition and context:The Urban Leage has not adopted a federal payment policy that complies with federal standards.Sample size and population:Sampling was not applicable to this finding.Effect:The result of the finding is that the Urban League is not in compliance with federal payment standards.Recommendation:Formalize written federal payment procedures in compliance with required standards.Question Costs:NoneManagement Response and Corrective Action Plan:See Corrective Action PlanContact Person: Mansour Camara, CFO
ULMS just met the threshold for a single audit last year. Before that, we were not required tocreate this policy.Actions taken: ULMS established a written federal payment policy as of January 2022.
Federal Grantor: Department of Treasury, Program Title: Coronavirus Relief Fund, Federal CFDA Number: 21.019, Contract Number: 4120, Identification as a Repeat Finding: Not a repeat finding.Finding:The Organization did not retain documentation of modification to grant terms and compliance requirements that related to changes in allowable costs, the period of performance and reporting for the identified contract.Criteria:Per 2 CFR 200.305, financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.Condition and context:The Organization did not retain documentation of modifications to the grant terms and had to rely on documentation provided by the grantor to complete the audit.Sample size and population:Sampling was not applicable to this finding.Effect:The result of the finding is that the Urban League is did not maintain adequate documentation of necessary compliance requirements.Recommendation:Develop a system for maintaining grant agreements and related modifications in order to ensure that file retention is complete and that changes in grant terms are timely communicated within the Organization.Question Costs:NoneManagement Response and Corrective Action Plan:See Corrective Action PlanContact Person: Mansour Camara, CFO
The grantor indicated that there was a public emergency and the provisions in the contract werechanging swiftly, which is why they were communicating contract amendments directly with ourcase managers and not with our designated personnel for amendments. The amendments werecommunicated via email to the program staff. The grantor did indicate during the audit thatULMS complied with all contract requirements and amendments and delivered on alldeliverables.Actions to be taken: ULMS will inform the general staff that any direct communicationreceived from the grantor must be communicated with Management to ensure the documents aremaintained.
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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