COMMUNITY ACTION COUNCIL OF LEWIS, MASON AND THURSTON COUNTIES

EIN: 910818368

UEI: CMGCKVHEZRD8

Data as of August 27, 2026

COMMUNITY ACTION COUNCIL OF LEWIS, MASON AND THURSTON COUNTIES10 audit years5 findings
10
Audit Years
5
Total Findings
0
Repeat Findings

FY 2022-09-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on May 1, 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 November 1, 2023 (1030 days ago).

What is a management decision? →
2022-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSQUESTIONED COSTS

Results of Tests of Internal Controls Over Compliance and Compliance ? 93.568 ? We selected a sample of 25 transactions to test controls over compliance and compliance of payroll disbursement costs charged to the major program. We identified 3 instances of the 25 payroll transactions where the employee's timesheet was reviewed by the supervisor, but the contract charged in the general ledger did not agree to the actual hour allocation noted on the employee?s timesheet and personnel action notice. The errors noted resulted in over charges to the program of $775. The total sample population of the 25 payroll items tested was $28,187. 93.569 ? We selected a sample of 25 transactions to test controls over compliance and compliance of payroll disbursement costs charged to the major program. We identified 1 instance of the 25 payroll transactions where the employee's timesheet was reviewed by the supervisor, but the contract charged in the general ledger did not agree to the actual hour allocation noted on the employee?s timesheet and personnel action notice. The errors noted resulted in an under charge to the program of $165. The total sample population of the 25 payroll items tested was $28,696. Cause: The primary factor that contributed to the deficiencies was the lack of sufficient controls implemented to appropriately review and monitor payroll activity and ensure amounts were properly recorded in the general ledger. Effect: Payroll transactions were being processed incorrectly. Context: Management did not implement effective internal controls over payroll disbursements. Questioned costs: 93.568 ? Known questioned costs were $775 of over charges. 93.569 ? Known questioned costs were $165 of under charges. Repeat Finding: This is not a repeat finding. Recommendation: In order to ensure payroll transactions are properly reviewed, approved, and supporting documentation maintained, we recommend the CAC ensure controls over payroll procedures are operating effectively ? this includes implementing a review process over employee time allocation from timesheets to the general ledger. Views of Responsible Officials: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

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Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Low-Income Home Energy Assistance CFDA number: 93.568 Award number: F19-53101-410, F19-53101-428, F21-32606-069, F21-32607-069, F21-5310C-410, F21-63260A-069, F22-32606-069 Award period: 10/1/2020 ? 9/30/2024 Funding agency: U.S. Department of Health and Human Services Title: Community Services Block Grant CFDA number: 93.569 Award number: F20-3210C-009, F21-32101-009, F22-32101-009 Award period: 1/20/2020 ? 9/30/2023 Criteria: The CAC must establish internal control procedures over compliance with provisions of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), that require, among other things, that direct charges to federal awards be for allowable costs. To be an allowable cost, charges must be supported by appropriate documentation and be properly approved. The specific requirements for allowable activities are unique to each Federal Program and are found in the laws, regulations, and the provisions of each contract or grant agreement pertaining to the federal program. Condition: Results of Tests of Internal Controls Over Compliance and Compliance ? 93.568 ? We selected a sample of 25 transactions to test controls over compliance and compliance of payroll disbursement costs charged to the major program. We identified 3 instances of the 25 payroll transactions where the employee's timesheet was reviewed by the supervisor, but the contract charged in the general ledger did not agree to the actual hour allocation noted on the employee?s timesheet and personnel action notice. The errors noted resulted in over charges to the program of $775. The total sample population of the 25 payroll items tested was $28,187. 93.569 ? We selected a sample of 25 transactions to test controls over compliance and compliance of payroll disbursement costs charged to the major program. We identified 1 instance of the 25 payroll transactions where the employee's timesheet was reviewed by the supervisor, but the contract charged in the general ledger did not agree to the actual hour allocation noted on the employee?s timesheet and personnel action notice. The errors noted resulted in an under charge to the program of $165. The total sample population of the 25 payroll items tested was $28,696. Cause: The primary factor that contributed to the deficiencies was the lack of sufficient controls implemented to appropriately review and monitor payroll activity and ensure amounts were properly recorded in the general ledger. Effect: Payroll transactions were being processed incorrectly. Context: Management did not implement effective internal controls over payroll disbursements. Questioned costs: 93.568 ? Known questioned costs were $775 of over charges. 93.569 ? Known questioned costs were $165 of under charges. Repeat Finding: This is not a repeat finding. Recommendation: In order to ensure payroll transactions are properly reviewed, approved, and supporting documentation maintained, we recommend the CAC ensure controls over payroll procedures are operating effectively ? this includes implementing a review process over employee time allocation from timesheets to the general ledger. Views of Responsible Officials: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Condition: Results of Tests of Internal Controls Over Compliance and Compliance ? 93.568 ? We selected a sample of 25 transactions to test controls selected a sample of 25 transactions to test controls over compliance and compliance of payroll disbursement costs charged to the major program. We identified 3 instances of the 25 payroll transactions where the employee's timesheet was reviewed by the supervisor, but the contract charged in the general ledger did not agree to the actual hour allocation noted on the employee?s timesheet and personnel action notice. The errors noted resulted in over charges to the program of $775. The total sample population of the 25 payroll items tested was $28,187. 93.569 ? We selected a sample of 25 transactions to test controls over compliance and compliance of payroll disbursement costs charged to the major program. We identified 1 instance of the 25 payroll transactions where the employee's timesheet was reviewed by the supervisor, but the contract charged in the general ledger did not agree to the actual hour allocation noted on the employee?s timesheet and personnel action notice. The errors noted resulted in an under charge to the program of $165. The total sample population of the 25 payroll items tested was $28,696. Planned Corrective Action: Updated Payroll software to ensure correct coding to contracts worked and ensure reduction in manual errors resulting in miscoding Responsible Division/Office and Individual: Sarah Miranda, Chief Financial Officer Estimated Completion Date: 04/24/2023

About Activities Allowed or Unallowed →

FY 2021-09-30

FAC accepted this audit on February 6, 2023 — management decision was due August 6, 2023.

2021-003
Eligibility
QUESTIONED COSTS

Out of 40 participants examined, 1) three participants? income determination was not properly calculated. However, these three participants were still determined to be eligible for assistance after the re-recalculation, and 2) two participants received assistance which exceeded the total eligible benefits by $1,171. (0.5% of a total of $222,304 disbursements selected for testing). Questioned costs: $1,171 Context: Out of 40 participant files examined, we noted that 1) three participants' income determination were note property determined. However, they were still determined to be eligible for assistance after re-calculation., and 2) two participants received assistance which exceeded the total eligible benefits by $1,171. Cause: The CAC did not follow the eligibility criteria provided by the Federal agency, and human error in using the incorrect income to perform eligibility determination or the incorrect monthly rental payment to determine the amount of rental assistance. Effect: Two participants received assistance more than they were not eligible. Repeat Finding: No Recommendation: Checks and balances should be in pace for any numeric calculations in the determination of eligibility in this program. Views of responsible officials: Management?s response and corrective action plan is attached to our report.

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Federal Agency: U.S. Department of Treasury Federal Program Name: Emergency Rental Assistance Program Assistance Listing Number: 21.023 Federal Award Identification Number and Year: Not available Pass-Through Agency: Thurston County Pass-Through Number(s): 2021-TRAP-CAC-RA, 2021-COMTRAP-CAC-RA Award Period: 2/16/2021-12/31/2021, 4/6/2021-9/30/2022 Type of Finding Significant Deficiency in Internal Control over Compliance - Eligibility Other Matter - Non-Compliance with Eligibility Compliance Requirements Criteria or specific requirement: Per the cost principles in 2 CFR Part 200, Subpart E (Cost Principles), the non-federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. Condition: Out of 40 participants examined, 1) three participants? income determination was not properly calculated. However, these three participants were still determined to be eligible for assistance after the re-recalculation, and 2) two participants received assistance which exceeded the total eligible benefits by $1,171. (0.5% of a total of $222,304 disbursements selected for testing). Questioned costs: $1,171 Context: Out of 40 participant files examined, we noted that 1) three participants' income determination were note property determined. However, they were still determined to be eligible for assistance after re-calculation., and 2) two participants received assistance which exceeded the total eligible benefits by $1,171. Cause: The CAC did not follow the eligibility criteria provided by the Federal agency, and human error in using the incorrect income to perform eligibility determination or the incorrect monthly rental payment to determine the amount of rental assistance. Effect: Two participants received assistance more than they were not eligible. Repeat Finding: No Recommendation: Checks and balances should be in pace for any numeric calculations in the determination of eligibility in this program. Views of responsible officials: Management?s response and corrective action plan is attached to our report.

Corrective Action Plan

2021-003 Emergency Rental Assistance Program ? Assistance Listing No. 21.023 Recommendation: Checks and balances should be in pace for any numeric calculations in the determination of eligibility in this program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have since had a more robust verification process that the Housing team implemented which requires approval of the employee and their lead/supervisor. Name of the contact person responsible for corrective action: Sarah Miranda, Chief Financial Officer Planned completion date for corrective action plan: January 2023

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2021-004
Activities Allowed or Unallowed

Out of 40 disbursements tested, 6 did not have proper approval documentation prior to processing for payments. Questioned costs: None Context: Out of 40 disbursements tested, 6 did not have proper approval documentation prior to processing for payments. Cause: The CAC department management was not properly following its approval process for disbursements. Effect: The auditor noted no instances of noncompliance with the provisions of allowable activities/costs; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the CAC follow its policies and procedures to ensure each disbursement has proper approval documentation prior to processing for payments. Views of responsible officials: Management?s response and corrective action plan is attached to our report.

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Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus Relief Fund Assistance Listing Number: 21.019 Federal Award Identification Number and Year: Not available Pass-Through Agency: Thurston County, and Washington State Department of Agriculture Pass-Through Number(s): K-2721, 2021-ERAP-CAC-RA Award Period: 7/1/2020-11/30/2020 Type of Finding Significant Deficiency in Internal Control over Compliance - Allowable Activities Criteria or specific requirement: The CAC's Financial Policies and Procedures 2018 Final indicates that invoices, timesheets, and journal entries are reviewed and approved by the appropriate director or their designee who has the first-hand knowledge of the programs. Condition: Out of 40 disbursements tested, 6 did not have proper approval documentation prior to processing for payments. Questioned costs: None Context: Out of 40 disbursements tested, 6 did not have proper approval documentation prior to processing for payments. Cause: The CAC department management was not properly following its approval process for disbursements. Effect: The auditor noted no instances of noncompliance with the provisions of allowable activities/costs; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the CAC follow its policies and procedures to ensure each disbursement has proper approval documentation prior to processing for payments. Views of responsible officials: Management?s response and corrective action plan is attached to our report.

Corrective Action Plan

2021-004 Coronavirus Relief Fund ? Assistance Listing No. 21.019 Recommendation: The CAC follows its policies and procedures to ensure each disbursement has proper approval documentation prior to processing for payments. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We updated our workflow processes to identify approval process on various documentations that come through. Name of the contact person responsible for corrective action: Sarah Miranda, Chief Financial Officer Planned completion date for corrective action plan: January 2023

About Activities Allowed or Unallowed →
2021-005
Procurement & Suspension/Debarment

During our testing, we noted the CAC did not retain the documentation showing the result of verification that subrecipients were not suspended or debarred. Questioned costs: None Context: During our testing, we noted the CAC was unable to provide the documentation showing the result of verification was performed prior to entering into an agreement with a subrecipient to ensure the subrecipient was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause: The CAC did not retain the documentation after the verification was completed. Effect: Awards can be provided to organizations which are suspended or debarred from entering into government contracts. Repeat Finding: No Recommendation: We recommend the CAC follow its policies and procedures and ensure an adequate review process is in place to review potential subrecipients and contractors to determine they are not suspended or debarred.Views of responsible officials: Management?s response and corrective action plan is attached to our report.

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Federal Agency: U.S. Department of Treasury Federal Program Name: Emergency Rental Assistance Program Assistance Listing Number: 21.023 Federal Award Identification Number and Year: Not available Pass-Through Agency: Thurston County Pass-Through Number(s): 2021-TRAP-CAC-RA, 2021-COMTRAP-CAC-RA Award Period: 2/16/2021-12/31/2021, 4/6/2021-9/30/2022 Type of Finding Significant Deficiency in Internal Control over Compliance - Procurement, Suspension and Debarment Other Matter - Non-Compliance with Procurement, Suspension and Debarment Compliance Requirements Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The CAC should follow its policies and procedures to ensure compliance with those provisions. Condition: During our testing, we noted the CAC did not retain the documentation showing the result of verification that subrecipients were not suspended or debarred. Questioned costs: None Context: During our testing, we noted the CAC was unable to provide the documentation showing the result of verification was performed prior to entering into an agreement with a subrecipient to ensure the subrecipient was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause: The CAC did not retain the documentation after the verification was completed. Effect: Awards can be provided to organizations which are suspended or debarred from entering into government contracts. Repeat Finding: No Recommendation: We recommend the CAC follow its policies and procedures and ensure an adequate review process is in place to review potential subrecipients and contractors to determine they are not suspended or debarred.Views of responsible officials: Management?s response and corrective action plan is attached to our report.

Corrective Action Plan

2021-005 Emergency Rental Assistance Program ? Assistance Listing No. 21.023 Recommendation: The CAC follows its policies and procedures and ensure an adequate review process is in place to review potential subrecipients and contractors to determine they are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We understand that documentation for subrecipient contracting with Federal awards needs to have back-up documentation when verifying on the SAM website and not just doing a search without proof. Name of the contact person responsible for corrective action: Sarah Miranda, Chief Financial Officer Planned completion date for corrective action plan: January 2023

About Procurement and Suspension and Debarment →
2021-006
Cost Allowability / Period of Performance
QUESTIONED COSTS

1 out of 21 disbursements tested, a total of $2,178 payroll disbursements was charged to the federal award and get reimbursed prior to the beginning of the period of performance. Questioned costs: $2,178 Context: Out of 21 disbursements tested, 1 disbursement for a total of $2,178 was charged to the federal award and get reimbursed prior to the beginning of the period of performance. Cause: The CAC's department management was not properly tracking the grant period and obtained the approval from the funding agency about incurring expenditures prior to the beginning of the period of performance. Effect: The CAC was reimbursed for unallowable costs. Repeat Finding: No Recommendation: We recommend the CAC implement controls to ensure expenditures are recorded in the correct Federal grant year. Views of responsible officials: Management?s response and corrective action plan is attached to our report.

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Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus Relief Fund Assistance Listing Number: 21.019 Federal Award Identification Number and Year: Not available Pass-Through Agency: City of Lacey Award Period: 7/1/2020-11/30/2020 Type of Finding Significant Deficiency in Internal Control over Compliance - Allowable Costs and Period of Performance Other Matter - Non-Compliance with Allowable Costs and Period of Performance Compliance Requirements Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance. Condition: 1 out of 21 disbursements tested, a total of $2,178 payroll disbursements was charged to the federal award and get reimbursed prior to the beginning of the period of performance. Questioned costs: $2,178 Context: Out of 21 disbursements tested, 1 disbursement for a total of $2,178 was charged to the federal award and get reimbursed prior to the beginning of the period of performance. Cause: The CAC's department management was not properly tracking the grant period and obtained the approval from the funding agency about incurring expenditures prior to the beginning of the period of performance. Effect: The CAC was reimbursed for unallowable costs. Repeat Finding: No Recommendation: We recommend the CAC implement controls to ensure expenditures are recorded in the correct Federal grant year. Views of responsible officials: Management?s response and corrective action plan is attached to our report.

Corrective Action Plan

2021-006 Coronavirus Relief Fund ? Assistance Listing No. 21.019 Recommendation: The CAC implement controls to ensure expenditures are recorded in the correct Federal grant year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We make sure that time is verified to contracts that are valid and within their time frame. Name of the contact person responsible for corrective action: Sarah Miranda, Chief Financial Officer Planned completion date for corrective action plan: January 2023

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