EIN: 910823767
UEI: LCL9SBLQFUM7
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 27, 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 March 27, 2025 (518 days ago).
What is a management decision? →During testing of reporting, it was noted that, for one sample, documentation was not retained of approval of financial reporting. Questioned costs: None Context: A sample of 9 financial reports was made from a population of 54 total reports. Of the 9 sampled, 1 was missing evidence of authorized personnel review and approval. Cause: In this one instance, verbal approval was given rather than via emailed approval. Effect: Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, Sound Generations could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that Sound Generations is entitled to under the terms of the grant. Repeat Finding: No. Recommendation: CLA recommends that documentation is retained as proof of authorized personnel review. Views of responsible officials: Please see the attached Management’s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Type of Finding: Significant Deficiency in Internal Control over Compliance – Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Aging Cluster Assistance Listing Number: 93.044 / 93.045 / 93.053 Federal Award Identification Number and Year: DA23-1109-2023 Pass-Through Agency: City of Seattle Pass-Through Number(s): DA23-1109 Award Period: January 1, 2023 through December 31, 2023 Criteria or specific requirement: 2 CFR 200.303(a) states that a 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)." Condition: During testing of reporting, it was noted that, for one sample, documentation was not retained of approval of financial reporting. Questioned costs: None Context: A sample of 9 financial reports was made from a population of 54 total reports. Of the 9 sampled, 1 was missing evidence of authorized personnel review and approval. Cause: In this one instance, verbal approval was given rather than via emailed approval. Effect: Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, Sound Generations could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that Sound Generations is entitled to under the terms of the grant. Repeat Finding: No. Recommendation: CLA recommends that documentation is retained as proof of authorized personnel review. Views of responsible officials: Please see the attached Management’s Corrective Action Plan.
Type of Finding: Significant Deficiency in Internal Control over Compliance - Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Aging Cluster Assistance Listing Number; 93.044 / 93.045 / 93.053 Federal Award Identification Number and Year: DA23-1109-2023 Pass-Through Agency: City of Seattle Pass-Through Number(s): DA23-1109 Award Period: January 1, 2023 through December 31, 2023 Criteria or specific requirement: 2 CFR 200.303(a) states that a 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 the Organization of the Treadway Commission (COSO).” Condition: During testing of reporting, it was noted that, for one sample, documentation was not retained of approval of financial reporting. Questioned Costs: None Context: A sample of 9 financial reports was made from a population of 54 total reports. Of the 9 sampled, 1 was missing evidence of authorized personnel review and approval. Cause: In this one instance, verbal approval was given rather than emailed approval. Effect: Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, Sound Generations could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that Sound Generations is entitled to under the terms of the grant. Repeat Finding: No. Recommendation: CLA recommends that documentation is retained as proof of authorized personnel review. Views of responsible officials and planned corrective actions: Sound Generations agrees with the finding. Sound Generations has revised its approval process to include digital signatures with time stamps by authorized personnel on all documentation rather than emailed approvals. Responsible Official: Carlos Rojas, Chief Financial Officer; Christina Hannan, Controller Anticipated Completion Date: March 31, 2024
During testing of payroll, it was noted that three employee's wages had been misallocated between contracts. These misallocations occurred due to clerical errors and inadequate monitoring and review of the allocation process. Questioned costs: None Context: A sample of 60 payroll samples were made from a population of over 250 individual employee paychecks. Of the 60 sampled, three samples had wages misallocated. The first was misallocated between the Community Dining and Meals on Wheels contracts. The second had misallocations between two funding sources under the Meals on Wheels contract. The third had misallocations between the Meals on Wheels contract and another funder. Cause: In one instance, a manual intervening calculation needed to be made to a normally automated process due to an illness at the executive level during time study updates. As a result of a clerical error, the allocations between the contracts were accidentally switched and the misallocation was not caught during review. In the remaining two instances, a formula error resulted in a misallocation of wages between funding sources. Effect: The misallocation of expenses could impact the accuracy of financial reporting for the major program and could result in noncompliance with federal regulations. Repeat Finding: No. Recommendation: CLA recommends that Sound Generations emphasize the importance of its procedures for monitoring and reviewing the allocation of wages between contracts and provide training to the individuals responsible for the allocation of expenses. Views of responsible officials: Please see the attached Management’s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Type of Finding: Significant Deficiency in Internal Control over Compliance – Activities Allowed or Unallowed, Allowable Costs / Cost Principles Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Aging Cluster Assistance Listing Number: 93.044 / 93.045 / 93.053 Federal Award Identification Number and Year: DA23-1109-2023, DA23-1176-2023 Pass-Through Agency: City of Seattle Pass-Through Number(s): DA23-1109, DA23-1176 Award Period: January 1, 2023 through December 31, 2023 Criteria or specific requirement: 2 CFR 200.303(a) states that a 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)." Condition: During testing of payroll, it was noted that three employee's wages had been misallocated between contracts. These misallocations occurred due to clerical errors and inadequate monitoring and review of the allocation process. Questioned costs: None Context: A sample of 60 payroll samples were made from a population of over 250 individual employee paychecks. Of the 60 sampled, three samples had wages misallocated. The first was misallocated between the Community Dining and Meals on Wheels contracts. The second had misallocations between two funding sources under the Meals on Wheels contract. The third had misallocations between the Meals on Wheels contract and another funder. Cause: In one instance, a manual intervening calculation needed to be made to a normally automated process due to an illness at the executive level during time study updates. As a result of a clerical error, the allocations between the contracts were accidentally switched and the misallocation was not caught during review. In the remaining two instances, a formula error resulted in a misallocation of wages between funding sources. Effect: The misallocation of expenses could impact the accuracy of financial reporting for the major program and could result in noncompliance with federal regulations. Repeat Finding: No. Recommendation: CLA recommends that Sound Generations emphasize the importance of its procedures for monitoring and reviewing the allocation of wages between contracts and provide training to the individuals responsible for the allocation of expenses. Views of responsible officials: Please see the attached Management’s Corrective Action Plan.
Type of Finding: Significant Deficiency in Internal Control over Compliance – Activities Allowed or Unallowed, Allowable Costs / Cost Principles Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Aging Cluster Assistance Listing Number; 93.044 / 93.045 / 93.053 Federal Award Identification Number and Year: DA23-1109-2023, DA23-1176-2023 Pass-Through Agency: City of Seattle Pass-Through Number(s): DA23-1109, DA23-1176 Award Period: January 1, 2023 through December 31, 2023 Criteria or specific requirement: 2 CFR 200.303(a) states that a 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 the Organization of the Treadway Commission (COSO).” Condition: During testing of payroll, it was noted that three employee’s wages had been misallocated between contracts. These misallocations occurred due to clerical errors and inadequate monitoring and review of the allocation process. Questioned Costs: None Context: A sample of 60 payroll samples were made from a population of over 260 individual employee paychecks. Of the 60 sampled, three samples had wages misallocated. The first was misallocated between the Community Dining and Meals on Wheels contracts. The second had misallocations between two funding sources under the Meals on Wheels contract. The third had misallocations between the Meals on Wheels contract and another funder. Cause: In one instance, a manual intervening calculation needed to be made to a normally automated process due to an illness at the executive level during time study updates. As a result of a clerical error, the allocations between the contracts were accidentally switched and the misallocation was not caught during review. In the remaining two instances, a formula error resulted in a misallocation of wages between funding sources. Effect: The misallocation of expenses could impact on the accuracy of financial reporting for the major program and could result in noncompliance with federal regulations. Repeat Finding: No. Recommendation: CLA recommends that Sound Generations emphasize the importance of its procedures for monitoring and reviewing the allocation of wages between contracts and provide training to the individuals responsible for the allocation of expenses. Views of responsible officials and planned corrective actions: Sound Generations Agrees with the finding. Sound Generations has reviewed and revised its procedures to include reviews at intermediary steps as well as streamlined its automation to allow for less opportunity for manual inputs and clerical errors. Responsible Official: Carlos Rojas, Chief Financial Officer; Christina Hannan, Controller Anticipated Completion Date: June 30, 2024
FAC accepted this audit on March 12, 2024 — management decision was due September 12, 2024.
CLA noted one sample in which federal funds were expended on unallowable costs. Questioned costs: $85 known, $910 likely Context: A sample of 25 was made from a population of 942 nonpayroll-related general disbursement costs charged to the major program. Of the 25 sampled costs, one was found to be out of compliance with the requirements of Allowable Costs / Cost Principles, totaling $85. Sampled nonpayroll-related general disbursement costs totaled $24,560. General disbursements totaled $263,090 of the $1,706,762 tracked to the major program. Extrapolating the error to the actual costs reported on the SEFA results in a likely questioned cost amount of $910. Cause: The individual in charge of entering the purchase into Microix did not code the alcoholic beverages to a separate general ledger account that was established to track unallowable costs so that they are not charged to the federal programs. Effect: Without adequate controls in place to ensure costs are allowable, Sound Generations runs the risk of being out of compliance with not only the major program but all federal programs. Repeat Finding: No. Recommendation: CLA recommends that emphasis be placed (via an employee training or organization-wide email) on specifically disallowed costs and the importance of tracking these costs separately so that they are not charged to federal programs. Views of responsible officials: Please see the attached Management’s Corrective Action Plan.
Show full finding ▾Hide full finding ▴Type of Finding: • Significant Deficiency in Internal Control over Compliance – Allowable Costs/Cost Principles • Other Matter – Non-Compliance with Allowable Costs/Cost Principles Compliance Requirements Federal Agency: Department of Transportation Federal Program Name: Enhanced Mobility of Seniors and Individuals with Disabilities Assistance Listing Number: 20.513 Federal Award Identification Number and Year: PTD0287-2022 Pass-Through Agency: WADOT Pass-Through Number(s): PTD0287 Award Period: July 1, 2021 through June 30, 2023 Criteria or specific requirement: 2 CFR 200.423 specifically identifies alcoholic beverages as unallowable costs. Condition: CLA noted one sample in which federal funds were expended on unallowable costs. Questioned costs: $85 known, $910 likely Context: A sample of 25 was made from a population of 942 nonpayroll-related general disbursement costs charged to the major program. Of the 25 sampled costs, one was found to be out of compliance with the requirements of Allowable Costs / Cost Principles, totaling $85. Sampled nonpayroll-related general disbursement costs totaled $24,560. General disbursements totaled $263,090 of the $1,706,762 tracked to the major program. Extrapolating the error to the actual costs reported on the SEFA results in a likely questioned cost amount of $910. Cause: The individual in charge of entering the purchase into Microix did not code the alcoholic beverages to a separate general ledger account that was established to track unallowable costs so that they are not charged to the federal programs. Effect: Without adequate controls in place to ensure costs are allowable, Sound Generations runs the risk of being out of compliance with not only the major program but all federal programs. Repeat Finding: No. Recommendation: CLA recommends that emphasis be placed (via an employee training or organization-wide email) on specifically disallowed costs and the importance of tracking these costs separately so that they are not charged to federal programs. Views of responsible officials: Please see the attached Management’s Corrective Action Plan.
Type of Finding: • Significant Deficiency in Internal Control over Compliance – Allowable Costs/Cost Principles • Other Matter – Non-Compliance with Allowable Costs/Cost Principles Compliance Requirements Federal Agency: Department of Transportation Federal Program Name: Enhanced Mobility of Seniors and Individuals with Disabilities Assistance Listing Number: 20.513 Federal Award Identification Number and Year: PTD0287-2022 Pass-Through Agency: WADOT Pass-Through Number(s): PTD0287 Award Period: July 1, 2021 through June 30, 2023 Criteria or specific requirement: 2 CFR 200.423 specifically identifies alcoholic beverages as unallowable costs. Condition: CLA noted one sample in which federal funds were expended on unallowable costs. Questioned costs: $85 known, $910 likely Context: A sample of 25 was made from a population of 942 nonpayroll-related general disbursement costs charged to the major program. Of the 25 sampled costs, one was found to be out of compliance with the requirements of Allowable Costs / Cost Principles, totaling $85. Sampled nonpayroll-related general disbursement costs totaled $24,560. General disbursements totaled $263,090 of the $1,706,762 tracked to the major program. Extrapolating the error to the actual costs reported on the SEFA results in a likely questioned cost amount of $910. Cause: The individual in charge of entering the purchase into Microix did not code the alcoholic beverages to a separate general ledger account that was established to track unallowable costs so that they are not charged to the federal programs. Effect: Without adequate controls in place to ensure costs are allowable, Sound Generations runs the risk of being out of compliance with not only the major program but all federal programs. Repeat Finding: No. Recommendation: CLA recommends that emphasis be placed (via an employee training or organization-wide email) on specifically disallowed costs and the importance of tracking these costs separately so that they are not charged to federal programs. Views of responsible officials and planned corrective actions: Sound Generations agrees with the finding. Sound Generations has implemented the following additional practices and policies: 1) Allowable costs and expenditures in Federal Grants and Contracts training to all Authorized Purchasers. - to be completed in the first quarter of 2024 and annually thereafter. 2) Additional General Ledger Codes to record unallowable costs: implemented in July 2023 3) Automating unallowable expenses to be excluded in grant and contract reporting and expense reimbursements. - implemented in July 2023 Responsible Official: Chief Financial Officer; Christina Hannan, Controller Anticipated Completion Date: March 31, 2024
FAC accepted this audit on May 1, 2023 — management decision was due November 1, 2023.
During our testing of Sound Generations? compliance with the Activities Allowed or Unallowed, & Allowable Costs/Cost Principles compliance requirements, we noted that in-kind expenditures (rent and supplies), intercompany expenditures, and late fees were charged to the Aging Cluster. Cause: These expenditures were allocated out amongst other cost pools; thus, management did not realize unallowed costs were getting charged to the Aging Cluster. In some cases, management did not realize these items were unallowable costs. Effect: Without adequate training and controls in place to ensure costs are allowable, Sound Generations could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement Sound Generations is entitled to under the terms of the grant. Questioned Costs: Known questioned costs were $18,362. Likely questioned costs were $1,064,524. Context: During our testing we sampled 40 items within the expenditure population, noting that of the total items tested, 4 items amounting to $18,362 were unallowable costs. This condition was identified per review of Sound Generations? compliance with specified requirements using a statistically valid sample. Repeat Finding: No. Recommendation: Sound Generations should improve internal controls by training employees on activities and costs unallowable under federal grants. Views of Responsible Officials and Planned Corrective Actions: Sound Generations agrees with the finding. Sound Generations has implemented a new Procurement and Expense reporting software. This allows us to enforce our Procurement policy, specifically for there to be multiple reviews of every expenditure and verify that costs are always allocated according to grant allowance, federal guidance and general accounting guidance. Additionally, all accounting staff are required to attend federal grants compliance training within the first 90 days of employment and follow up trainings are encouraged no less frequently than biannually. See the attached unaudited corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-006 Unallowed Costs ? Material Weakness in Internal Control and Instance of Non-Compliance Program: Aging Cluster CFDA No.: 93.044, 93.045, 93.053 Federal Grantor: Department of Health and Human Services Award No: DA20-1109, DA21-1109, DA21-1176, DA21-1818, DA21-1874 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Criteria: 2 CFR Part 200.404, Reasonable costs, states that a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally funded. In determining reasonableness of a given cost, consideration must be given to: a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. b) The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award. c) Market prices for comparable goods or services for the geographic area. d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award's cost. 2 CFR Part 200.434, Contributions and donations, states the value of services and property donated to the non-Federal entity may not be charged to the Federal award either as a direct or indirect cost. 2 CFR Part 200.441, Fines, penalties, damages and other settlements, states that costs resulting from non-Federal entity violations of, alleged violations of, or failure to comply with, Federal, state, tribal, local or foreign laws and regulations are unallowable. Condition: During our testing of Sound Generations? compliance with the Activities Allowed or Unallowed, & Allowable Costs/Cost Principles compliance requirements, we noted that in-kind expenditures (rent and supplies), intercompany expenditures, and late fees were charged to the Aging Cluster. Cause: These expenditures were allocated out amongst other cost pools; thus, management did not realize unallowed costs were getting charged to the Aging Cluster. In some cases, management did not realize these items were unallowable costs. Effect: Without adequate training and controls in place to ensure costs are allowable, Sound Generations could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement Sound Generations is entitled to under the terms of the grant. Questioned Costs: Known questioned costs were $18,362. Likely questioned costs were $1,064,524. Context: During our testing we sampled 40 items within the expenditure population, noting that of the total items tested, 4 items amounting to $18,362 were unallowable costs. This condition was identified per review of Sound Generations? compliance with specified requirements using a statistically valid sample. Repeat Finding: No. Recommendation: Sound Generations should improve internal controls by training employees on activities and costs unallowable under federal grants. Views of Responsible Officials and Planned Corrective Actions: Sound Generations agrees with the finding. Sound Generations has implemented a new Procurement and Expense reporting software. This allows us to enforce our Procurement policy, specifically for there to be multiple reviews of every expenditure and verify that costs are always allocated according to grant allowance, federal guidance and general accounting guidance. Additionally, all accounting staff are required to attend federal grants compliance training within the first 90 days of employment and follow up trainings are encouraged no less frequently than biannually. See the attached unaudited corrective action plan.
Finding 2021-006 ? Unallowable Costs Condition: During our testing of the Organization?s compliance with the Activities Allowed or Unallowed, & Allowable Costs/Cost Principles compliance requirements, we noted that in-kind expenditures (rent and supplies), intercompany expenditures, and late fees were charged to the Aging Cluster. Recommendations: The Organization should improve internal controls by training employees on activities and costs unallowable under federal grants. Name of Contact Persons responsible for corrective action: Carlos Rojas, Chief Financial Officer; Christina Hannan, Controller Corrective Action taken in 2022: Sound Generations agrees with the finding. We would like to note that the intercompany expenditures are in accordance with the grant as written and we maintain clear records for reconciliation with the funder for reimbursement rates to intercompany entities. We only include the costs according to the reimbursement rates when reporting to the funder per the grant guidelines. There is no duplication or incorrect or excess billing of costs to any Funder. The agency included $14,961 in in-kind rent and 292.50 in in-kind supplies in 1 month in the Funder expenses and similarly applied combined program expenses against the in-kind funding match. As such, the agency has already implemented processes by which in-kind and other directly funded expenditures are clearly excluded from erroneously being either charged to another funder, or reported as program expenditures to other funders, except in total funding match reports. Worth noting is that this particular contract is not cost reimbursement, thus no in-kind expenses were charged or billed to the grant for the 1 month the error occurred. The agency included $3.96 in vendor late fees in the total reimbursement request to a grant. Sound Generations has implemented a new Procurement and Expense reporting software. This allows us to enforce our Procurement policy, specifically for there to be multiple reviews of every expenditure and verify that costs are always allocated according to grant allowance, federal guidance and general accounting guidance. Additionally, all accounting staff are required to attend federal grants compliance training within the first 90 days of employment and follow up trainings are encouraged no less frequently than biannually.
For employees who work in multiple programs, their time is allocated based on estimated allocation rates (obtained from semi-annual time studies where the employees report actual time spent on the Aging Cluster Program). When payroll and related costs were charged in the accounting system, they were charged based on these allocated rates. Three hundred and sixty-seven timesheets were tested during the audit, and all were charged based on allocated rates. Cause: Sound Generations did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the Aging Cluster to the actual expenditures incurred. Effect: Without adequate controls in place to ensure costs based on allocations are reasonable and reconcile to the actual time spent on the program, Sound Generations could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement Sound Generations is entitled to under the terms of the grant. Questioned Costs: Questioned costs are not able to be determined. Context: This is a condition identified per review of Sound Generations? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits for the Aging Cluster in 2021 were $2,519,848. Repeat Finding: No. Recommendation: We recommend that Sound Generations implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR 200.430. Views of Responsible Officials and Planned Corrective Actions: Sound Generations agrees with the finding. Management has implemented a final review process where all allocated payroll costs are reviewed two times per year to verify that all employees participate in time studies and that allocations of payroll costs are allocated according to those time studies. See the attached unaudited corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-007 Payroll Costs ? Material Weakness in Internal Control and Instance of Non-Compliance Program: Aging Cluster CFDA No.: 93.044, 93.045, 93.053 Federal Grantor: Department of Health and Human Services Award No: DA20-1109, DA21-1109, DA21-1176, DA21-1818, DA21-1874 Compliance Requirements: Activities Allowed/Unallowed and Allowable Costs/Cost Principles Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: For employees who work in multiple programs, their time is allocated based on estimated allocation rates (obtained from semi-annual time studies where the employees report actual time spent on the Aging Cluster Program). When payroll and related costs were charged in the accounting system, they were charged based on these allocated rates. Three hundred and sixty-seven timesheets were tested during the audit, and all were charged based on allocated rates. Cause: Sound Generations did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the Aging Cluster to the actual expenditures incurred. Effect: Without adequate controls in place to ensure costs based on allocations are reasonable and reconcile to the actual time spent on the program, Sound Generations could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement Sound Generations is entitled to under the terms of the grant. Questioned Costs: Questioned costs are not able to be determined. Context: This is a condition identified per review of Sound Generations? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits for the Aging Cluster in 2021 were $2,519,848. Repeat Finding: No. Recommendation: We recommend that Sound Generations implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR 200.430. Views of Responsible Officials and Planned Corrective Actions: Sound Generations agrees with the finding. Management has implemented a final review process where all allocated payroll costs are reviewed two times per year to verify that all employees participate in time studies and that allocations of payroll costs are allocated according to those time studies. See the attached unaudited corrective action plan.
Finding 2021-007 Time Studies Condition: For employees who work in multiple programs, their time is allocated based on estimated allocation rates (obtained from semi-annual time studies). These employees did not track and report their time based on actual time spent on Aging Cluster programs, and instead tracked total hours worked. When payroll and related costs were charged in the accounting system, they were charged based on the allocated rates. There was no procedure in place to determine if a true-up was necessary from allocated costs. Three hundred and sixty-seven timesheets were tested during the audit, and all were charged based on allocated rates. Recommendation: We recommend that Sound Generations implement policies and procedures to review for any necessary budget to actual adjustments, and we recommend that sufficient documentation be maintained to support any adjustments made as required by 2 CFR 200.430. Name of Contact Persons responsible for corrective action: Carlos Rojas, Chief Financial Officer; Christina Hannan, Controller Corrective Action taken in 2022: Sound Generations agrees with the finding. Of the 367 timesheets reviewed, and the thousands of timesheets that were not reviewed, we had one employee who had time allocated to multiple departments and was not participating in the semi-annual time study process. This employee?s allocations were established prior to the allocation review process, where the Controller reviews all allocations and job assignments for new employees and then adds them to the semi-annual time study schedule. Additionally, this employee worked in the two departments that are funded based upon deliverables and not expense reimbursement, so the payroll allocations weren?t part of our secondary review. As such, we have implemented a final review process where all allocated employees are reviewed in September and March to verify that they are scheduled for semi-annual time studies. Additionally, we will ask all employees who work in multiple departments to sign an attestation that the time study remains an accurate record of their time no less often than quarterly. Worth noting: there was no incorrect billing because of this error.
We noted that Sound Generations allocated payroll expenditures, including wages and fringe benefits, to the Aging Cluster during 2021 based on allocation workbooks pulling departmental and program allocations from pivot tables. On a monthly basis, people and related program wages are copied and pasted into these workbooks based on payroll system breakouts. In April 2021, prior month wages were not wiped from the workbook before April wages were pasted in, thus the fringe benefit allocations charged exceeded the correct amount for that month. Cause: The monthly benefit allocation workbooks and pivot tables were not reviewed in April 2021. Effect: Without adequate controls in place to ensure benefit allocation workbooks are accurate, Sound Generations could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement Sound Generations is entitled to under the terms of the grant. Questioned Costs: Known and likely questioned costs are below the reporting threshold. Context: This is a condition identified per review of Sound Generations? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits for the Aging Cluster in 2021 were $2,519,848. Repeat Finding: No. Recommendation: Sound Generations should add a level of review to allocation workbooks to ensure preparation was done correctly. Views of Responsible Officials and Planned Corrective Actions: Sound Generations agrees with the finding. The agency has changed its process to include reviews of the workbooks and final results that tie to the actual expenditures. Automations now include flags and warnings when calculations are out of balance. See the attached unaudited corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-008 Fringe Benefits ? Significant Deficiency in Internal Control and Instance of Non-Compliance Program: Aging Cluster CFDA No.: 93.044, 93.045, 93.053 Federal Grantor: Department of Health and Human Services Award No: DA20-1109, DA21-1109, DA21-1176, DA21-1818, DA21-1874 Compliance Requirements: Activities Allowed/Unallowed and Allowable Costs/Cost Principles Criteria: 2 CFR 200.430, Compensation ? personal services, states that compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits which are addressed in ? 200.431. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity, consistently applied to both Federal and non-Federal activities, and includes reasonable amounts for activities contributing and directly related to work under an agreement. Condition: We noted that Sound Generations allocated payroll expenditures, including wages and fringe benefits, to the Aging Cluster during 2021 based on allocation workbooks pulling departmental and program allocations from pivot tables. On a monthly basis, people and related program wages are copied and pasted into these workbooks based on payroll system breakouts. In April 2021, prior month wages were not wiped from the workbook before April wages were pasted in, thus the fringe benefit allocations charged exceeded the correct amount for that month. Cause: The monthly benefit allocation workbooks and pivot tables were not reviewed in April 2021. Effect: Without adequate controls in place to ensure benefit allocation workbooks are accurate, Sound Generations could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement Sound Generations is entitled to under the terms of the grant. Questioned Costs: Known and likely questioned costs are below the reporting threshold. Context: This is a condition identified per review of Sound Generations? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits for the Aging Cluster in 2021 were $2,519,848. Repeat Finding: No. Recommendation: Sound Generations should add a level of review to allocation workbooks to ensure preparation was done correctly. Views of Responsible Officials and Planned Corrective Actions: Sound Generations agrees with the finding. The agency has changed its process to include reviews of the workbooks and final results that tie to the actual expenditures. Automations now include flags and warnings when calculations are out of balance. See the attached unaudited corrective action plan.
Finding 2021-008 Deficiency in Internal Control for Payroll Benefits Condition: We noted that Sound Generations allocated payroll expenditures, including wages and fringe benefits, to the Aging Cluster during 2021 based on allocation workbooks pulling departmental and program allocations from pivot tables. On a monthly basis, people and related program wages are copied and pasted into these workbooks based on payroll system breakouts. In April 2021, prior month wages were not wiped from the workbook before April wages were pasted in, thus the fringe benefit allocations charged exceeded the correct amount for that month. Recommendations: The Organization should add a level of review to allocation workbooks to ensure preparation was done correctly. Name of Contact Persons responsible for corrective action: Carlos Rojas, Chief Financial Officer; Christina Hannan, Controller Corrective Action taken in 2022: Sound Generations agrees with the finding. The agency has changed its process to include reviews of the workbooks and final results that tie to the actual expenditures. Automations now include flags and warnings when calculations are out of balance.
Finding 2021-009 Ransomware Attacks ? Material Weakness in Internal Control and Instance of Non-Compliance Program: All federal programs CFDA No.: All federal programs Federal Grantor: Department of Housing and Urban Development, Department of Transportation, Department of Health and Human Services Award No: DA21-1477, 10153, 10215, PTD0061, PTD0287, 1074-19-JAS, DA21-1874, DA21-1109, DA21-1176, DA21-1818 Compliance Requirements: Special tests and provisions Finding and Recommendation: Two ransomware attacks occurred in 2021. The attacker had access to electronic health information and personally identifiable information during the breach. Sound Generations should improve cyber security in accordance with recommendations provided by industry experts. Views of Responsible Officials and Planned Corrective Actions: Sound Generations agrees with the finding. Sound Generations has taken steps to improve cyber security. See the attached unaudited corrective action plan. See Section II, finding 2021-005 for further description of the criteria, condition, cause, effect, recommendations and views of responsible officials and planned corrective actions for this finding.
Show full finding ▾Hide full finding ▴Finding 2021-009 Ransomware Attacks ? Material Weakness in Internal Control and Instance of Non-Compliance Program: All federal programs CFDA No.: All federal programs Federal Grantor: Department of Housing and Urban Development, Department of Transportation, Department of Health and Human Services Award No: DA21-1477, 10153, 10215, PTD0061, PTD0287, 1074-19-JAS, DA21-1874, DA21-1109, DA21-1176, DA21-1818 Compliance Requirements: Special tests and provisions Finding and Recommendation: Two ransomware attacks occurred in 2021. The attacker had access to electronic health information and personally identifiable information during the breach. Sound Generations should improve cyber security in accordance with recommendations provided by industry experts. Views of Responsible Officials and Planned Corrective Actions: Sound Generations agrees with the finding. Sound Generations has taken steps to improve cyber security. See the attached unaudited corrective action plan. See Section II, finding 2021-005 for further description of the criteria, condition, cause, effect, recommendations and views of responsible officials and planned corrective actions for this finding.
Finding 2021-009 Weakness in IT Control Environment Condition: Two ransomware attacks occurred in 2021. The attacker could have accessed electronic health information and personally identifiable information during the breach. Recommendations: Sound Generations should improve cyber security in accordance with recommendations provided by industry experts. Name of Contact Persons responsible for corrective action: Carlos Rojas, Chief Financial Officer; Christina Hannan, Controller; John Gleichman, IT Director Corrective Action taken in 2021: Sound Generations agrees with the finding. Sound Generations has adopted the cybersecurity best practices identified in The Cybersecurity Act of 2015 to include: 13) Moved the primary computing network from an on-premises Active Directory to the cloud-based Microsoft 365 platform and enforced multi-factor authentication for access on all accounts. 14) Azure-joined all workstations and enforced BitLocker encryption as part of this process. 15) Enforced multi-factor authentication for all access to the downtown network. 16) Implemented Windows Defender for Endpoint on all workstations to provide integrated endpoint protection. 17) Implemented Windows Defender for Office to provide additional email/attachment protection. 18) Implemented a cloud-based backup for Microsoft 365 with multi-factor authentication for all administrators. 19) Implemented a staff security training and phishing test system to enforce quarterly staff security trainings. 20) Arranged for a comprehensive HIPAA Security Assessment to identify deficiencies in our HIPPA policies and procedures. 21) Arranged for a comprehensive Technical Security Assessment to perform penetration testing on our firewall and verify that Microsoft 365 settings are optimal. 22) Updated its privacy and security policies and procedures. 23) Updated a new security rule risk mitigation plan; and 24) Performed a new security rule risk analysis.
Sound Generations did not submit their data collection form as of September 30, 2022. Cause: Financial statements were not completed by September 30, 2022. Effect: The federal government was unaware of the 2021 audit results for all of 2022 and part of 2023. Questioned Costs: None. Context: Sound Generations did not submit their data collection form as of September 30, 2022. Recommendations: Sound Generations should ensure preparation of required information is accurately completed and reported by the imposed deadlines. Views of Responsible Officials and Planned Corrective Actions: Sound Generations agrees with the finding. Due to the cyber-attack that occurred in 2021 and subsequent class action lawsuit, the audit report was delayed awaiting the results of the settlement which was final in January of 2023. Sound Generations will ensure preparation of required information is accurately completed and reported by the imposed deadlines. See the attached unaudited corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-010 ? Late Submission of Data Collection Form - Significant Deficiency in Internal Control and Instance of Non-Compliance Program: All federal programs CFDA No.: All federal programs Federal Grantor: Department of Housing and Urban Development, Department of Transportation, Department of Health and Human Services Award No. and Year: DA21-1477, 10153, 10215, PTD0061, PTD0287, 1074-19-JAS, DA21-1874, DA21-1109, DA21-1176, DA21-1818 Compliance Requirements: Reporting Criteria: According to Uniform Guidance 2 CFR 200.512(a), non-federal entities that expend $750,000 or more of federal awards in one year are required to have a single audit and complete the related data collection form within the Federal Audit Clearinghouse within 30 days of receipt of the auditor?s report or 9 months after the end of the fiscal year ? whichever comes first. Condition: Sound Generations did not submit their data collection form as of September 30, 2022. Cause: Financial statements were not completed by September 30, 2022. Effect: The federal government was unaware of the 2021 audit results for all of 2022 and part of 2023. Questioned Costs: None. Context: Sound Generations did not submit their data collection form as of September 30, 2022. Recommendations: Sound Generations should ensure preparation of required information is accurately completed and reported by the imposed deadlines. Views of Responsible Officials and Planned Corrective Actions: Sound Generations agrees with the finding. Due to the cyber-attack that occurred in 2021 and subsequent class action lawsuit, the audit report was delayed awaiting the results of the settlement which was final in January of 2023. Sound Generations will ensure preparation of required information is accurately completed and reported by the imposed deadlines. See the attached unaudited corrective action plan.
Finding 2021-010 ? Late Submittance of Data Collection Form Condition: Sound Generations did not submit their data collection form as of September 30, 2022. Recommendations: Sound Generations should ensure preparation of required information is accurately completed and reported by the imposed deadlines. Views of Responsible Officials: Sound Generations agrees with the finding. Due to the cyber-attack that occurred in 2021 and subsequent class action lawsuit, the audit report was delayed to await the results of the settlement which was final in January of 2023. Sound Generations will ensure preparation of required information is accurately completed and reported by the imposed deadlines.
FAC accepted this audit on July 11, 2019 — management decision was due January 11, 2020.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-004
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-005
FAC accepted this audit on August 20, 2018 — management decision was due February 20, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-002
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-003
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-004
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on July 9, 2018 — management decision was due January 9, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-002
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-003
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-004
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.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and compliance status.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.