EIN: 910852323
UEI: KMV8MSZW1615
Audited by: Clark Nuber PS
Oversight agency: 93 [Department of Health and Human Services]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 9, 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 March 9, 2026 (178 days ago).
What is a management decision? →Finding 2024-001 Significant deficiency in internal controls over financial reporting in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP). Criteria Internal controls over financial reporting should be in place to ensure proper reconciliations are being performed to ensure transactions are recorded in accordance with U.S. GAAP. Condition/Context During our audit, we noted that a significant amount of donor restrictions had been met in prior years but not released in those years. Effect/Potential Effect As a result, a prior period adjustment had to be booked to reclass $655,000 from net assets with donor restrictions to net assets without donor restrictions. Cause In the prior year, a year end review of restricted net assets was not performed to assess termed awards or to compare year end restricted net asset balances against expectations based on expenditures to date. Repeat Finding No Recommendation We recommend that PDA implement necessary internal controls to ensure that donor restricted balances are reviewed as part of year end close processes to determine if restrictions have been met and amounts should be released from restriction. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.
Show full finding ▾Hide full finding ▴Finding 2024-001 Significant deficiency in internal controls over financial reporting in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP). Criteria Internal controls over financial reporting should be in place to ensure proper reconciliations are being performed to ensure transactions are recorded in accordance with U.S. GAAP. Condition/Context During our audit, we noted that a significant amount of donor restrictions had been met in prior years but not released in those years. Effect/Potential Effect As a result, a prior period adjustment had to be booked to reclass $655,000 from net assets with donor restrictions to net assets without donor restrictions. Cause In the prior year, a year end review of restricted net assets was not performed to assess termed awards or to compare year end restricted net asset balances against expectations based on expenditures to date. Repeat Finding No Recommendation We recommend that PDA implement necessary internal controls to ensure that donor restricted balances are reviewed as part of year end close processes to determine if restrictions have been met and amounts should be released from restriction. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.
Significant deficiency in internal controls over financial reporting of net assets with and without donor restrictions in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP). Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: PDA instituted a monthly review of foundation grant spending to ensure spending is in line with assumptions. By the completion of each fiscal year, PDA will have proper information gathered to release funds from restricted net assets accordingly. Anticipated Completion Date: Implemented in 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard, Tara Moss, and Fe LopezGaetke Co-Executive Directors
Finding 2024-002 Significant deficiency in internal controls over financial reporting in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP). Criteria Internal controls over financial reporting should ensure that leases are identified, evaluated, and recorded in accordance with U.S. GAAP, including the recognition of right-of-use assets and lease liabilities, and appropriate classification and disclosure under ASC 842. Condition/Context For the year ended December 31, 2024, the modifications of two leases were incorrectly recorded as if the modifications were present at inception of the leases rather than as of the date of the modification, and one new lease was not recorded as required by ASC 842. Effect/Potential Effect As a result, an adjustment of $41,184 was needed to lease expense, a $40,690 adjustment was needed for lease liabilities, and a $494 adjustment was needed for the right-of-use asset to properly state the financial statements in accordance with US. GAAP. Cause The lease modifications were recorded incorrectly due to a misunderstanding of how the lease accounting software distinguishes between lease edits and lease modifications. Amendments resulting in term extensions are considered triggering events and are recorded as modifications effective on the amendment date. Instead, the original lease terms were edited directly, which prompted the lease accounting software to produce improper calculations. Additionally, a new lease signed during the audit year was initially treated as a short-term lease and not capitalized under ASC 842 based on the expectation that it would be canceled partway through its term. However, no formal amendment was executed to document the early termination. As a result, a right-of-use asset and lease liability were not recorded as required by ASC 842. Repeat Finding No Recommendation We recommend that PDA implement necessary internal controls and review to ensure that lease modifications and new leases are properly recorded in accordance with ASC 842 when executed. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.
Show full finding ▾Hide full finding ▴Finding 2024-002 Significant deficiency in internal controls over financial reporting in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP). Criteria Internal controls over financial reporting should ensure that leases are identified, evaluated, and recorded in accordance with U.S. GAAP, including the recognition of right-of-use assets and lease liabilities, and appropriate classification and disclosure under ASC 842. Condition/Context For the year ended December 31, 2024, the modifications of two leases were incorrectly recorded as if the modifications were present at inception of the leases rather than as of the date of the modification, and one new lease was not recorded as required by ASC 842. Effect/Potential Effect As a result, an adjustment of $41,184 was needed to lease expense, a $40,690 adjustment was needed for lease liabilities, and a $494 adjustment was needed for the right-of-use asset to properly state the financial statements in accordance with US. GAAP. Cause The lease modifications were recorded incorrectly due to a misunderstanding of how the lease accounting software distinguishes between lease edits and lease modifications. Amendments resulting in term extensions are considered triggering events and are recorded as modifications effective on the amendment date. Instead, the original lease terms were edited directly, which prompted the lease accounting software to produce improper calculations. Additionally, a new lease signed during the audit year was initially treated as a short-term lease and not capitalized under ASC 842 based on the expectation that it would be canceled partway through its term. However, no formal amendment was executed to document the early termination. As a result, a right-of-use asset and lease liability were not recorded as required by ASC 842. Repeat Finding No Recommendation We recommend that PDA implement necessary internal controls and review to ensure that lease modifications and new leases are properly recorded in accordance with ASC 842 when executed. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.
Significant deficiency in internal controls over financial reporting of leases in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP). Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: Review lease terms at inception of lease(s) and ensure accounted for correctly in the leasing software and general ledger; review all leases again at year end to ensure any changes to said leases were recorded properly. Anticipated Completion Date: End of 2025 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard, Tara Moss, and Fe LopezGaetke Co-Executive Directors
Finding 2024-003 Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: Department of Health and Human Services Program Titles: Community Funded Projects Assistance Listing Number: 93.493 Pass-Through Entity: N/A Award Numbers: H79FG001026 and H79FG001037 Award Periods: September 30, 2023 through September 29, 2024 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 requirements identified in 2 CFR Part 200. The procurement procedures must include the following: - Using the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the nonfederal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). - For acquisitions exceeding the simplified acquisition threshold, using one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of the circumstances are met, in accordance with 2 CFR section 200.320(c)). - Using Noncompetitive procurement only if one or more of the following circumstances apply: · The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; · The item is available only from a single source; · The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; · The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the nonfederal entity; or · After solicitation of a number of sources, competition is determined inadequate PDA’s procurement policy also requires a verification that vendors and sub-recipients are not suspended or debarred by checking the website of the System for Award Management and documentation of such verification maintained by the Finance Office. Condition/Context While PDA has established a procurement policy, it does not fully conform to Federal law and the Uniform Guidance for the following reasons: - Micro purchase threshold is not explicitly defined, although it is mentioned that cost and price analysis shall be made and documented in connection with every procurement action above $5,000. - The policy does not have clear provisions for maintaining detailed procurement records. Such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. - The simplified acquisition threshold is not defined and does not incorporate all relevant elements including sealed bids method. The total misstatement is the entire population amount $1,546,725 as PDA did not maintain sufficient documentation to evidence history of procurement for all procurements. Cause PDA’s procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance. Internal controls over maintaining sufficient records to detail the history of procurement including noncompetitive justification and suspension and debarment verification were found to be insufficient. Effect The absence of a policy that fully conformed to the Uniform Guidance resulted in noncompliance issues such as records sufficient to detail the history of procurement transactions not maintained. Questioned Costs $1,546,725 Repeat Finding Yes Recommendation We recommend PDA implement measures to ensure that its procurement policy reflect applicable state and local laws and regulations conforming to applicable federal statutes and requirement in 2 CFR part 200. Management should ensure procurement transactions are documented in such detail to evidence the method of procurement use and vendor verification for suspension and debarment.
Show full finding ▾Hide full finding ▴Finding 2024-003 Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: Department of Health and Human Services Program Titles: Community Funded Projects Assistance Listing Number: 93.493 Pass-Through Entity: N/A Award Numbers: H79FG001026 and H79FG001037 Award Periods: September 30, 2023 through September 29, 2024 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 requirements identified in 2 CFR Part 200. The procurement procedures must include the following: - Using the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the nonfederal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). - For acquisitions exceeding the simplified acquisition threshold, using one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of the circumstances are met, in accordance with 2 CFR section 200.320(c)). - Using Noncompetitive procurement only if one or more of the following circumstances apply: · The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; · The item is available only from a single source; · The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; · The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the nonfederal entity; or · After solicitation of a number of sources, competition is determined inadequate PDA’s procurement policy also requires a verification that vendors and sub-recipients are not suspended or debarred by checking the website of the System for Award Management and documentation of such verification maintained by the Finance Office. Condition/Context While PDA has established a procurement policy, it does not fully conform to Federal law and the Uniform Guidance for the following reasons: - Micro purchase threshold is not explicitly defined, although it is mentioned that cost and price analysis shall be made and documented in connection with every procurement action above $5,000. - The policy does not have clear provisions for maintaining detailed procurement records. Such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. - The simplified acquisition threshold is not defined and does not incorporate all relevant elements including sealed bids method. The total misstatement is the entire population amount $1,546,725 as PDA did not maintain sufficient documentation to evidence history of procurement for all procurements. Cause PDA’s procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance. Internal controls over maintaining sufficient records to detail the history of procurement including noncompetitive justification and suspension and debarment verification were found to be insufficient. Effect The absence of a policy that fully conformed to the Uniform Guidance resulted in noncompliance issues such as records sufficient to detail the history of procurement transactions not maintained. Questioned Costs $1,546,725 Repeat Finding Yes Recommendation We recommend PDA implement measures to ensure that its procurement policy reflect applicable state and local laws and regulations conforming to applicable federal statutes and requirement in 2 CFR part 200. Management should ensure procurement transactions are documented in such detail to evidence the method of procurement use and vendor verification for suspension and debarment.
Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: PDA adopted a new, updated procurement policy in October 2024. PDA worked with Clark Nuber to develop this policy. Anticipated Completion Date: October of 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard, Tara Moss, and Fe LopezGaetke Co-Executive Directors
2023-001
FAC accepted this audit on October 24, 2024 — management decision was due April 24, 2025.
Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: Department of Health and Human Services Program Titles: Community Funded Projects Assistance Listing Number: 93.493 Pass-Through Entity: N/A Award Numbers: H79FG001026 Award Periods: September 30, 2023 through September 29, 2024 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 requirements identified in 2 CFR Part 200. The procurement procedures must include the following: - Using the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the nonfederal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). - For acquisitions exceeding the simplified acquisition threshold, using one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of the circumstances are met, in accordance with 2 CFR section 200.320(c)). - Using Noncompetitive procurement only if one or more of the following circumstances apply: · The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; · The item is available only from a single source; · The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; · The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the nonfederal entity; or · After solicitation of a number of sources, competition is determined inadequate PDA’s procurement policy also requires a verification that vendors and sub-recipient are not suspended or debarred by checking the website of the System for Award Management and documentation of such verification maintained by the Finance Office. Condition/Context While PDA has established a procurement policy, it does not fully conform to Federal law and the Uniform Guidance for the following reasons: - Micro purchase threshold is not explicitly defined, although it is mentioned that cost and price analysis shall be made and documented in connection with every procurement action above $5,000. - The policy does not have clear provisions for maintaining detailed procurement records. Such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. - The simplified acquisition threshold is not defined and does not incorporate all relevant elements including sealed bids method. During our testing of 2 procurement transactions out of a total of 18, we observed that, despite management's detailed historical background on each of the selected transactions, the necessary documentation evidencing compliance with PDA’s procurement standards was not retained. All the transactions tested were noncompetitive and thus single sourced. The total misstatement is the entire population amount $208,580 as PDA did not maintain sufficient documentation to evidence history of procurement for all procurements and not just the 2 samples we tested. Furthermore, for these two vendors, which represented a 100% sample, we found no evidence of documentation for suspension and debarment verification. Although discussions with management suggested that all these transactions were properly conceived and evaluated at the time, supporting documentation was not retained. Cause PDA’s procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance. Internal controls over maintaining sufficient records to detail the history of procurement including noncompetitive justification and suspension and debarment verification were found to be insufficient. Effect The absence of a policy that fully conformed to the Uniform Guidance resulted in noncompliance issues such as records sufficient to detail the history of procurement transactions not maintained. Questioned Costs $208,580 Repeat Finding Yes. Recommendation We recommend PDA implement measures to ensure that its procurement policy reflect applicable state and local laws and regulations conforming to applicable federal statutes and requirement in 2 CFR part 200. Management should ensure procurement transactions are documented in such detail to evidence the method of procurement use and vendor verification for suspension and debarment.
Show full finding ▾Hide full finding ▴Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: Department of Health and Human Services Program Titles: Community Funded Projects Assistance Listing Number: 93.493 Pass-Through Entity: N/A Award Numbers: H79FG001026 Award Periods: September 30, 2023 through September 29, 2024 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 requirements identified in 2 CFR Part 200. The procurement procedures must include the following: - Using the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the nonfederal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). - For acquisitions exceeding the simplified acquisition threshold, using one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of the circumstances are met, in accordance with 2 CFR section 200.320(c)). - Using Noncompetitive procurement only if one or more of the following circumstances apply: · The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; · The item is available only from a single source; · The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; · The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the nonfederal entity; or · After solicitation of a number of sources, competition is determined inadequate PDA’s procurement policy also requires a verification that vendors and sub-recipient are not suspended or debarred by checking the website of the System for Award Management and documentation of such verification maintained by the Finance Office. Condition/Context While PDA has established a procurement policy, it does not fully conform to Federal law and the Uniform Guidance for the following reasons: - Micro purchase threshold is not explicitly defined, although it is mentioned that cost and price analysis shall be made and documented in connection with every procurement action above $5,000. - The policy does not have clear provisions for maintaining detailed procurement records. Such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. - The simplified acquisition threshold is not defined and does not incorporate all relevant elements including sealed bids method. During our testing of 2 procurement transactions out of a total of 18, we observed that, despite management's detailed historical background on each of the selected transactions, the necessary documentation evidencing compliance with PDA’s procurement standards was not retained. All the transactions tested were noncompetitive and thus single sourced. The total misstatement is the entire population amount $208,580 as PDA did not maintain sufficient documentation to evidence history of procurement for all procurements and not just the 2 samples we tested. Furthermore, for these two vendors, which represented a 100% sample, we found no evidence of documentation for suspension and debarment verification. Although discussions with management suggested that all these transactions were properly conceived and evaluated at the time, supporting documentation was not retained. Cause PDA’s procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance. Internal controls over maintaining sufficient records to detail the history of procurement including noncompetitive justification and suspension and debarment verification were found to be insufficient. Effect The absence of a policy that fully conformed to the Uniform Guidance resulted in noncompliance issues such as records sufficient to detail the history of procurement transactions not maintained. Questioned Costs $208,580 Repeat Finding Yes. Recommendation We recommend PDA implement measures to ensure that its procurement policy reflect applicable state and local laws and regulations conforming to applicable federal statutes and requirement in 2 CFR part 200. Management should ensure procurement transactions are documented in such detail to evidence the method of procurement use and vendor verification for suspension and debarment.
Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: Action steps Who At least quarterly program level review of budget vs. actuals to discuss trends, variances, potential errors in coding of transaction Finance Team and Executive Directors At least quarterly review of admin costs, to review for trends against budget and errors in classification of transactions Finance Team and Executive Directors Adjust cadence /deadlines for balance sheet reconciliations and incorporate Finance Director level review. Ensure adjustments are made in a timely manner. Finance Team Email weekly cash deposit report for Executive Directors and Finance Director to review for proper classification in the general ledger Finance Team and Executive Directors Streamline key processes which will allow finance team the time and flexibility to analyze and strategize and get ahead of firedrills; this will allow them to understand the story that the numbers are telling. Finance Team Continue to document procedures. This will ensure proper backup when team members are out due to vacation or illness. Comprehensive, documented procedures are the teams bench strength. Finance Team Ensure all transaction in the general ledger have proper backup to ensure understanding of underlying transaction Finance Team Anticipated Completion Date: End of 2024 Name(s) of the Contact Person(s) Responsible for Corrective Action: Barbara Donohue, Director of Finance Lisa Daugaard and Tara Moss, Co-Executive Directors
2022-002
FAC accepted this audit on October 24, 2024 — management decision was due April 24, 2025.
Significant deficiency in internal control over compliance for allowable costs related to adequate documentation. Federal Agency: United States Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery FundsFinding 2022-002 (Continued) Questioned Costs None. Repeat Finding Yes. Recommendation We recommend PDA review its accounting policies and practices for compliance with the policy guide provisions of the Code of Federal Regulations. While this policy may have been formulated for materiality purposes, charges to Federal awards require adequate documentation regardless of amount. Assistance Listing Number: 21.027 Pass-Through Entity: King County Award Numbers: 6200091 Award Periods: January 1, 2021 through December 31, 2024 Criteria Internal control requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E ‐ Cost Principles, Section 200.403, policy guide, require that a non‐Federal entity ensure that cost be adequately documented to be allowable under Federal awards. The accounting practices of the non-Federal entity must be consistent with cost principles per the policy guide and support the accumulation of costs as required by the principles, and must provide for adequate documentation to support costs charged to the Federal award. Condition/Context In our initial sample of transactions for allowability, the PDA said they did not require support for the 14 transactions we had selected under $75 as a policy. They were subsequently able to locate support for all but 5 of these transactions totaling $107. Cause PDA’s accounting policies and practices over allowable costs seemed not properly implemented to ensure compliance with the Uniform Guidance requirements. Effect Some of the transactions were missing adequate documented support. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend PDA review its accounting policies and practices for compliance with the policy guide provisions of the Code of Federal Regulations. While this policy may have been formulated for materiality purposes, charges to Federal awards require adequate documentation regardless of amount.
Show full finding ▾Hide full finding ▴Significant deficiency in internal control over compliance for allowable costs related to adequate documentation. Federal Agency: United States Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery FundsFinding 2022-002 (Continued) Questioned Costs None. Repeat Finding Yes. Recommendation We recommend PDA review its accounting policies and practices for compliance with the policy guide provisions of the Code of Federal Regulations. While this policy may have been formulated for materiality purposes, charges to Federal awards require adequate documentation regardless of amount. Assistance Listing Number: 21.027 Pass-Through Entity: King County Award Numbers: 6200091 Award Periods: January 1, 2021 through December 31, 2024 Criteria Internal control requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E ‐ Cost Principles, Section 200.403, policy guide, require that a non‐Federal entity ensure that cost be adequately documented to be allowable under Federal awards. The accounting practices of the non-Federal entity must be consistent with cost principles per the policy guide and support the accumulation of costs as required by the principles, and must provide for adequate documentation to support costs charged to the Federal award. Condition/Context In our initial sample of transactions for allowability, the PDA said they did not require support for the 14 transactions we had selected under $75 as a policy. They were subsequently able to locate support for all but 5 of these transactions totaling $107. Cause PDA’s accounting policies and practices over allowable costs seemed not properly implemented to ensure compliance with the Uniform Guidance requirements. Effect Some of the transactions were missing adequate documented support. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend PDA review its accounting policies and practices for compliance with the policy guide provisions of the Code of Federal Regulations. While this policy may have been formulated for materiality purposes, charges to Federal awards require adequate documentation regardless of amount.
Significant deficiency in internal control over compliance for allowable costs related to adequate documentation. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: • This is primarily related to the absence of receipts for expense items under $75. There are three items contributing to this finding: 1) Receipts that were not able to be located related to employees who had left the organization and did not provide receipts prior to departure - $0 of sample list. 2) Receipts that were simply not able to be found - $0 from sample list. 3) In general, PDA relies on our credit card platform for the repository of credit card receipts. The forum used during 2021 was “Elan”. Elan only retains receipts up to a maximum of 12 months from the date of spending. Due to the timing of the audit, in most cases 7-12 months had passed when the receipts were requested, and we were not able to extract from that system and therefore relied on employees’ records (see #1-2 above). Total amount related to expiration of receipts in Elan - $114.40. • PDA’s policy is to retain and upload receipts for all spending, no minimum. • In May of 2022, PDA moved to a new credit card platform (“Center”), which retains receipts into perpetuity. Anticipated completion date: This was implemented in May of 2022. Name(s) of the contact person(s) responsible for corrective action: Co-Executive Directors, Finance team
2021-001
Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: United States Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Entity: King County Award Numbers: 6200091 Award Periods: January 1, 2021 through December 31, 2024 Criteria Procurement Standards 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 Procurement Standards, 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 requirements identified in 2 CFR Part 200. The procurement procedures must include the following: - Using the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). - For acquisitions exceeding the simplified acquisition threshold, using one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of the circumstances are met, in accordance with 2 CFR section 200.320(c)). - Using Noncompetitive procurement only if one or more of the following circumstances apply: · The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; · The item is available only from a single source; · The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; · The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or · After solicitation of a number of sources, competition is determined inadequate PDA’s procurement policy also requires a verification that vendors and sub-recipient are not suspended or debarred by checking the website of the System for Award Management and documentation of such verification maintained by the Finance Office. Condition/Context While PDA has established a procurement policy, it does not fully conform to the Uniform Guidance for the following reasons: - Micro purchase threshold is not explicitly defined, although it is mentioned that cost and price analysis shall be made and documented in connection with every procurement action above $5,000. - The policy did not have clear provisions for maintaining detailed procurement records. Such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. - The simplified acquisition threshold is not defined and does not incorporate all relevant elements including sealed bids method. During our testing of 3 procurement transactions from a total of 15, we observed that, despite management's detailed historical background on each of the selected transactions, the necessary documentation evidencing compliance with PDA’s procurement policy was not retained. All the transactions tested were noncompetitive. The total misstatement is the entire population amount $205,921 as PDA did not maintain sufficient documentation to evidence history of procurement for all procurement transactions. Furthermore, for three vendors, which represented a 100% sample, we found no evidence of documentation for suspension and debarment verification. Although discussions with management suggested that all these transactions were properly conceived and evaluated at the time, there was no contemporaneous documentation to support this. Cause PDA’s procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance. Internal controls over maintaining sufficient records to detail the history of procurement including noncompetitive justification and suspension and debarment verification were found to be insufficient. Effect The absence of a policy that fully conformed to the Uniform Guidance resulted in noncompliance issues such as records sufficient to detail the history of procurement transactions not maintained. Questioned Costs $205,921 Repeat Finding Yes. Recommendation We recommend PDA implement measures to ensure that its procurement policy reflect applicable state and local laws and regulations conforming to applicable federal statutes and requirement in 2 CFR part 200. Management should ensure procurement transactions are documented in such detail to evidence the method of procurement use and vendor verification for suspension and debarment.
Show full finding ▾Hide full finding ▴Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: United States Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Entity: King County Award Numbers: 6200091 Award Periods: January 1, 2021 through December 31, 2024 Criteria Procurement Standards 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 Procurement Standards, 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 requirements identified in 2 CFR Part 200. The procurement procedures must include the following: - Using the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). - For acquisitions exceeding the simplified acquisition threshold, using one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of the circumstances are met, in accordance with 2 CFR section 200.320(c)). - Using Noncompetitive procurement only if one or more of the following circumstances apply: · The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; · The item is available only from a single source; · The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; · The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or · After solicitation of a number of sources, competition is determined inadequate PDA’s procurement policy also requires a verification that vendors and sub-recipient are not suspended or debarred by checking the website of the System for Award Management and documentation of such verification maintained by the Finance Office. Condition/Context While PDA has established a procurement policy, it does not fully conform to the Uniform Guidance for the following reasons: - Micro purchase threshold is not explicitly defined, although it is mentioned that cost and price analysis shall be made and documented in connection with every procurement action above $5,000. - The policy did not have clear provisions for maintaining detailed procurement records. Such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. - The simplified acquisition threshold is not defined and does not incorporate all relevant elements including sealed bids method. During our testing of 3 procurement transactions from a total of 15, we observed that, despite management's detailed historical background on each of the selected transactions, the necessary documentation evidencing compliance with PDA’s procurement policy was not retained. All the transactions tested were noncompetitive. The total misstatement is the entire population amount $205,921 as PDA did not maintain sufficient documentation to evidence history of procurement for all procurement transactions. Furthermore, for three vendors, which represented a 100% sample, we found no evidence of documentation for suspension and debarment verification. Although discussions with management suggested that all these transactions were properly conceived and evaluated at the time, there was no contemporaneous documentation to support this. Cause PDA’s procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance. Internal controls over maintaining sufficient records to detail the history of procurement including noncompetitive justification and suspension and debarment verification were found to be insufficient. Effect The absence of a policy that fully conformed to the Uniform Guidance resulted in noncompliance issues such as records sufficient to detail the history of procurement transactions not maintained. Questioned Costs $205,921 Repeat Finding Yes. Recommendation We recommend PDA implement measures to ensure that its procurement policy reflect applicable state and local laws and regulations conforming to applicable federal statutes and requirement in 2 CFR part 200. Management should ensure procurement transactions are documented in such detail to evidence the method of procurement use and vendor verification for suspension and debarment.
Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: • PDA worked with Clark Nuber team to revise and update the procurement policy to be in-line with the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards procurement standards. Anticipated completion date: Third quarter 2024 Name(s) of the contact person(s) responsible for corrective action: Co-Executive Directors, Directors, Finance team
2021-002
FAC accepted this audit on October 24, 2024 — management decision was due April 24, 2025.
Significant deficiency in internal control over compliance for allowable costs related to adequate documentation. Federal Agency: United States Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.019 & 21.027 Pass-Through Entity: King County Award Numbers: 6200091 Award Periods: January 1, 2021 through December 31, 2024 Criteria Internal control requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E ‐ Cost Principles, Section 200.400, policy guide, require that a non‐Federal entity ensure that cost be adequately documented to be allowable under Federal awards. The accounting practices of the non-Federal entity must be consistent with cost principles per the policy guide and support the accumulation of costs as required by the principles and must provide for adequate documentation to support costs charged to the Federal award. Condition/Context In our initial sample of transactions for allowability, the PDA said they did not require support for the 24 transactions we had selected under $75 as a policy. They were subsequently able to locate support for all but 8 of these transactions totaling $105. Cause PDA’s accounting policies and practices over allowable costs seemed not properly implemented to ensure compliance with the Uniform Guidance requirements. Effect Some of the transactions were missing adequate documented support. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend that PDA revisits and updates its accounting policies and practices to align with the provisions outlined in the policy guide of the Code of Federal Regulations. Although the current policy may have been established with materiality considerations in mind, it is important to note that all charges to Federal awards necessitate proper documentation, irrespective of the amount involved.
Show full finding ▾Hide full finding ▴Significant deficiency in internal control over compliance for allowable costs related to adequate documentation. Federal Agency: United States Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.019 & 21.027 Pass-Through Entity: King County Award Numbers: 6200091 Award Periods: January 1, 2021 through December 31, 2024 Criteria Internal control requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E ‐ Cost Principles, Section 200.400, policy guide, require that a non‐Federal entity ensure that cost be adequately documented to be allowable under Federal awards. The accounting practices of the non-Federal entity must be consistent with cost principles per the policy guide and support the accumulation of costs as required by the principles and must provide for adequate documentation to support costs charged to the Federal award. Condition/Context In our initial sample of transactions for allowability, the PDA said they did not require support for the 24 transactions we had selected under $75 as a policy. They were subsequently able to locate support for all but 8 of these transactions totaling $105. Cause PDA’s accounting policies and practices over allowable costs seemed not properly implemented to ensure compliance with the Uniform Guidance requirements. Effect Some of the transactions were missing adequate documented support. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend that PDA revisits and updates its accounting policies and practices to align with the provisions outlined in the policy guide of the Code of Federal Regulations. Although the current policy may have been established with materiality considerations in mind, it is important to note that all charges to Federal awards necessitate proper documentation, irrespective of the amount involved.
Significant deficiency in internal control over compliance for allowable costs related to adequate documentation. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: • This is primarily related to the absence of receipts for expense items under $75. There are three items contributing to this finding: 1) Receipts that were not able to be located related to employees who had left the organization and did not provide receipts prior to departure - $96.12 of sample list. 2) Receipts that were simply not able to be found - $18.86 from sample list. 3) In general, PDA relies on our credit card platform for the repository of credit card receipts. The forum used during 2021 was “Elan”. Elan only retains receipts up to a maximum of 12 months from the date of spending. Due to the timing of the audit, in most cases 7-12 months had passed when the receipts were requested, and we were not able to extract from that system and therefore relied on employees’ records (see #1-2 above). • PDA’s policy is to retain and upload receipts for all spending, no minimum. • In May of 2022, PDA moved to a new credit card platform (“Center”), which retains receipts into perpetuity. Anticipated completion date: Quarter 1, 2024 Name(s) of the contact person(s) responsible for corrective action: Co-Executive Directors, Finance team
2020-002
Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: United States Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Entity: King County Award Numbers: 6200091 Award Periods: January 1, 2021 through December 31, 2024 Criteria Internal control 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. The procurement procedures must include the following: - Using the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). - For acquisitions exceeding the simplified acquisition threshold, using one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of the circumstances are met, in accordance with 2 CFR section 200.320(c)). - Using Noncompetitive procurement only if one or more of the following circumstances apply: · The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; · The item is available only from a single source; · The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; - The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or ∙ After solicitation of a number of sources, competition is determined inadequate PDA’s procurement policy also requires a verification that vendors and sub-recipient are not suspended or debarred by checking the website of the System for Award Management and documentation of such verification maintained by the Finance Office. Condition/Context While PDA has established a procurement policy, it does not fully conform to Federal law and the Uniform Guidance for the following reasons: - Micro purchase threshold is not explicitly defined, although it is mentioned that cost and price analysis shall be made and documented in connection with every procurement action above $5,000. - The policy does not clear provisions for maintaining detailed procurement records. Such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. - The simplified acquisition threshold is not defined and does not incorporate all relevant elements including sealed bids method. During our testing of 3 procurement transactions from a total of 20, we observed that, despite management's detailed historical background on each of the selected the necessary documentation evidencing compliance with PDA’s procurement standards was not retained. All the transactions tested were noncompetitive and thus single sourced. The total misstatement from these three transactions amounted to approximately $56,000 out of a total population of about $186,491. Furthermore, for these three vendors, which represented a 100% sample, we found no evidence of documentation for suspension and debarment verification. Although discussions with management suggested that all these transactions were properly conceived and evaluated at the time, there was no contemporaneous documentation to support this. Cause PDA’s procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance. Internal controls over maintaining sufficient records to detail the history of procurement including noncompetitive justification and suspension and debarment verification were found to be insufficient. Effect The policy did not fully conformed to the Uniform Guidance resulting to noncompliance issues such as records not sufficient to detail the history of procurement transactions. Questioned Costs $186,491 Repeat Finding No. Recommendation We recommend PDA implement measures to ensure that its procurement policy reflect applicable state and local laws and regulations conforming to applicable federal statutes and requirement in 2 CFR part 200. Management should ensure procurement transactions are documented in such detail to evidence the method of procurement use and vendor verification for suspension and debarment.
Show full finding ▾Hide full finding ▴Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: United States Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Entity: King County Award Numbers: 6200091 Award Periods: January 1, 2021 through December 31, 2024 Criteria Internal control 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. The procurement procedures must include the following: - Using the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). - For acquisitions exceeding the simplified acquisition threshold, using one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of the circumstances are met, in accordance with 2 CFR section 200.320(c)). - Using Noncompetitive procurement only if one or more of the following circumstances apply: · The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; · The item is available only from a single source; · The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; - The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or ∙ After solicitation of a number of sources, competition is determined inadequate PDA’s procurement policy also requires a verification that vendors and sub-recipient are not suspended or debarred by checking the website of the System for Award Management and documentation of such verification maintained by the Finance Office. Condition/Context While PDA has established a procurement policy, it does not fully conform to Federal law and the Uniform Guidance for the following reasons: - Micro purchase threshold is not explicitly defined, although it is mentioned that cost and price analysis shall be made and documented in connection with every procurement action above $5,000. - The policy does not clear provisions for maintaining detailed procurement records. Such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. - The simplified acquisition threshold is not defined and does not incorporate all relevant elements including sealed bids method. During our testing of 3 procurement transactions from a total of 20, we observed that, despite management's detailed historical background on each of the selected the necessary documentation evidencing compliance with PDA’s procurement standards was not retained. All the transactions tested were noncompetitive and thus single sourced. The total misstatement from these three transactions amounted to approximately $56,000 out of a total population of about $186,491. Furthermore, for these three vendors, which represented a 100% sample, we found no evidence of documentation for suspension and debarment verification. Although discussions with management suggested that all these transactions were properly conceived and evaluated at the time, there was no contemporaneous documentation to support this. Cause PDA’s procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance. Internal controls over maintaining sufficient records to detail the history of procurement including noncompetitive justification and suspension and debarment verification were found to be insufficient. Effect The policy did not fully conformed to the Uniform Guidance resulting to noncompliance issues such as records not sufficient to detail the history of procurement transactions. Questioned Costs $186,491 Repeat Finding No. Recommendation We recommend PDA implement measures to ensure that its procurement policy reflect applicable state and local laws and regulations conforming to applicable federal statutes and requirement in 2 CFR part 200. Management should ensure procurement transactions are documented in such detail to evidence the method of procurement use and vendor verification for suspension and debarment.
Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: PDA worked with Clark Nuber team to revise and update the procurement policy to be in-line with the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards procurement standards. Anticipated completion date: Third quarter 2024 Name(s) of the contact person(s) responsible for corrective action: Co-Executive Directors, Directors, Finance team
FAC accepted this audit on February 8, 2022 — management decision was due August 8, 2022.
Sufficient documentation of costs demonstrating that expenditures were accurate, allowable, and properly allocated was not always readily available. Context: Approximately 25% of expenditures required additional documentation to determine allowability of costs and activities. Cause: This is the first time the entity has received and expended federal funds, and the accounting department was not fully staffed to handle the work involved. Due to inexperience with federal funds, misunderstandings occurred regarding documentation required to support allowable costs and activities. Effect: Errors may occur, documentation may not be able to be produced when needed, or be re-produced. Recommendation: We recommend training in accounting and compliance for federal expenditures, and a second review of backup documentation of all submissions for reimbursement. We recommend all federal expenditures be segregated in the general ledger, and support maintained (i.e. invoices, allocations, support for employee time) in such a way that another finance person could review it and readily come to the conclusion that the costs and activities were allowable under federal regulations. Views of responsible officials and planned corrective actions: As noted by the auditors, PDA began 2020 as a much smaller organization than it was at the end of the year. During the year, PDA took on administration of COVID relief funds to vulnerable communities, fielded an outreach and sheltering team for people being literally turned out of shelters and the justice system due to COVID de-intensification measures, nearly doubled our staff and governmental revenue, and vastly increased transactions in a way that had not been planned for and could not have been anticipated. PDA had one full time accountant during 2020 and until mid-February 2021, who by necessity focused on completing financial transactions and recording activity in the most practical way for function and reporting. Had the scope and nature of our 2020 growth been planned for and anticipated, we would of course have increased the size of our accounting department in advance of such growth, and it would have taken place over a longer time frame. Reacting to the emergency, our Finance Director worked exceptionally long hours and made every effort to find and follow guidance on best practices with the kinds of transactions and fund sources we were unexpectedly dealing with. While attempting to set up the most efficient systems, due to the complexity of the programs some transactions were not recorded in the correct year. We agree with the auditors? recommendations, which can and will be followed in future years. The larger matter of assembling a finance team able to meet the demands of PDA's expansion in both programs and complex funding is underway. A Federal and Government Contracts Accountant was hired in February 2021 and a Financial Controller and Assistant Controller were hired in October 2021. Hiring of a Finance Director is underway. In addition, we will schedule training for staff in accounting and compliance for federal expenditures, segregate federal expenditures, and maintain all necessary support for expenditures. .
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of the Treasury Federal Program Title: Coronavirus Relief Fund CFDA Number: 21.019 Pass-Through Agency: King County, Washington Award Period: March 1, 2020 ? December 31, 2020 Finding Identification Number: 2020-002 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Criteria: The Association is responsible for establishing and maintaining effective internal control over compliance. Documentation establishing allowability of costs and activities compliant with federal regulations should be complete, readily available, and easily auditable. Condition: Sufficient documentation of costs demonstrating that expenditures were accurate, allowable, and properly allocated was not always readily available. Context: Approximately 25% of expenditures required additional documentation to determine allowability of costs and activities. Cause: This is the first time the entity has received and expended federal funds, and the accounting department was not fully staffed to handle the work involved. Due to inexperience with federal funds, misunderstandings occurred regarding documentation required to support allowable costs and activities. Effect: Errors may occur, documentation may not be able to be produced when needed, or be re-produced. Recommendation: We recommend training in accounting and compliance for federal expenditures, and a second review of backup documentation of all submissions for reimbursement. We recommend all federal expenditures be segregated in the general ledger, and support maintained (i.e. invoices, allocations, support for employee time) in such a way that another finance person could review it and readily come to the conclusion that the costs and activities were allowable under federal regulations. Views of responsible officials and planned corrective actions: As noted by the auditors, PDA began 2020 as a much smaller organization than it was at the end of the year. During the year, PDA took on administration of COVID relief funds to vulnerable communities, fielded an outreach and sheltering team for people being literally turned out of shelters and the justice system due to COVID de-intensification measures, nearly doubled our staff and governmental revenue, and vastly increased transactions in a way that had not been planned for and could not have been anticipated. PDA had one full time accountant during 2020 and until mid-February 2021, who by necessity focused on completing financial transactions and recording activity in the most practical way for function and reporting. Had the scope and nature of our 2020 growth been planned for and anticipated, we would of course have increased the size of our accounting department in advance of such growth, and it would have taken place over a longer time frame. Reacting to the emergency, our Finance Director worked exceptionally long hours and made every effort to find and follow guidance on best practices with the kinds of transactions and fund sources we were unexpectedly dealing with. While attempting to set up the most efficient systems, due to the complexity of the programs some transactions were not recorded in the correct year. We agree with the auditors? recommendations, which can and will be followed in future years. The larger matter of assembling a finance team able to meet the demands of PDA's expansion in both programs and complex funding is underway. A Federal and Government Contracts Accountant was hired in February 2021 and a Financial Controller and Assistant Controller were hired in October 2021. Hiring of a Finance Director is underway. In addition, we will schedule training for staff in accounting and compliance for federal expenditures, segregate federal expenditures, and maintain all necessary support for expenditures. .
Recommendation: We recommend training in accounting and compliance for federal expenditures, and a second review of backup documentation of all submissions for reimbursement. We recommend all federal expenditures be segregated in the general ledger, and support maintained (i.e. invoices, allocations, support for employee time) in such a way that another finance person could review it and readily come to the conclusion that the costs and activities were allowable under federal regulations. Corrective Action Planned: PDA will hire additional accounting staff trained in Generally Accepted Accounting Principles and non-profit accounting in order to perform more timely reconciliations of accounts. PDA will increase its accounting and finance staff to support the expanded operating and accounting needs. A Federal and Government Contracts Accountant was hired in February 2021 and a Financial Controller and Assistant Controller were hired in October 2021. Hiring of a Finance Director is underway. In addition, we are scheduling training for staff in accounting and compliance for federal expenditures, segregate federal expenditures, and maintain all necessary support for expenditures.
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