EIN: 911180810
UEI: J7C8WLVK66Q1
Audit also covers 2 related EINs: 270627714, 911494758 · unlinked EINs have no separate FAC filing
Audited by: Clark Nuber, PS
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 22, 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 June 22, 2026 (70 days ago).
What is a management decision? →Finding 2025-002 Significant deficiency in internal controls over compliance and noncompliance with procurement and suspension and debarment procedures meeting the requirements of the Uniform Guidance. Federal Agency: Department of Health and Human Services Program Title: Congressional Directives Assistance Listing Number: 93.493 Award Number: CE1HS47357-01-00 Award Period: September 1, 2022 - August 31, 2025 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-Federal entity that has expended federal awards to have written policies pertaining to its federal grants for procurement and that the history of each procurement is documented in accordance with 2 CFR section 200.318 to 200.320. Further, the regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition/Context for Evaluation The Organization received and utilized the federal award to pay for general contractor services for Phase II of a multi-phase construction project that was ongoing at the time of the award. The general contractor was selected as part of a competitive RFQ process for Phase I of the construction prior to notice of the award. A cost and price analysis was completed on the general contractor during the RFQ process. During predevelopment, the general contractor selected for Phase I was contracted for consulting work for scoping Phase II of the project. The general contractor and Organization solicited competitive bids from subcontractors and performed a cost/price analysis that was used for subcontractor selection. A stipulated sum contract was signed with the general contractor based substantially on the competitive bids received from subcontractors. As a result, the Organization ultimately elected to utilize a noncompetitive procurement method for the selection of the general contractor for Phase II of the construction project, on the basis that the procurement could only be obtained from a single source. This was determined due to the specialized nature of the building itself, as well as the accumulated knowledge that the general contractor had from Phase I of the project, and consulting on the predevelopment of Phase II. Ultimately, the Organization did not have a procurement policy in place that specifically covered the criteria and documentation requirements for a noncompetitive procurement required under the Uniform Guidance. As a result, the Organization did not have a process in place that resulted in compliance with the Uniform Guidance, including the maintenance of records to detail the history of the procurement in accordance with 2 CFR 200.318 to 1 CFR 200.320 Cause The Organization did not have a procurement policy or internal controls in place to ensure that the Organization’s procurement activities were done in accordance with the Uniform Guidance and controls were in place to retain documentation of the history of the procurement. Effect or Potential Effect The Organization entered into agreements to procure goods and services for which appropriate documentation was not retained to support the history of the procurement. Questioned Costs $0 Repeat Finding No
Show full finding ▾Hide full finding ▴Finding 2025-002 Significant deficiency in internal controls over compliance and noncompliance with procurement and suspension and debarment procedures meeting the requirements of the Uniform Guidance. Federal Agency: Department of Health and Human Services Program Title: Congressional Directives Assistance Listing Number: 93.493 Award Number: CE1HS47357-01-00 Award Period: September 1, 2022 - August 31, 2025 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-Federal entity that has expended federal awards to have written policies pertaining to its federal grants for procurement and that the history of each procurement is documented in accordance with 2 CFR section 200.318 to 200.320. Further, the regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition/Context for Evaluation The Organization received and utilized the federal award to pay for general contractor services for Phase II of a multi-phase construction project that was ongoing at the time of the award. The general contractor was selected as part of a competitive RFQ process for Phase I of the construction prior to notice of the award. A cost and price analysis was completed on the general contractor during the RFQ process. During predevelopment, the general contractor selected for Phase I was contracted for consulting work for scoping Phase II of the project. The general contractor and Organization solicited competitive bids from subcontractors and performed a cost/price analysis that was used for subcontractor selection. A stipulated sum contract was signed with the general contractor based substantially on the competitive bids received from subcontractors. As a result, the Organization ultimately elected to utilize a noncompetitive procurement method for the selection of the general contractor for Phase II of the construction project, on the basis that the procurement could only be obtained from a single source. This was determined due to the specialized nature of the building itself, as well as the accumulated knowledge that the general contractor had from Phase I of the project, and consulting on the predevelopment of Phase II. Ultimately, the Organization did not have a procurement policy in place that specifically covered the criteria and documentation requirements for a noncompetitive procurement required under the Uniform Guidance. As a result, the Organization did not have a process in place that resulted in compliance with the Uniform Guidance, including the maintenance of records to detail the history of the procurement in accordance with 2 CFR 200.318 to 1 CFR 200.320 Cause The Organization did not have a procurement policy or internal controls in place to ensure that the Organization’s procurement activities were done in accordance with the Uniform Guidance and controls were in place to retain documentation of the history of the procurement. Effect or Potential Effect The Organization entered into agreements to procure goods and services for which appropriate documentation was not retained to support the history of the procurement. Questioned Costs $0 Repeat Finding No
Corrective Action Plan Contact Person(s): Janet Carbary, Deana Gilpin Management agrees with this finding and recognizes the need to strengthen internal controls over purchasing processes to ensure compliance with Uniform Guidance requirements (§200.317–§200.326; §200.213). To address the deficiency, the Organization will implement the following actions: 1. Update Purchasing Policies and Procedures o Purchasing policies will be revised to clearly incorporate Uniform Guidance requirements, including competitive bidding thresholds, procurement method selection, and documentation standards. o Policies will explicitly require verification of suspension and debarment status for all vendors receiving federal funds. 2. Implement Mandatory Suspension and Debarment Verification o Staff will be required to document verification through SAM.gov or other approved sources before awarding or renewing contracts funded by federal awards. o A verification will be maintained and reviewed by Finance leadership. 3. Enhance Procurement Documentation Controls o Leadership will ensure all federal purchases meet the requirement below before purchase approval. • Competitive purchasing requirements are met • Cost/price analyses are documented when required • Suspension/debarment verifications are completed and retained 4. Training for Finance Staff o Staff involved in purchasing, contract approval, and grant management will receive training on Uniform Guidance procurement rules and suspension/debarment requirements. 5. Periodic Internal Monitoring o Revenue accountant will monitor expenses related to federal programs monthly to ensure compliance. o Senior management will be notified if corrective steps are needed. Anticipated Completion Date: December 31, 2025 Responsible Officials: • Chief Financial Officer (CFO) • Accounting Manager • Director of Financial Planning
FAC accepted this audit on January 15, 2025 — management decision was due July 15, 2025.
FAC accepted this audit on January 25, 2024 — management decision was due July 25, 2024.
FAC accepted this audit on January 6, 2023 — management decision was due July 6, 2023.
FAC accepted this audit on February 14, 2022 — management decision was due August 14, 2022.
FAC accepted this audit on March 14, 2021 — management decision was due September 14, 2021.
Finding 2020-001 Significant deficiency in internal controls over eligibility and program income and an instance of noncompliance with the eligibility requirements. Federal Agency: United States Department of Housing and Urban Development CFDA Number/Title: 14.239/HOME Investment Partnerships Program Pass-Through Entity: Snohomish County; Snohomish County; State of Washington - CTED Award Number: 9804100414; 9607180391; 03-40402-240 Award Period: 10/15/1999 - 10/14/2049; 04/24/1996 - 07/16/2056; 06/01/2004 - 05/31/2044 Criteria Per the standards contained in Title 2 US Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, Subpart D - Post Federal Award Requirements, Section 200.303, non-federal entities are required to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Federal awards referenced require that eligible tenants are individuals with chronic mental illness. Condition/Context for Evaluation The Organization's internal compliance controls require that a Household Eligibility Certification is completed and certified by the property representative once an eligibility and tenant rent rate determination is made. During testing for the year ended June 30, 2020, we noted that for three of nine tenants selected, the Household Eligibility Certification was not retained or certified by the property representative. In addition, for one of nine tenants selected for testing, the Organization did not retain documentation to support the tenant was an individual with chronic mental illness when an authorized Household Eligibility Certification was completed. Questioned Costs Not determinable Effect or Potential Effect Eligibility and tenant rent rate determinations may not be completed in accordance with the requirements of the federal awards. Cause The Organization?s internal controls over compliance did not operate effectively to certify accurate eligibility and program income determinations for tenants. Repeat Finding Not applicable as no similar finding was noted in the prior year audit of the Organization. Section III - Federal Award Findings and Questioned Costs (Continued) Recommendation We recommend the Organization strengthen its internal control processes to ensure that all Household Eligibility Certifications are retained and certified when completed and that such certifications only occur when all required documentation has been obtained and maintained to support proper eligibility and tenant rental rate determinations. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-001 Significant deficiency in internal controls over eligibility and program income and an instance of noncompliance with the eligibility requirements. Federal Agency: United States Department of Housing and Urban Development CFDA Number/Title: 14.239/HOME Investment Partnerships Program Pass-Through Entity: Snohomish County; Snohomish County; State of Washington - CTED Award Number: 9804100414; 9607180391; 03-40402-240 Award Period: 10/15/1999 - 10/14/2049; 04/24/1996 - 07/16/2056; 06/01/2004 - 05/31/2044 Criteria Per the standards contained in Title 2 US Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, Subpart D - Post Federal Award Requirements, Section 200.303, non-federal entities are required to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Federal awards referenced require that eligible tenants are individuals with chronic mental illness. Condition/Context for Evaluation The Organization's internal compliance controls require that a Household Eligibility Certification is completed and certified by the property representative once an eligibility and tenant rent rate determination is made. During testing for the year ended June 30, 2020, we noted that for three of nine tenants selected, the Household Eligibility Certification was not retained or certified by the property representative. In addition, for one of nine tenants selected for testing, the Organization did not retain documentation to support the tenant was an individual with chronic mental illness when an authorized Household Eligibility Certification was completed. Questioned Costs Not determinable Effect or Potential Effect Eligibility and tenant rent rate determinations may not be completed in accordance with the requirements of the federal awards. Cause The Organization?s internal controls over compliance did not operate effectively to certify accurate eligibility and program income determinations for tenants. Repeat Finding Not applicable as no similar finding was noted in the prior year audit of the Organization. Section III - Federal Award Findings and Questioned Costs (Continued) Recommendation We recommend the Organization strengthen its internal control processes to ensure that all Household Eligibility Certifications are retained and certified when completed and that such certifications only occur when all required documentation has been obtained and maintained to support proper eligibility and tenant rental rate determinations. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.
Finding Number 2020-001: Significant deficiency in internal controls over eligibility and program income and an instance of noncompliance with the eligibility requirements Contact Person(s): Tamera Loesch, Chief Financial Officer Tamera.Loesch@compassh.org Corrective action planned: Compass has now engaged new housing property management company, effective July 1, 2020 and we anticipate internal compliance controls to improve and certification documents to be completed and retained based on the expertise of the new property management company. Compass Health has also revisited our internal compliance controls related to eligibility certification to ensure documentation is updated and maintained in the tenant files. Anticipated completion date: December 31, 2020
FAC accepted this audit on February 25, 2020 — management decision was due August 25, 2020.
FAC accepted this audit on January 27, 2019 — management decision was due July 27, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on February 15, 2018 — management decision was due August 15, 2018.
FAC accepted this audit on December 8, 2016 — management decision was due June 8, 2017.
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