EIN: 911577469
UEI: CQXLDH469E67
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 4, 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 December 4, 2025 (266 days ago).
What is a management decision? →.Activities Allowed or Unallowed; Allowable Costs and Cost Principles Program: ACL Centers for Independent Living (ALN 93.432) Federal Agency: U.S. Department of Health and Human Services Federal Award Year: September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matter compliance finding. Criteria 2 CFR 200.403(a) states that costs must "be necessary and reasonable for the performance of the federal award" to be allowable. Condition Three tested transactions were found to be unallowable in nature as they were not necessary or reasonable for the performance of the federal award. Questioned Costs $166 Context A sample of 40 was made from a population of 541 transactions charged to the major program for program expenses. Of the 40 sampled transactions, 3 transactions were found to be unreasonable and unallowable. Effect Charging unallowable costs to the major program results in erroneous charges to the federal award and raises compliance concerns. This can potentially lead to overcharging or undercharging the federal award, which may result in penalties or repayment obligations.Activities Allowed or Unallowed; Allowable Costs and Cost Principles Program: ACL Centers for Independent Living (ALN 93.432) Federal Agency: U.S. Department of Health and Human Services Federal Award Year: September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matter compliance finding. Criteria 2 CFR 200.403(a) states that costs must "be necessary and reasonable for the performance of the federal award" to be allowable. Condition Three tested transactions were found to be unallowable in nature as they were not necessary or reasonable for the performance of the federal award. Questioned Costs $166 Context A sample of 40 was made from a population of 541 transactions charged to the major program for program expenses. Of the 40 sampled transactions, 3 transactions were found to be unreasonable and unallowable. Effect Charging unallowable costs to the major program results in erroneous charges to the federal award and raises compliance concerns. This can potentially lead to overcharging or undercharging the federal award, which may result in penalties or repayment obligations. Cause The Organization had inadequate internal controls over compliance to detect charges that were unallowable prior to requesting reimbursement for the federal award. Repeat Finding No Auditor Recommendation We recommend that the Organization obtains a better understanding of allowable and unallowable costs for federal awards. We also recommend that the Organization implement a system of internal controls that can detect noncompliance prior to charging costs to the federal award. Views of Responsible Officials The Organization has reviewed, and agrees with, the finding and recommendation.
Show full finding ▾Hide full finding ▴.Activities Allowed or Unallowed; Allowable Costs and Cost Principles Program: ACL Centers for Independent Living (ALN 93.432) Federal Agency: U.S. Department of Health and Human Services Federal Award Year: September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matter compliance finding. Criteria 2 CFR 200.403(a) states that costs must "be necessary and reasonable for the performance of the federal award" to be allowable. Condition Three tested transactions were found to be unallowable in nature as they were not necessary or reasonable for the performance of the federal award. Questioned Costs $166 Context A sample of 40 was made from a population of 541 transactions charged to the major program for program expenses. Of the 40 sampled transactions, 3 transactions were found to be unreasonable and unallowable. Effect Charging unallowable costs to the major program results in erroneous charges to the federal award and raises compliance concerns. This can potentially lead to overcharging or undercharging the federal award, which may result in penalties or repayment obligations.Activities Allowed or Unallowed; Allowable Costs and Cost Principles Program: ACL Centers for Independent Living (ALN 93.432) Federal Agency: U.S. Department of Health and Human Services Federal Award Year: September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matter compliance finding. Criteria 2 CFR 200.403(a) states that costs must "be necessary and reasonable for the performance of the federal award" to be allowable. Condition Three tested transactions were found to be unallowable in nature as they were not necessary or reasonable for the performance of the federal award. Questioned Costs $166 Context A sample of 40 was made from a population of 541 transactions charged to the major program for program expenses. Of the 40 sampled transactions, 3 transactions were found to be unreasonable and unallowable. Effect Charging unallowable costs to the major program results in erroneous charges to the federal award and raises compliance concerns. This can potentially lead to overcharging or undercharging the federal award, which may result in penalties or repayment obligations. Cause The Organization had inadequate internal controls over compliance to detect charges that were unallowable prior to requesting reimbursement for the federal award. Repeat Finding No Auditor Recommendation We recommend that the Organization obtains a better understanding of allowable and unallowable costs for federal awards. We also recommend that the Organization implement a system of internal controls that can detect noncompliance prior to charging costs to the federal award. Views of Responsible Officials The Organization has reviewed, and agrees with, the finding and recommendation.
Activities Allowed or Unallowed; Allowable Costs and Cost Principles Auditor's Recommendations: We recommend that the Organization obtains a better understanding of allowable and unallowable costs for federal awards. We also recommend that the Organization implement a system of internal control that can detect noncompliance prior to charging costs to the federal award. Corrective Action: Executive Director, Faith Brown, will develop a process for checking and charging costs to federal awards as required per the compliance policy. The Executive Director will be responsible for verifying that all internal controls are operating and will have been checked for unallowable prior to disbursing future federal funds. Timing of remediation completion: Executive Director, Faith Brown, will complete by September 29, 2025.
FAC accepted this audit on March 23, 2022 — management decision was due September 23, 2022.
Procurement, Suspension and Debarment: Criteria - Per OMB guidance, non-federal entities are prohibited from contracting with parties that are suspended or debarred, or whose principals are suspended or debarred. The guidance also requires the entities to follow documented procurement procedures. Condition - There is a policy in place for procurement procedures and to determine whether vendors are suspended or debarred. The policy was not followed during the audit period. Context - Per our review of vendors over the applicable threshold, there was no documentation of having been reviewed for procurement, suspension or debarment. Cause - Staff had not been made aware of the procedures for procurement, suspension and debarment status. Effect - Purchases may occur that do not follow the policy, and contracts to vendors that had been suspended or debarred could be awarded and not detected. Auditor's Recommendations -The Organization should include a provision in contracts with respect to suspension and debarment, communicate all requirements for procurement to staff and establish procedures to verify vendors are not suspended or debarred.
Show full finding ▾Hide full finding ▴Procurement, Suspension and Debarment: Criteria - Per OMB guidance, non-federal entities are prohibited from contracting with parties that are suspended or debarred, or whose principals are suspended or debarred. The guidance also requires the entities to follow documented procurement procedures. Condition - There is a policy in place for procurement procedures and to determine whether vendors are suspended or debarred. The policy was not followed during the audit period. Context - Per our review of vendors over the applicable threshold, there was no documentation of having been reviewed for procurement, suspension or debarment. Cause - Staff had not been made aware of the procedures for procurement, suspension and debarment status. Effect - Purchases may occur that do not follow the policy, and contracts to vendors that had been suspended or debarred could be awarded and not detected. Auditor's Recommendations -The Organization should include a provision in contracts with respect to suspension and debarment, communicate all requirements for procurement to staff and establish procedures to verify vendors are not suspended or debarred.
The accounting policy to check that vendors are legitimate requires a written statement from vendors as to procurement, suspension and debarment, or CFI to verify within the System for Award Management vendor database, and the policy was not being followed. The accounting policy on procurement, suspension and debarment has been modified to include creating a manual copy of the screen shots when the verification is completed. Leah Velasco, Executive Director, is responsible for ensuring that CFI conducts training with accounting staff responsible for reviewing vendors to ensure that they are not suspended or debarred and ensuring this procedure is properly documented. CFI did not engage in business with any suspended or debarred vendors.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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