EIN: 911704028
UEI: HKFDGSVSE8R4
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 24, 2026. 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 24, 2026 (126 days from today).
What is a management decision? →Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.329, recipients must submit performance reports as required by the Federal awarding agency and ensure such reports are accurate, complete, and submitted timely. Additionally, 2 CFR 200.303 requires the entity to establish and maintain effective internal controls over Federal awards, including controls that provide reasonable assurance that reporting requirements are met and that documentation is retained to support compliance. Condition: During testing of reporting, we noted the following: - Management stated that required reviews and approvals of performance reports were conducted in person, but the organization does not maintain documentation or an audit trail to evidence these reviews. While documentation was available for quarterly performance reports, 2 of 2 annual performance reports and 6 of 21 monthly performance reports tested lacked evidence of review and approval. - Additionally, 6 of 10 performance reports selected for testing were not submitted/uploaded timely in accordance with grantor requirements. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The Organization has not established formalized policies and procedures governing the preparation, review, and timely submission of performance reports. As a result, responsibility for monitoring reporting deadlines and performing supervisory review was informal and not consistently documented. Effect: Failure to submit required performance reports timely increases the risk of noncompliance with federal award requirements and may result in adverse actions by the federal awarding agency, including delayed reimbursements or additional monitoring. Additionally, the lack of a documented review process increases the risk that performance reports may be incomplete, inaccurate, or not aligned with program requirements. Repeat finding: No Recommendation: We recommend the Organization develop and implement formal policies and procedures to ensure required performance reports are prepared, reviewed, and submitted in a timely manner. Such procedures should include clearly defined roles and responsibilities, tracking of reporting deadlines, and documented evidence of supervisory review and approval prior to submission. Views of responsible officials: There is no disagreement with the audit finding.
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the Organization develop and implement formal policies and procedures to ensure required performance reports are prepared, reviewed, and submitted in a timely manner. Such procedures should include clearly defined roles and responsibilities, tracking of reporting deadlines, and documented evidence of supervisory review and approval prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was related to a one-time ARPA grant during a period of staff transition, where performance reports were not consistently documented as reviewed and approved prior to submission. Since then, management has implemented formalized procedures for grant reporting. All performance reports are now prepared by designated program staff, tracked against reporting deadlines, and subject to supervisory review and approval by the Executive Director prior to submission. These procedures establish clear roles and responsibilities and ensure timely, documented review and submission of required reports. Name(s) of the contact person(s) responsible for corrective action: Monique Valenzuela, Executive Director and Theo Everhearts, Senior Director of Finance. Planned completion date for corrective action plan: June 2024
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, an entity is required to establish and maintain effective internal controls over Federal awards, including controls that provide reasonable assurance that reporting requirements are met and that documentation is retained to support compliance. Condition: During payroll testing, we noted for 2 of 60 payroll disbursements tested, the employee’s timecard was self‑approved by the individual whose time was being charged. There is no mitigating control in place to prevent or detect self‑approval of timecards or allocation of payroll costs. Questioned costs: None Context: At the time the timesheet was filed, there was no control system in place to prevent or detect such self-approval of timecards or allocation of payroll costs. The two instances noted were for the same employee and isolated to that specific employee. Cause: The Organization has not established formalized policies or supervisory procedures to prevent employees from self‑approving their own timecards. Effect: Self‑approval of timecards increases the risk of inaccurate or unsupported payroll charges, misallocation of labor costs, potential fraud or manipulation of reported hours, and reduced reliability of payroll and cost‑allocation data. Repeat finding: No Recommendation: We recommend the Organization develop and implement formal policies and procedures or workflow restrictions that prevent employees from self‑approving their own timecards. Views of responsible officials: There is no disagreement with the audit finding.
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the Organization develop and implement formal policies and procedures or workflow restrictions that prevent employees from self‑approving their own timecards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. During 2024, the Organization implemented BanbooHR to replace manual timekeeping and strengthen payroll controls. The self-approval issue occurred during initial system implementation and was identified through audit procedures. A corrective control has since been established whereby the Human Resources Manager reviews and approves the Executive Director's timecards, eliminating the ability for self-approval. In addition, payroll continues to be independently processed and reviewed by the Senior Director of Finanice, providing an additional layer of oversight. These control enhancements ensure proper segregation of duties and prevent self-approval of timecards going forward. Name(s) of the contact person(s) responsible for corrective action: Monique Valenzuela, Executive Director and Theo Everheart, Senior Director of Finance. Planned completion date for corrective action plan: May 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 28, 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 July 28, 2025, which was (388 days ago).
What is a management decision? →Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP0002 – 2021, SLFRP1045 – 2021, SLFRP0194 - 2021 Pass-Through Agency: Washington State Department of Commerce, City of Seattle, Snohomish County Pass-Through Number(s): (DOC) 23-F21400119-017, DC222308, CLFR-042 Award Period: Various Type of Finding: • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: 2 CFR 200.430 states: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. In addition, records must support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award or a Federal award and non-Federal award. Further, budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards. Condition: For some paychecks tested, it was noted the percentage of hours worked on the Federal program as indicated on the timesheet did not always tie to the allocation spreadsheet which determined the payroll costs that was ultimately charged to the major program. In addition, for one employee paycheck tested that was partially allocated to the major program, it was found that there was an error in the calculation of a salary increase, which resulted in an incorrect amount being charged to the program. Questioned costs: $2,339 Context: Of the 40 paychecks tested, 10 paychecks showed a potential over allocation of payroll costs to the Federal program. These over allocations varied from paycheck to paycheck and ranged from $5 to $1,648. One of the paychecks tested also included the miscalculation of salary amount. Cause: The person responsible for allocating payroll is no longer employed with Ventures. Therefore, specific cause cannot be identified. It was noted, however, there were two allocation spreadsheet templates being used during this fiscal year causing both a redundancy of information and a lack of synchronized information in some areas. This was likely the main reason for the allocation related issues encountered during the audit. In addition, the miscalculation of the payrate that occurred was not detected by the organization’s internal controls. Effect: Potential outcome is an overallocation to the Federal program leading to requests for reimbursement of funds (in the payroll expense category). Repeat finding: No Recommendation: We recommend the Organization utilize one spreadsheet for allocating payroll costs and implement additional controls to ensure the allocations to Federal grants accurately reflect the actual hours worked. Views of responsible officials: There is no disagreement with the audit finding.
Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend the Organization utilize one spreadsheet for allocating payroll costs and implement additional controls to ensure the allocations to Federal grants accurately reflect the actual hours worked. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ventures has stopped utilizing multiple allocation spreadsheets and will only use one spreadsheet. This single spreadsheet will be utilized for all payroll cost allocations and will be housed within the finance department under restricted access. The allocation of expenses to grants will be based on the FTE count per the payroll allocation spreadsheet. Changes to the allocations will be documented and shared with the Executive Director. Name(s) of the contact person(s) responsible for corrective action: Theo Everheart and Monique Valenzuela Planned completion date for corrective action plan: 07/31/2024
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP0002 – 2021, SLFRP1045 – 2021, SLFRP0194 - 2021 Pass-Through Agency: Washington State Department of Commerce, City of Seattle, Snohomish County Pass-Through Number(s): (DOC) 23-F21400119-017, DC222308, CLFR-042 Award Period: Various Type of Finding: • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: For grants and cooperative agreements, the procurement method used must be appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320 or the entities policies, whichever is more restrictive. Condition: Procurement procedures were not followed in accordance with the Agency’s policy. Questioned costs: None Context: Eight vendors that were identified as requiring procurement procedures during testing did not have formal documentation of obtaining bids, the reason for final decision and justification for sole source. Cause: The Agency did not follow its procurement policy. Effect: The Agency is out of compliance with its procurement policy. Repeat finding: No Recommendation: We recommend the Agency's procurement policy is updated to reflect the current federal guidelines and that policies and procedures are implemented to ensure that the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price is documented as applicable (2 CFR section 200.318(i) and 48 CFR Part 44 and section 52.244-2). Views of responsible officials: There is no disagreement with the audit finding.
Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend the Agency's procurement policy is updated to reflect the current federal guidelines and that policies and procedures are implemented to ensure that the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price is documented as applicable (2 CFR section 200.318(i) and 48 CFR Part 44 and section 52.244-2). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Ventures is in the process of evaluating and updating our procurement policy and expects it to be complete by year end. We have already started making sure necessary documents needed for RFQs and RFPs are kept in a restricted access folder along with the methodologies and tabulations for the final decisions. The Executive Director will approve all final decisions on RFPs and RFQs. Name(s) of the contact person(s) responsible for corrective action: Theo Everheart and Monique Valenzuela Planned completion date for corrective action plan: 12/31/2024
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1045 - 2021 Pass-Through Agency: City of Seattle Pass-Through Number(s): DC222308 Award Period: 4/1/2022 to 3/31/2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: 2 CFR 200.303 of the Uniform Guidance states the recipient of Federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Controls over expenditure approval were not being consistently applied. Questioned costs: $3,781 Context: Of the 29 general disbursements tested, 5 expenditures did not show evidence of approval Cause: Likely caused by an administrative oversight or error. Effect: Potential outcome would be an unallowable cost being charged to the Federal program. Repeat finding: No Recommendation: We recommend that approval of all expenditures, whether initiated by an invoice or a journal entry be documented. In the case where the expenditure is likely to be charged to a Federal program, it is recommended there be documentation of approval from someone knowledgeable of allowability of costs (it is permissible if this is the same individual as the initial approver). Views of responsible officials: There is no disagreement with the audit finding.
Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend that approval of all expenditures, whether initiated by an invoice or a journal entry be documented. In the case where the expenditure is likely to be charged to a Federal program, it is recommended there be documentation of approval from someone knowledgeable of allowability of costs (it is permissible if this is the same individual as the initial approver). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ventures has moved to keeping copies of the check requests/payment requests and invoice in a restricted folder. The check request is initiated by someone knowledgeable of the program and approved by an overseeing director, also knowledgeable of the program. These two documents are required for accounting to pay and will be returned without proper approval and corresponding invoice. Name(s) of the contact person(s) responsible for corrective action: Theo Everheart and Monique Valenzuela Planned completion date for corrective action plan: 09/30/2024
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