EIN: 930686170
UEI: NUGTB311H3C1
Audited by: Aprio, LLP
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 June 30, 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 30, 2026 (121 days from today).
What is a management decision? →FAC accepted this audit on June 21, 2025 — management decision was due December 21, 2025.
FAC accepted this audit on April 17, 2024 — management decision was due October 17, 2024.
FAC accepted this audit on May 17, 2023 — management decision was due November 17, 2023.
FAC accepted this audit on September 6, 2022 — management decision was due March 6, 2023.
Amounts drawn were based on estimated costs on the accrual basis, rather than tied to specific grant related cash needs. In addition, documentation of the reconciliation of amounts drawn to the organizations financial records was not verifiable and the process of review by an independent individual was not maintained in a consistent manner. Cause: While we understand that the organization had established a policy with regard to draw-downs of federal funds, it appears that policy was not consistently followed. Effect: Documentation of the process of reconciliation of draws to financial records and review by an individual independent of the preparation of the draw amounts was not verifiable. Audit Recommendation: We recommend the organization develop a standardized process for reconciling draw amounts to internal financial records and an internal control monitoring process to document the review and approval of all draws in advance of the drawdown of funds. In addition, the organization should ensure that all staff in charge of cash requests of federal funds receive specialized training related to the requirements and provisions of federal funding. Management Response: Management concurs with the auditor?s recommendation. During FY 2022, the organization implemented a standardized process for reconciling draw amounts to internal financial records. Draw requests and federal reporting are reviewed and approved prior to submission to the funders.
Show full finding ▾Hide full finding ▴Finding number: 2021-004 Finding type: Federal award finding Federal Assistance Listing No.: 93.138, 93.618, 93.630, 93.843, 93.873, 96.008, 96.009, 84.240, 84.161 Program name: Various Federal agencies: U.S. Department of Health and Human Services, Social Security Administration, U.S. Department of Education Pass-through entity: n/a Grant number: n/a Federal award year: 2021 Control deficiency type: Significant deficiency in internal control over compliance Instance of noncompliance: No Compliance requirement: Cash management Questioned costs: None Repeat finding: Yes Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, requires that the organization establish and maintain effective controls over the federal award that provides 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. Non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Condition: Amounts drawn were based on estimated costs on the accrual basis, rather than tied to specific grant related cash needs. In addition, documentation of the reconciliation of amounts drawn to the organizations financial records was not verifiable and the process of review by an independent individual was not maintained in a consistent manner. Cause: While we understand that the organization had established a policy with regard to draw-downs of federal funds, it appears that policy was not consistently followed. Effect: Documentation of the process of reconciliation of draws to financial records and review by an individual independent of the preparation of the draw amounts was not verifiable. Audit Recommendation: We recommend the organization develop a standardized process for reconciling draw amounts to internal financial records and an internal control monitoring process to document the review and approval of all draws in advance of the drawdown of funds. In addition, the organization should ensure that all staff in charge of cash requests of federal funds receive specialized training related to the requirements and provisions of federal funding. Management Response: Management concurs with the auditor?s recommendation. During FY 2022, the organization implemented a standardized process for reconciling draw amounts to internal financial records. Draw requests and federal reporting are reviewed and approved prior to submission to the funders.
2021-004 Finding - Federal award finding ? Significant deficiency in internal control over compliance. U.S. Department of Health and Human Services, Social Security Administration, U.S. Department of Education Context: Amounts drawn were based on estimated costs on the accrual basis, rather than tied to specific grant related cash needs. In addition, documentation of the reconciliation of amounts drawn to the organizations financial records was not verifiable and the process of review by an independent individual was not maintained in a consistent manner. Audit Recommendation: We recommend the organization develop a standardized process for reconciling draw amounts to internal financial records and an internal control monitoring process to document the review and approval of all draws in advance of the drawdown of funds. In addition, the organization should ensure that all staff in charge of cash requests of federal funds receive specialized training related to the requirements and provisions of federal funding. Action Taken: During FY 2022, the organization has implemented a standardized process for reconciling draw amounts to internal financial records. Draw requests and federal reporting are reviewed and approved prior to submission to the funders. Responsible parties: Shirley Cyr, Chief Financial Officer and Ian Rosser, Finance Manager. Anticipated completion date: Complete as of August 1, 2022.
2020-001
Documentation of volunteer hours used to support required match were not available or verifiable. In addition, certain amounts reported to the funder were incorrect. Cause: Policies to document and maintain documentation of matching activities have not been developed formally. Effect: The organization is unable to document adherence to the matching requirement of the grant. Audit Recommendation: We recommend the organization develop a standardized process recording and documenting volunteer hours to ensure the organization can accurately report having met all matching requirements and maintaining documentation in support of the match. Management Response: Management concurs with the auditor?s recommendation and has implemented a process to ensure volunteer hours are documented through the timekeeping system and value of services appropriately documented to support the matching requirements.
Show full finding ▾Hide full finding ▴Finding number: 2021-005 Finding type: Federal award finding Federal Assistance Listing No.: 96.008 Program name: Work Incentives Planning and Assistance Program Federal agencies: Social Security Administration Pass-through entity: n/a Grant number: n/a Federal award year: 2021 Control deficiency type: Significant deficiency in internal control over compliance Instance of noncompliance: No Compliance requirement: Matching, level of effort, earmarking Questioned costs: None Repeat finding: No Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, requires that the organization establish and maintain effective controls over the federal award that provides 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. In accordance with 2 CFR 200.306, costs and contributions that are deemed acceptable to meet matching requirements are verifiable from the non-entity?s records, are not included as contributions for any other federal award, are necessary and reasonable for accomplishment of program objectives, and are provided for in the approved budget. Condition: Documentation of volunteer hours used to support required match were not available or verifiable. In addition, certain amounts reported to the funder were incorrect. Cause: Policies to document and maintain documentation of matching activities have not been developed formally. Effect: The organization is unable to document adherence to the matching requirement of the grant. Audit Recommendation: We recommend the organization develop a standardized process recording and documenting volunteer hours to ensure the organization can accurately report having met all matching requirements and maintaining documentation in support of the match. Management Response: Management concurs with the auditor?s recommendation and has implemented a process to ensure volunteer hours are documented through the timekeeping system and value of services appropriately documented to support the matching requirements.
2021-005 Finding - Federal award finding ? Significant deficiency in internal control over compliance. Social Security Administration Context: Documentation of volunteer hours used to support required match were not available or verifiable. In addition, certain amounts reported to the funder were incorrect. Audit Recommendation: We recommend the organization develop a standardized process of recording and documenting volunteer hours to ensure the organization can accurately report having met all matching requirements and maintaining documentation in support of the match. Action taken: The organization has implemented a process to ensure volunteer hours are documented through the timekeeping system and value of services appropriately documented to support the matching requirements. Responsible parties: Shirley Cyr, Chief Financial Officer and Ian Rosser, Finance Manager. Anticipated completion date: Complete as of August 1 , 2022.
Two required reports were submitted after the required due date. In addition, for financial reports filed, reported expenditures were not supported by underlying accounting records and the organization did not maintain a reconciliation between the required reported and internal financial records. Lastly, certain amounts were reported incorrectly or were unsupported. All reports filed during the year under audit were selected for testing. Cause: Internal controls were not designed and implemented to ensure all required reports were submitted within the required deadline and with correct information. In addition, there is no documentation of an independent review of the reports for accuracy. Effect: Missed filings of required reports and incorrect information reported to the federal agency could prevent proper oversight and inquiry by the funding agency. Audit Recommendation: We recommend that management implement procedures to ensure all required reports are submitted properly and in a timely manner, and strengthen the organization?s re-view procedures related to the preparation of its financial reports. At a minimum, someone independent of the preparer should review the reports and reconcile the data reported to that in underlying accounting records, to ensure that the information reported is complete and accurate. In addition, the organization should ensure that all staff in charge of preparing and reviewing the financial reports have been provided with adequate training. Management Response: Management concurs with the auditor?s recommendation and has established a reporting schedule to ensure completion of federal reports within the required timeframe. During FY 2022, the organization implemented procedures for independent review and reconciliation of all reports prior to submission.
Show full finding ▾Hide full finding ▴Finding number: 2021-006 Finding type: Federal award finding Federal Assistance Listing No.: 93.630, 96.008, 16.575 Program name: Developmental Disabilities Basic Support and Advocacy Grants, Work Incentives Planning and Assistance Program, Crime Victim Assistance Federal agencies: U.S. Department of Health and Human Services, Social Security Administration, U.S. Department of Justice Pass-through entity: n/a, State of Oregon ? Department of Justice Grant number: n/a, VOCA-CS-2021-DisabilityRightsOregon-00016 Federal award year: 2021 Control deficiency type: Significant deficiency in internal control over compliance Instance of noncompliance: Yes Compliance requirement: Reporting Questioned costs: None Repeat finding: Yes Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, requires that the organization establish and maintain effective controls over the Federal award that provides 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. This system of controls should provide reasonable assurance that reports of Federal awards submitted to Federal agencies include all the activity of the reporting period, are supported by underlying accounting records, and are presented fairly and in accordance with program requirements. Condition: Two required reports were submitted after the required due date. In addition, for financial reports filed, reported expenditures were not supported by underlying accounting records and the organization did not maintain a reconciliation between the required reported and internal financial records. Lastly, certain amounts were reported incorrectly or were unsupported. All reports filed during the year under audit were selected for testing. Cause: Internal controls were not designed and implemented to ensure all required reports were submitted within the required deadline and with correct information. In addition, there is no documentation of an independent review of the reports for accuracy. Effect: Missed filings of required reports and incorrect information reported to the federal agency could prevent proper oversight and inquiry by the funding agency. Audit Recommendation: We recommend that management implement procedures to ensure all required reports are submitted properly and in a timely manner, and strengthen the organization?s re-view procedures related to the preparation of its financial reports. At a minimum, someone independent of the preparer should review the reports and reconcile the data reported to that in underlying accounting records, to ensure that the information reported is complete and accurate. In addition, the organization should ensure that all staff in charge of preparing and reviewing the financial reports have been provided with adequate training. Management Response: Management concurs with the auditor?s recommendation and has established a reporting schedule to ensure completion of federal reports within the required timeframe. During FY 2022, the organization implemented procedures for independent review and reconciliation of all reports prior to submission.
2021-006 Finding - Federal award finding ? Significant deficiency in internal control over compliance. U.S. Department of Health and Human Services, Social Security Administration, U.S. Department of Justice Context: Two required reports were submitted after the due date. In addition, for financial reports filed, reported expenditures were not supported by underlying accounting records and the organization did not maintain a reconciliation between the required report and internal financial records. Lastly, certain amounts were reported incorrectly or were unsupported. All reports filed during the year under audit were selected for testing. Audit Recommendation: We recommend that management implement procedures to ensure all required reports are submitted properly and in a timely manner, and strengthen the organization?s review procedures related to the preparation of financial reports. At a minimum, someone independent of the preparer should review the reports and reconcile the data reported to that in underlying accounting records to ensure that the information reported is complete and accurate. In addition, the organization should ensure that all staff in charge of preparing and reviewing the financial reports have been provided with adequate training. Action taken: During FY 2022, the organization established a reporting schedule to ensure completion of federal reports within the required timeframe and implemented procedures for independent review and reconciliation of all reports prior to submission. Responsible parties: Shirley Cyr, Chief Financial Officer and Ian Rosser, Finance Manager. Anticipated completion date: Complete as of August 1, 2022.
2020-002
FAC accepted this audit on July 28, 2021 — management decision was due January 28, 2022.
During our review of the cash draws from Payment Management System (PMS) throughout the year, we noted that the organization overdrew the grant during the year. In addition, amounts drawn were based on estimated costs on the accrual basis, rather than tied to specific grant related cash needs. Cause: While we understand that the organization had established a policy with regard to draw-downs of federal funds, it appears that policy was not consistently followed. Effect: Cash draws exceeded cash requirements for the three days subsequent to each draw. Written procedures were inconsistent with the organization?s practices. Questioned Costs: None. Repeat Finding: 2019-003. Audit Recommendation: We recommend the organization develop an internal control monitoring process to ensure controls are operating as designed. In addition, the organization should ensure that all staff in charge of cash requests of federal funds receive specialized training related to the requirements and provisions of federal funding. Management Response: Management agrees with this recommendation. Management adopted a new accounting system during the 2020 calendar year that will improve timeliness of financial reporting used to draw down federal awards. Further, management has hired a consultant to provide assistance with improving internal control monitoring processes and provide training to the Chief Financial Officer related to the requirements and provisions of federal funding. Finally, Management will require that the back-up calculations be included in the approval process.
Show full finding ▾Hide full finding ▴Finding number: 2020-001 ? Significant deficiency in internal control over compliance and instance of noncompliance related to cash management requirements. Federal agency: U.S. Department of Health and Human Services CFDA number: 93.138 Program name: Protection and Advocacy for Individuals with Mental Illness Pass-through entity: n/a Grant number: 6x98SM082573-01M001 Federal award year: 2020 Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, requires that the organization establish and maintain effective controls over the federal award that provides 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. In addition, Disability Rights Oregon?s current written accounting policy states that federal funds must be drawn in amounts not to exceed cash requirements for the three business days subsequent to the draw. Condition: During our review of the cash draws from Payment Management System (PMS) throughout the year, we noted that the organization overdrew the grant during the year. In addition, amounts drawn were based on estimated costs on the accrual basis, rather than tied to specific grant related cash needs. Cause: While we understand that the organization had established a policy with regard to draw-downs of federal funds, it appears that policy was not consistently followed. Effect: Cash draws exceeded cash requirements for the three days subsequent to each draw. Written procedures were inconsistent with the organization?s practices. Questioned Costs: None. Repeat Finding: 2019-003. Audit Recommendation: We recommend the organization develop an internal control monitoring process to ensure controls are operating as designed. In addition, the organization should ensure that all staff in charge of cash requests of federal funds receive specialized training related to the requirements and provisions of federal funding. Management Response: Management agrees with this recommendation. Management adopted a new accounting system during the 2020 calendar year that will improve timeliness of financial reporting used to draw down federal awards. Further, management has hired a consultant to provide assistance with improving internal control monitoring processes and provide training to the Chief Financial Officer related to the requirements and provisions of federal funding. Finally, Management will require that the back-up calculations be included in the approval process.
Finding no.: 2020-001 Contact person(s) responsible: Kevin Rogers, Chief Financial Officer Corrective action planned: Management adopted a new accounting system during the 2020 calendar year that will improve timeliness of financial reporting used to draw down federal awards. Further, management has hired a consultant to provide assistance with improving internal control monitoring processes and provide training to the Chief Financial Officer related to the requirements and provisions of federal funding. Finally, Management will require that the back-up calculations be included in the approval process. Anticipated completion date: September 31, 2021
2019-003
The organization is required to submit annual SF-425 reports to the funding agency to report cumulative spending status; however, the organization was unable to provide evidence that the annual report had been submitted. In addition, for quarterly reports filed, reported expenditures were not supported by underlying accounting records. All quarterly reports filed during the year under audit were selected for testing. Cause: Internal controls were not designed and implemented to ensure all required reports were submitted and with correct information. In addition, no one independent of the preparer reviewed the reports for accuracy. Effect: Missed filings of required reports and incorrect information reported to the federal agency prevented proper oversight and inquiry by the funding agency. Questioned Costs: Not applicable. Repeat Finding: 2019-004. Audit Recommendation: We recommend that management implement procedures to ensure all required reports are submitted properly and in a timely manner, and strengthen the organization?s review procedures related to the preparation of its Federal Financial Reports. At a minimum, someone independent of the preparer should review the reports and reconcile the data reported to that in underlying accounting records, to ensure that the information reported is complete and accurate. In addition, the organization should ensure that all staff in charge of preparing and reviewing the Federal Financial Reports have been provided with adequate training. Management Response: All SF-425 reports to the funding agency have been filed. Management agrees that procedures could be improved to ensure evidence of submitting the reports is available. Moreover, management agrees procedures should be strengthened related to preparation of Federal Financial Reports. In response to the 2019 audit, management began strengthening this procedure and provided training to the Chief Financial Officer. Further, management has hired a consultant to provide further assistance with improving internal control monitoring processes and provide further training to the Chief Financial Officer related to the requirements of Federal Financial Reports.
Show full finding ▾Hide full finding ▴Finding number: 2020-002 ? Significant deficiency in internal control over compliance and instance of noncompliance related to reporting requirements. Federal agency: U.S. Department of Health and Human Services CFDA numbers: 93.138 Program name: Protection and Advocacy for Individuals with Mental Illness Pass-through entity: n/a Grant number: 6x98SM082573-01M001 Federal award year: 2020 Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, requires that the organization establish and maintain effective controls over the Federal award that provides 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. This system of controls should provide reasonable assurance that reports of Federal awards submitted to Federal agencies include all the activity of the reporting period, are supported by underlying accounting records, and are presented fairly and in accordance with program requirements. Condition: The organization is required to submit annual SF-425 reports to the funding agency to report cumulative spending status; however, the organization was unable to provide evidence that the annual report had been submitted. In addition, for quarterly reports filed, reported expenditures were not supported by underlying accounting records. All quarterly reports filed during the year under audit were selected for testing. Cause: Internal controls were not designed and implemented to ensure all required reports were submitted and with correct information. In addition, no one independent of the preparer reviewed the reports for accuracy. Effect: Missed filings of required reports and incorrect information reported to the federal agency prevented proper oversight and inquiry by the funding agency. Questioned Costs: Not applicable. Repeat Finding: 2019-004. Audit Recommendation: We recommend that management implement procedures to ensure all required reports are submitted properly and in a timely manner, and strengthen the organization?s review procedures related to the preparation of its Federal Financial Reports. At a minimum, someone independent of the preparer should review the reports and reconcile the data reported to that in underlying accounting records, to ensure that the information reported is complete and accurate. In addition, the organization should ensure that all staff in charge of preparing and reviewing the Federal Financial Reports have been provided with adequate training. Management Response: All SF-425 reports to the funding agency have been filed. Management agrees that procedures could be improved to ensure evidence of submitting the reports is available. Moreover, management agrees procedures should be strengthened related to preparation of Federal Financial Reports. In response to the 2019 audit, management began strengthening this procedure and provided training to the Chief Financial Officer. Further, management has hired a consultant to provide further assistance with improving internal control monitoring processes and provide further training to the Chief Financial Officer related to the requirements of Federal Financial Reports.
Finding no.: 2020-002 Contact person(s) responsible: Kevin Rogers, Chief Financial Officer Corrective action planned: In response to the 2019 audit, management began strengthening this procedure and provided training to the Chief Financial Officer. Further, management has hired a consultant to provide further assistance with improving internal control monitoring processes and provide further training to the Chief Financial Officer related to the requirements of Federal Financial Reports. Anticipated completion date: September 31, 2021
2019-004
During our review of expenses, we noted instances in which the organization was not able to provide support for the basis of allocation, charges that were allocated based on labor distribution reports from prior periods, and changes made to previously allocated charges that were not reviewed. Cause: Following the fiscal 2019 audit and the identification of control weaknesses, the organization changed its process and methodology for allocating costs charged to grants, but did not update the labor distribution allocations quickly enough to provide for consistent treatment of costs charged to Federal awards through the 2020 year. Nevertheless, in addition, the organization did not retain adequate documentation to support changes to charges that had previously been reviewed in accordance with the organization?s policies. Finally, the organization?s written policies and procedures were not updated to reflect the change in methodology. Effect: The organization did not fully comply with the allowable cost principles specified in the Code of Federal Regulation. As a result, there may be charges to awards that were not properly allocated, do not have adequate support, and/or were not accorded consistent treatment. Questioned Costs: None reportable. Repeat Finding: No. Audit Recommendation: We recommend that the organization establish clear written guidelines on how certain costs are to be allocated. Appropriate documentation should be retained, and someone independent of the preparer should review allocations for reasonableness and accuracy. Management Response: Management agrees with this recommendation. Management will be revising our internal processes to ensure adequate documentation is being retained. Furthermore, management has hired a consultant to review our process and methodology for allocating costs charged to grants and to make recommendations on specific improvements in the process and systems of internal control. The consultant will also provide training to the Chief Financial Officer and other appropriate members of management related to allocation and allowable cost principles specified in the Code of Federal Regulation.
Show full finding ▾Hide full finding ▴Finding number: 2020-004 ? Significant deficiency in internal controls over compliance and instances of non-compliance related to allowable costs/cost principles requirements. Federal agencies: U.S. Department of Health and Human Services, Social Security Administration, U.S. Department of Education CFDA numbers: 93.138, 93.618, 93.630, 93.843, 93.873, 96.008, 96.009, 84.240, 84.161 Program name: various Pass-through entity: n/a Grant number: various Federal award year: 2020 Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart E ? Cost Principles, requires that costs charged to a federal award must be supported by a system of internal controls which provides reasonable assurance that time charges are accurate, allowable, and properly allocated, and supported by adequate documentation, and be accorded consistent treatment. Condition: During our review of expenses, we noted instances in which the organization was not able to provide support for the basis of allocation, charges that were allocated based on labor distribution reports from prior periods, and changes made to previously allocated charges that were not reviewed. Cause: Following the fiscal 2019 audit and the identification of control weaknesses, the organization changed its process and methodology for allocating costs charged to grants, but did not update the labor distribution allocations quickly enough to provide for consistent treatment of costs charged to Federal awards through the 2020 year. Nevertheless, in addition, the organization did not retain adequate documentation to support changes to charges that had previously been reviewed in accordance with the organization?s policies. Finally, the organization?s written policies and procedures were not updated to reflect the change in methodology. Effect: The organization did not fully comply with the allowable cost principles specified in the Code of Federal Regulation. As a result, there may be charges to awards that were not properly allocated, do not have adequate support, and/or were not accorded consistent treatment. Questioned Costs: None reportable. Repeat Finding: No. Audit Recommendation: We recommend that the organization establish clear written guidelines on how certain costs are to be allocated. Appropriate documentation should be retained, and someone independent of the preparer should review allocations for reasonableness and accuracy. Management Response: Management agrees with this recommendation. Management will be revising our internal processes to ensure adequate documentation is being retained. Furthermore, management has hired a consultant to review our process and methodology for allocating costs charged to grants and to make recommendations on specific improvements in the process and systems of internal control. The consultant will also provide training to the Chief Financial Officer and other appropriate members of management related to allocation and allowable cost principles specified in the Code of Federal Regulation.
Finding no.: 2020-004 Contact person(s) responsible: Kevin Rogers, Chief Financial Officer Corrective action planned: Management will be revising our internal processes to ensure adequate documentation is being retained. Furthermore, management has hired a consultant to review our process and methodology for allocating costs charged to grants and to make recommendations on specific improvements in the process and systems of internal control. The consultant will also provide training to the Chief Financial Officer and other appropriate members of management related to allocation and allowable cost principles specified in the Code of Federal Regulation. Anticipated completion date: September 31, 2021
During our review of payroll expenses, we noted that certain payroll costs, recovered through the Families First Coronavirus Response Act were also charged to other Federal awards. Cause: The organization did not have proper controls in place to ensure that costs recovered from other sources were not also charged to Federal awards. Effect: The organization did not fully comply with the allowable costs principles specified in the Code of Federal Regulation. As a result, there are charges to awards that are unallowed. Questioned Costs: None. Adjustments identified during the audit were recorded by the organization. Repeat Finding: No. Audit Recommendation: We recommend that the organization establish effective monitoring and review procedures to ensure that costs recovered from other sources are not also charged to Federal awards. Management Response: Management agrees with this recommendation. At the beginning of the pandemic, management did not have in place an adequate system to ensure the payroll costs for employees who used leave under the Family First Coronavirus Response Act were not charged to Federal awards. These costs were recovered under payroll tax credits authorized under the Family First Coronavirus Response Act. When these costs were identified, management immediately made adjustments to ensure Federal awards were not charged for these payroll costs that were already recovered through the Family First Coronavirus Response Act. Management will review records and develop a system to ensure such costs recovered through the Family First Coronavirus Response Act are not also charged to Federal awards in 2021.
Show full finding ▾Hide full finding ▴Finding number: 2020-005 ? Significant deficiency in internal controls over compliance related to allowable costs/cost principles requirements (payroll costs) Federal agencies: U.S. Department of Health and Human Services, Social Security Administration, U.S. Department of Education CFDA numbers: 93.138, 93.618, 93.630, 93.843, 93.873, 96.008, 96.009, 84.240, 84.161 Program name: various Pass-through entity: n/a Grant number: various Federal award year: 2020 Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart E ? Cost Principles. Costs charged to a Federal award must be supported by a system of internal controls which provide reasonable assurance that costs are not also recovered from another award or a third party. Condition: During our review of payroll expenses, we noted that certain payroll costs, recovered through the Families First Coronavirus Response Act were also charged to other Federal awards. Cause: The organization did not have proper controls in place to ensure that costs recovered from other sources were not also charged to Federal awards. Effect: The organization did not fully comply with the allowable costs principles specified in the Code of Federal Regulation. As a result, there are charges to awards that are unallowed. Questioned Costs: None. Adjustments identified during the audit were recorded by the organization. Repeat Finding: No. Audit Recommendation: We recommend that the organization establish effective monitoring and review procedures to ensure that costs recovered from other sources are not also charged to Federal awards. Management Response: Management agrees with this recommendation. At the beginning of the pandemic, management did not have in place an adequate system to ensure the payroll costs for employees who used leave under the Family First Coronavirus Response Act were not charged to Federal awards. These costs were recovered under payroll tax credits authorized under the Family First Coronavirus Response Act. When these costs were identified, management immediately made adjustments to ensure Federal awards were not charged for these payroll costs that were already recovered through the Family First Coronavirus Response Act. Management will review records and develop a system to ensure such costs recovered through the Family First Coronavirus Response Act are not also charged to Federal awards in 2021.
Finding no.: 2020-005 Contact person(s) responsible: Kevin Rogers, Chief Financial Officer Corrective action planned: Management will review records and develop a system to ensure such costs recovered through the Family First Coronavirus Response Act or charged to Federal awards in 2021, not both. Anticipated completion date: June 30, 2021
FAC accepted this audit on July 22, 2020 — management decision was due January 22, 2021.
During our review of the cash draws from Payment Management System (PMS) throughout the year, we noted that the organization overdrew certain grants during the year. In addition, the amount drawn was based on estimated costs, rather than tied to specific grant needs. Cause: While we understand that the organization had established a policy with regard to draw-downs of federal funds, it appears that policy was not always followed. Effect: Cash draws exceeded cash requirements for the three days subsequent to each draw. Written procedures were inconsistent with the organization?s practices. Questioned Costs: None. Repeat Finding: No. Audit Recommendation: We recommend the organization develop an internal control monitoring process to ensure controls are operating as designed. In addition, the organization should ensure that all staff in charge of cash requests of federal funds receive specialized training related to the requirements and provisions of federal funding. Management Response: Management agrees with this recommendation. Management determined a condition that led to this finding was an accounting system that does not provide timely expense reporting. As such, management began procurement of a new accounting and financial reporting system in March 2020 and expects the system will be operational by August 2020. In August 2019, the Chief Financial Officer received specialized training regarding the requirements and provisions of federal funding. The Chief Financial Officer will review this training again in 2020.
Show full finding ▾Hide full finding ▴Finding number: 2019-003 ? Significant deficiency in internal control over compliance and instance of noncompliance related to cash management requirements. Federal agency: Department of Health and Human Services CFDA number: 93.138 Program name: Protection and Advocacy for Individuals with Mental Illness Pass-through entity: n/a Grant number: 5x98SM004197-19 Federal award year: 2019 Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, requires that the organization establish and maintain effective controls over the Federal award that provides 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. In addition, Disability Rights Oregon?s current written accounting policy states that federal funds must be drawn in amounts not to exceed cash requirements for the three business days subsequent to the draw. Condition: During our review of the cash draws from Payment Management System (PMS) throughout the year, we noted that the organization overdrew certain grants during the year. In addition, the amount drawn was based on estimated costs, rather than tied to specific grant needs. Cause: While we understand that the organization had established a policy with regard to draw-downs of federal funds, it appears that policy was not always followed. Effect: Cash draws exceeded cash requirements for the three days subsequent to each draw. Written procedures were inconsistent with the organization?s practices. Questioned Costs: None. Repeat Finding: No. Audit Recommendation: We recommend the organization develop an internal control monitoring process to ensure controls are operating as designed. In addition, the organization should ensure that all staff in charge of cash requests of federal funds receive specialized training related to the requirements and provisions of federal funding. Management Response: Management agrees with this recommendation. Management determined a condition that led to this finding was an accounting system that does not provide timely expense reporting. As such, management began procurement of a new accounting and financial reporting system in March 2020 and expects the system will be operational by August 2020. In August 2019, the Chief Financial Officer received specialized training regarding the requirements and provisions of federal funding. The Chief Financial Officer will review this training again in 2020.
Finding no.: 2019-003 Contact person(s) responsible: Kevin Rogers, Chief Financial Officer Corrective action planned: Management determined a condition that led to this finding was an accounting system that does not provide timely expense reporting. As such, management began procurement of a new accounting and financial reporting system in March 2020 and expects the system will be operational by August 2020. In August 2019, the Chief Financial Officer received specialized training regarding the requirements and provisions of federal funding. The Chief Financial Officer will review this training again in 2020. Anticipated completion date: August 31, 2020
The organization is required to submit annual SF-425 reports to the funding agency to report cumulative spending status; however, the organization was unable to provide these required annual reports for testing during the audit. In addition, for all of the reports filed, reported expenditures were not supported by underlying accounting records. All quarterly reports filed during the year under audit were selected for testing. Cause: Internal controls were not designed and implemented to ensure all required reports were submitted and with correct information. In addition, no one independent of the preparer reviewed the reports for accuracy. Effect: Missed filings of required reports and incorrect information reported to the federal agency prevented proper oversight and inquiry by the funding agency. Questioned Costs: Not applicable. Repeat Finding: 2018-005. Audit Recommendation: We recommend that management implement procedures to ensure all required reports are submitted properly and in a timely manner, and strengthen the organization?s review procedures related to the preparation of its Federal Financial Reports. At a minimum, someone independent of the preparer should review the reports and reconcile the data reported to that in underlying accounting records, to ensure that the information reported is complete and accurate. In addition, the organization should ensure that all staff in charge of preparing and re-viewing the Federal Financial Reports have been provided with adequate training. Management Response: Management agrees with this recommendation. The Chief Financial Officer determined a condition that led to this finding was an external contractor who prepares DRO?s quarterly financial statements did not provide management timely reports. These reports are relied on for SF-425 reporting. This caused the Chief Financial Officer to miss deadlines established for SF-425 reporting. Management met with this external contractor in September 2019 to discuss the issue. After determining the external contractor is unable to provide management with timely reports, management began procurement of a new accounting and financial reporting system in March 2020 and expects the system will be operational by August 2020. The Chief Financial Officer will begin sending the Executive Director all required financial reports for review.
Show full finding ▾Hide full finding ▴Finding number: 2019-004 ? Significant deficiency in internal control over compliance and instance of noncompliance related to reporting requirements. Federal agency: Department of Health and Human Services CFDA numbers: 93.138, 93,618, 93.630, 93.843, 93.873 Program names: Various Pass-through entity: n/a Grant numbers: Various Federal award years: 2016, 2017, 2018, and 2019 Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, requires that the organization establish and maintain effective controls over the Federal award that provides 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. This system of controls should provide reasonable assurance that reports of Federal awards submitted to Federal agencies include all the activity of the reporting period, are supported by underlying accounting records, and are presented fairly and in accordance with program requirements. Condition: The organization is required to submit annual SF-425 reports to the funding agency to report cumulative spending status; however, the organization was unable to provide these required annual reports for testing during the audit. In addition, for all of the reports filed, reported expenditures were not supported by underlying accounting records. All quarterly reports filed during the year under audit were selected for testing. Cause: Internal controls were not designed and implemented to ensure all required reports were submitted and with correct information. In addition, no one independent of the preparer reviewed the reports for accuracy. Effect: Missed filings of required reports and incorrect information reported to the federal agency prevented proper oversight and inquiry by the funding agency. Questioned Costs: Not applicable. Repeat Finding: 2018-005. Audit Recommendation: We recommend that management implement procedures to ensure all required reports are submitted properly and in a timely manner, and strengthen the organization?s review procedures related to the preparation of its Federal Financial Reports. At a minimum, someone independent of the preparer should review the reports and reconcile the data reported to that in underlying accounting records, to ensure that the information reported is complete and accurate. In addition, the organization should ensure that all staff in charge of preparing and re-viewing the Federal Financial Reports have been provided with adequate training. Management Response: Management agrees with this recommendation. The Chief Financial Officer determined a condition that led to this finding was an external contractor who prepares DRO?s quarterly financial statements did not provide management timely reports. These reports are relied on for SF-425 reporting. This caused the Chief Financial Officer to miss deadlines established for SF-425 reporting. Management met with this external contractor in September 2019 to discuss the issue. After determining the external contractor is unable to provide management with timely reports, management began procurement of a new accounting and financial reporting system in March 2020 and expects the system will be operational by August 2020. The Chief Financial Officer will begin sending the Executive Director all required financial reports for review.
Finding no.: 2019-004 Contact person(s) responsible: Kevin Rogers, Chief Financial Officer Corrective action planned: The Chief Financial Officer determined a condition that led to this finding was an external contractor who prepares DRO?s quarterly financial statements did not provide management timely re-ports. These reports are relied on for SF-425 reporting. This caused the Chief Financial Officer to miss deadlines established for SF-425 reporting. Management met with this external contractor in September 2019 to discuss the issue. After determining the external contractor is unable to provide management with timely reports, management began procurement of a new accounting and financial reporting system in March 2020 and expects the system will be operational by August 2020. The Chief Financial Officer will begin sending the Executive Director all required financial reports for review. Anticipated completion date: August 31, 2020
2018-005
Our testing of the eligibility compliance requirement included testing a random sample of six cases, representing approximately 10% of the population. From these, we noted one instance in which the participant or client did not meet the eligibility requirement for the developmental disabilities program, due to being coded to the wrong grant in the client-tracking database. Cause: The organization did not have proper controls in place to ensure that only eligible participants were being served. Effect: A participant was incorrectly coded to the wrong grant. In addition, as a result of the miscoding, the information reported to the federal agency related to program performance was incorrect, which prevents proper oversight and inquiry by the funding agency. Questioned Costs: Unknown. Repeat Finding: No. Audit Recommendation: We recommend that the organization establish effective monitoring and review procedures to ensure that all participants or clients benefitting from a program are actually eligible for that program. Management Response: Management agrees with this recommendation. The Legal Director and Director of Operations reviewed case acceptance procedures with staff. Management is also exploring whether changes can be made to the electronic case management system as a secondary check to client eligibility.
Show full finding ▾Hide full finding ▴Finding number: 2019-005 ? Significant deficiencies in internal controls over compliance related to eligibility. Federal agency: Department of Health and Human Services CFDA numbers: 93.630 Program names: Developmental Disabilities Basic Support and Advocacy Grants Pass-through entity: n/a Grant numbers: 1901ORPADD-00; 1901ORPADD-01; 1901ORPADD-02 Federal award years: 2019 Criteria: Only eligible participants should benefit from a program, and the organization should have monitoring procedures in place to ascertain that all established internal control policies and procedures regarding program participant eligibility determinations are being followed. In addition, Disability Rights Oregon?s internal controls also require that the Legal Director meet with all attorneys at least quarterly to review cases. Condition: Our testing of the eligibility compliance requirement included testing a random sample of six cases, representing approximately 10% of the population. From these, we noted one instance in which the participant or client did not meet the eligibility requirement for the developmental disabilities program, due to being coded to the wrong grant in the client-tracking database. Cause: The organization did not have proper controls in place to ensure that only eligible participants were being served. Effect: A participant was incorrectly coded to the wrong grant. In addition, as a result of the miscoding, the information reported to the federal agency related to program performance was incorrect, which prevents proper oversight and inquiry by the funding agency. Questioned Costs: Unknown. Repeat Finding: No. Audit Recommendation: We recommend that the organization establish effective monitoring and review procedures to ensure that all participants or clients benefitting from a program are actually eligible for that program. Management Response: Management agrees with this recommendation. The Legal Director and Director of Operations reviewed case acceptance procedures with staff. Management is also exploring whether changes can be made to the electronic case management system as a secondary check to client eligibility.
Finding no.: 2019-005 Contact person(s) responsible: Kevin Rogers, Chief Financial Officer Corrective action planned: The Legal Director and Director of Operations reviewed case acceptance procedures with staff. Management is also exploring whether changes can be made to the electronic case management system as a secondary check to client eligibility. Anticipated completion date: August 31, 2020
FAC accepted this audit on April 21, 2019 — management decision was due October 21, 2019.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
2017-003
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on April 1, 2018 — management decision was due October 1, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on April 17, 2017 — management decision was due October 17, 2017.
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