EIN: 931078543
UEI: MEL1AJK8F8G9
Audited by: Jones & Roth, P.C.
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 15, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 15, 2026 (175 days ago).
What is a management decision? →FAC accepted this audit on August 7, 2024 — management decision was due February 7, 2025.
FAC accepted this audit on August 7, 2023 — management decision was due February 7, 2024.
FAC accepted this audit on July 7, 2022 — management decision was due January 7, 2023.
FAC accepted this audit on September 21, 2021 — management decision was due March 21, 2022.
During our testing of payroll disbursements, we noted several instances in which there was not supporting documentation maintained for approved employee pay rates. We also noted instances in which employee time sheets were not approved by an authorized individual. We also noted lack of documentation for employee stipends for cell phones and health insurance. Cause: Policies and procedures were not designed and/or implemented to ensure that documentation for pay rates and stipends were approved and retained. The controls for approval of timesheets were not properly implemented. Effect: This condition increases risks that unallowable costs would be charged to the federal award. Questioned Costs: None. Context: Our sample size was 21 payroll disbursements for which each disbursement represents one employee for one pay period; the sample was not a statistically valid sample. We found 20 instances in which documentation of approved employee pay rates were not retained. We found 2 instances in which time sheets did not included signatures evidencing approval. We found 3 instances in which documentation for the approval of stipends for cell phones or health insurance was not completed/retained. Repeat Finding: No. Recommendation: We recommend management revise the current processes in place for the organization?s payroll disbursement system and develop procedures to address documentation for employee pay rates, timesheet review, and employee stipends. Systems should be designed and implemented to ensure documentation is retained. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2020-002 Federal Program: Coronavirus Relief Fund (CRF) (Assistance Listing # 21.019) Pass-through Agency: Oregon Health Authority Type of Finding: Material weakness in internal control over compliance Compliance Requirement: Allowable costs Criteria: The U.S. Treasury Guidance and the federal award agreements for the Coronavirus Relief Fund stipulate that costs charged to the federal award must establish a direct connection between the cost and COVID-19 related expenses and must be supported by appropriate documentation. It is the responsibility of management to design and implement internal controls over compliance to ensure compliance with the material compliance requirements of the federal award will be achieved. Condition: During our testing of payroll disbursements, we noted several instances in which there was not supporting documentation maintained for approved employee pay rates. We also noted instances in which employee time sheets were not approved by an authorized individual. We also noted lack of documentation for employee stipends for cell phones and health insurance. Cause: Policies and procedures were not designed and/or implemented to ensure that documentation for pay rates and stipends were approved and retained. The controls for approval of timesheets were not properly implemented. Effect: This condition increases risks that unallowable costs would be charged to the federal award. Questioned Costs: None. Context: Our sample size was 21 payroll disbursements for which each disbursement represents one employee for one pay period; the sample was not a statistically valid sample. We found 20 instances in which documentation of approved employee pay rates were not retained. We found 2 instances in which time sheets did not included signatures evidencing approval. We found 3 instances in which documentation for the approval of stipends for cell phones or health insurance was not completed/retained. Repeat Finding: No. Recommendation: We recommend management revise the current processes in place for the organization?s payroll disbursement system and develop procedures to address documentation for employee pay rates, timesheet review, and employee stipends. Systems should be designed and implemented to ensure documentation is retained. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding 2020-002 Corrective action planned: The retirement of Cornerstone?s longtime CFO in December of 2019 brought about significant opportunities for clarification of process. This led to both updated and additional policies and procedures that correlate to this finding. The following corrective actions were taken: a) In late 2020, a new electronic time-keeping system was employed, which requires employee and supervisor approval before payroll can be processed. Time sheets can be generated from this system, which includes approval verification. The Accounting Manager, Kayla Haas ensures all approvals are done prior to payroll processing. b) Stricter wage documentation procedures have been employed since June 2020. All offer letters (with initial pay rates) are signed by both the employee and supervisor/HR staff. These documents are retained in the personnel files. A form is used for all pay rate/status changes, signed by management, and retained in the personnel file. The Accounting Manager, Kayla Haas, will obtain such documentation before making changes in the payroll system. c) Policies are in the process of being updated to document all employee stipends. This will be completed before December 31, 2021 by the Operations Director, Michelle Cady. Person(s) responsible: Kayla Haas, Accounting Manager and Michelle Cady, Operations Director Anticipated date of completion: December 31, 2021
During our testing of non-payroll disbursements, we noted one instance in which costs were charged to the federal award that did not directly relate to COVID-19 as required and one instance for which supporting documentation for costs charged to the federal award was not retained. Cause: The internal controls in place were not adequately designed and/or implemented to ensure a connection between the cost and COVID-19 existed prior to charging the federal award. Internal controls in place were not adequately implemented to ensure that sufficient documentation of expenses charged to federal awards was retained. Effect: This condition increases risks that federal awards would be used for unallowable activities and/or that unallowable costs would be charged to the federal award. Questioned Costs: Questioned costs are aggregated and reported in compliance Finding 2020-005. Context: Our sample size was 50 disbursements; the sample was not a statistically valid sample. Repeat Finding: No. Recommendation: We recommend management review the internal controls in place with respect to allowable costs to design and implement additional controls to ensure only allowable costs are charged to federal awards and that sufficient documentation is retained for all costs charged to federal award programs. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2020-003 Federal Program: Coronavirus Relief Fund (Assistance Listing # 21.019) Pass-through Agency: Oregon Health Authority Type of Finding: Significant deficiency in internal control over compliance Compliance Requirements: Allowable activities, allowable costs Criteria: The U.S. Treasury Guidance and the federal award agreements for the Coronavirus Relief Fund stipulate that costs charged to the federal award must establish a direct connection between the cost and COVID-19 related expenses and must be supported by appropriate documentation. It is the responsibility of management to design and implement internal controls over compliance to ensure compliance with the material compliance requirements of the federal award will be achieved. Condition: During our testing of non-payroll disbursements, we noted one instance in which costs were charged to the federal award that did not directly relate to COVID-19 as required and one instance for which supporting documentation for costs charged to the federal award was not retained. Cause: The internal controls in place were not adequately designed and/or implemented to ensure a connection between the cost and COVID-19 existed prior to charging the federal award. Internal controls in place were not adequately implemented to ensure that sufficient documentation of expenses charged to federal awards was retained. Effect: This condition increases risks that federal awards would be used for unallowable activities and/or that unallowable costs would be charged to the federal award. Questioned Costs: Questioned costs are aggregated and reported in compliance Finding 2020-005. Context: Our sample size was 50 disbursements; the sample was not a statistically valid sample. Repeat Finding: No. Recommendation: We recommend management review the internal controls in place with respect to allowable costs to design and implement additional controls to ensure only allowable costs are charged to federal awards and that sufficient documentation is retained for all costs charged to federal award programs. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding 2020-003 Corrective action planned: The retirement of Cornerstone?s longtime CFO in December of 2019 coupled with the pandemic impacted organizational capacity. Fortunately, mid-2020 Cornerstone hired a new Accounting Manager with significant expertise to assist in internal process and controls. This led to the following changes related to this finding: a) Effective for the 2021 grant period, all costs allocated to grants are reviewed/approved by the Operations Director, Michelle Cady, to ensure accuracy and compliance to grant requirements. b) Since the change in accounting staff in 2020, expense-related documents, including invoices and credit card receipts, are retained as either a paper or digital file by the Accounting Manager, Kayla Haas. Person(s) responsible: Kayla Haas, Accounting Manager and Michelle Cady, Operations Director Anticipated date of completion: January 1, 2021
Indirect costs were charged to the federal award (Oregon Health Authority Grant #165657). Cause: We noted Cornerstone did not have adequate internal controls in place to ensure the federal award agreements were carefully reviewed for compliance provisions. We also noted the budget submitted to Oregon Health Authority for Grant #165657 included a provision for a 15 percent indirect cost rate for the funding. The budget was approved by the granting agency. Effect: The effect is indirect costs of $14,916 were charged to the CRF program which are considered unallowable costs under the terms of the federal award. Questioned Costs: Questioned costs are aggregated and reported in compliance Finding 2020-005. Context: Not applicable. Repeat Finding: No. Recommendation: We recommend management design and implement internal controls over compliance to ensure that the terms and compliance requirements of all agreements involving federal awards are reviewed carefully and consistently followed. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2020-004 Federal Program: Coronavirus Relief Fund (Assistance Listing # 21.019) Pass-through Agency: Oregon Health Authority Type of Finding: Significant deficiency in internal control over compliance Compliance Requirements: Allowable activities, allowable costs Criteria: The U.S. Treasury Guidance and agreements related to the Coronavirus Relief Fund grants stipulate that recipients may not charge indirect costs to the CRF grants. Condition: Indirect costs were charged to the federal award (Oregon Health Authority Grant #165657). Cause: We noted Cornerstone did not have adequate internal controls in place to ensure the federal award agreements were carefully reviewed for compliance provisions. We also noted the budget submitted to Oregon Health Authority for Grant #165657 included a provision for a 15 percent indirect cost rate for the funding. The budget was approved by the granting agency. Effect: The effect is indirect costs of $14,916 were charged to the CRF program which are considered unallowable costs under the terms of the federal award. Questioned Costs: Questioned costs are aggregated and reported in compliance Finding 2020-005. Context: Not applicable. Repeat Finding: No. Recommendation: We recommend management design and implement internal controls over compliance to ensure that the terms and compliance requirements of all agreements involving federal awards are reviewed carefully and consistently followed. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding 2020-004 Corrective action planned: The Budget Guidance document and template provided on July 26, 2020, by the funder, included specific instructions for budgeting 15% indirect costs. The budget submitted by Cornerstone which reflected the indirect costs was approved by the funder and we now realize this conflicted with the final Grant Agreement executed on August 12, 2020. However, this was received after our submission. We have modified our process for future Federal awards to alleviate confusion and accurately budget allocated funding. Effective for the 2021 grant period, new grant agreements are reviewed by both the Accounting Manager, Kayla Haas, and Operations Director, Michelle Cady, to ensure a thorough understanding of all funding sources, guidelines, and restrictions. Person(s) responsible: Kayla Haas, Accounting Manager and Michelle Cady, Operations Director Anticipated date of completion: January 1, 2021
During our testing of allowable costs we noted indirect costs were charged to the federal award resulting in known questioned costs. We also noted instances of unallowable costs charged to the federal award in our testing of a sample of non-payroll disbursement transactions resulting in known and projected likely questioned costs. The aggregate questioned costs are in excess of the reportable threshold of $25,000. See details at Findings 2020-003 and 2020-004. Cause: There was an instance in which costs charged to the federal award program did not directly relate to COVID-19. We also noted an instance in which sufficient documentation to determine whether costs were directly related to COVID-19 were not retained. We also noted, the budget submitted to Oregon Health Authority grant #165657 included a provision for a 15 percent indirect cost rate for the funding which resulted in indirect costs being charged to the federal award. Effect: The effect is non-compliance with the federal award allowable cost compliance requirement. Questioned Costs: We noted aggregate known and likely questioned costs totaling $25,629. Context: Not applicable. Repeat Finding: No. Recommendation: We recommend management review its internal controls in place with respect to the federal award allowable cost compliance requirement and ensure internal controls designed and implemented incorporate all required elements in order to comply with the federal award allowable cost compliance requirement in the future. See details at Findings 2020-003 and 2020-004. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2020-005 Federal Program: Coronavirus Relief Fund (Assistance Listing # 21.019) Pass-through Agency: Oregon Health Authority Type of Finding: Instance of material non-compliance Compliance Requirements: Allowable costs Criteria: The U.S. Treasury Guidance and agreements related to the Coronavirus Relief Fund federal award stipulate that recipients may not charge indirect costs to the federal award. Further, costs charged to the federal award must establish a direct connection between the cost and COVID-19 related expenses. Condition: During our testing of allowable costs we noted indirect costs were charged to the federal award resulting in known questioned costs. We also noted instances of unallowable costs charged to the federal award in our testing of a sample of non-payroll disbursement transactions resulting in known and projected likely questioned costs. The aggregate questioned costs are in excess of the reportable threshold of $25,000. See details at Findings 2020-003 and 2020-004. Cause: There was an instance in which costs charged to the federal award program did not directly relate to COVID-19. We also noted an instance in which sufficient documentation to determine whether costs were directly related to COVID-19 were not retained. We also noted, the budget submitted to Oregon Health Authority grant #165657 included a provision for a 15 percent indirect cost rate for the funding which resulted in indirect costs being charged to the federal award. Effect: The effect is non-compliance with the federal award allowable cost compliance requirement. Questioned Costs: We noted aggregate known and likely questioned costs totaling $25,629. Context: Not applicable. Repeat Finding: No. Recommendation: We recommend management review its internal controls in place with respect to the federal award allowable cost compliance requirement and ensure internal controls designed and implemented incorporate all required elements in order to comply with the federal award allowable cost compliance requirement in the future. See details at Findings 2020-003 and 2020-004. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Finding 2020-005 Corrective action planned: As with Finding 2020-004, effective for the 2021 grant period, new grant agreements are reviewed by both the Accounting Manager, Kayla Haas, and Operations Director, Michelle Cady, to ensure a thorough understanding of all funding sources, guidelines and restrictions. Since the change in accounting staff in 2020, expense-related documents, including invoices and credit card receipts, are retained as either a paper or digital file by the Accounting Manager, Kayla Haas. With our renewed understanding of the process for Federal awards, expenses for which documentation cannot be obtained will be excluded from allocations. Person(s) responsible: Kayla Haas, Accounting Manager and Michelle Cady, Operations Director Anticipated date of completion: January 1, 2021
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