EIN: 940382330
UEI: GSA_MIGRATION
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 29, 2021. 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 29, 2022 (1612 days ago).
What is a management decision? →2020-002 ? General ledger not updated for federal equipment disposal Cluster: Research & Development Sponsoring Agency: National Institutes of Health Award Name: Research Infrastructure Award Number: 1 C06 RR16226-01A1 CFDA Title: National Center for Research Resources CFDA Number: 93.389 Award Year: 5/1/2002 ? 4/30/2005 Criteria 2 CFR 200.313 (d)(1-2) indicates that a physical inventory of federal equipment must be taken and the results reconciled with property records at least once every two years. Additionally, accurate property records must be maintained which include various identifying information, such as the location, use and condition of the property and any ultimate disposition data, including the date of disposal and sale of the property. Condition In testing CHRCO?s conformity with the compliance requirements for equipment management, we selected 5 pieces of equipment from the detailed listing provided to physically inspect. Through our testing, we noted 1 piece of equipment out of the 5 selections made that was incorrectly included in the listing. This piece of equipment had been disposed of prior to the end of the fiscal year but was not updated in the equipment management system. Cause Management indicated they closed many labs during 2020 and missed transferring this asset write-off to accounting in a timely fashion in order to update the general ledger. Effect The listing of federally funded equipment was not complete and accurate. Questioned Costs None noted. Recommendation We recommend CHRCO review the policies and procedures around federal equipment management with its grant administrative unit, emphasizing the importance of timely communication of disposals and other changes to the equipment inventory listing to the appropriate personnel to ensure the listing is complete and accurate.
Show full finding ▾Hide full finding ▴2020-002 ? General ledger not updated for federal equipment disposal Cluster: Research & Development Sponsoring Agency: National Institutes of Health Award Name: Research Infrastructure Award Number: 1 C06 RR16226-01A1 CFDA Title: National Center for Research Resources CFDA Number: 93.389 Award Year: 5/1/2002 ? 4/30/2005 Criteria 2 CFR 200.313 (d)(1-2) indicates that a physical inventory of federal equipment must be taken and the results reconciled with property records at least once every two years. Additionally, accurate property records must be maintained which include various identifying information, such as the location, use and condition of the property and any ultimate disposition data, including the date of disposal and sale of the property. Condition In testing CHRCO?s conformity with the compliance requirements for equipment management, we selected 5 pieces of equipment from the detailed listing provided to physically inspect. Through our testing, we noted 1 piece of equipment out of the 5 selections made that was incorrectly included in the listing. This piece of equipment had been disposed of prior to the end of the fiscal year but was not updated in the equipment management system. Cause Management indicated they closed many labs during 2020 and missed transferring this asset write-off to accounting in a timely fashion in order to update the general ledger. Effect The listing of federally funded equipment was not complete and accurate. Questioned Costs None noted. Recommendation We recommend CHRCO review the policies and procedures around federal equipment management with its grant administrative unit, emphasizing the importance of timely communication of disposals and other changes to the equipment inventory listing to the appropriate personnel to ensure the listing is complete and accurate.
2020-002 ? General ledger not updated for federal equipment disposal CHRCO plans to strengthen the effectiveness of its controls in accordance with PWC?s recommendations through the following corrective action: 1) Description of Corrective Actions: CHRCO will review its policies and procedures related to federal equipment management with its administrative emphasizing importance of timely communication of disposals and other changes to the equipment inventory listing to the appropriate personnel to ensure the listing is complete and accurate. 2) Responsible Executive: MC Gaisbauer, Business and Integration Manager 3) Timeline for Completion. All activities will be concluded by September 30, 2021.
2020-003 ? Costs incorrectly allocated to award Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services ? Health Resources and Services Administration Award Name: Ryan White Title IV Women, Infants, Children, Youth and Affected Family Members AIDS Healthcare Award Number: H12HA2477 CFDA Title: Coordinated Services and Access to Research for Women, Infants, Children, and Youth CFDA Number: 93.153 Award Year: 2019-2020 Criteria 45 CFR 75.405, Allocable costs, notes that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost: is incurred specifically for the Federal award; benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods; and is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in this subpart. Condition In order to test CHRCO?s conformity with the compliance requirements for activities allowed/unallowed and allowable costs/costs principles, we selected a sample 60 transactions from the detailed listing provided for testing. Of these transactions, 5 related to transactions charged to the award, the source for which were corporate credit card reports for 2 employees and exceptions were noted related to 4 of the 5 selections, as follows: ? 1 selection was posted without being properly approved, in addition to being erroneously posted twice ($705) ? 1 selection did not have appropriate supporting documentation (i.e., receipt), however, based on an understanding of the nature of the cost, it was appropriate to charge to the award ? 2 selections were charged to the award in error ($4,546) Cause The credit card holders in these instances, did not allocate their monthly credit card charges to appropriate cost centers, as required by CHRCO?s policy, instead charging all costs to one cost center (i.e., the cost center associated with this award). CHRCO?s credit card policy was inadequate in that it was not clear the approver should require receipts for all material transactions, and seek concurrence from the Principal Investigator when involving grant funds. CHRCO?s mitigating control of the Principal Investigator review of the monthly financial reports failed to detect the errors due to small dollar values. . Effect Certain credit card charges were inappropriately charged to the award. Questioned Costs $5,251 of questioned costs were noted, related to 3 of the 4 exceptions, which CHRCO management has removed from the award. Recommendation We recommend that CHRCO review their policies and procedures related to credit card transactions, including, but not limited to, formalizing the review of credit card transactions at the grant level and enhancing the overall monthly credit card review and reconciliation process. Additionally, we recommend providing training to the principal investigators and other grant personnel focusing on the policies and procedures related to the appropriate allocation of credit card transactions, including emphasizing the importance of proper supporting documentation.
Show full finding ▾Hide full finding ▴2020-003 ? Costs incorrectly allocated to award Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services ? Health Resources and Services Administration Award Name: Ryan White Title IV Women, Infants, Children, Youth and Affected Family Members AIDS Healthcare Award Number: H12HA2477 CFDA Title: Coordinated Services and Access to Research for Women, Infants, Children, and Youth CFDA Number: 93.153 Award Year: 2019-2020 Criteria 45 CFR 75.405, Allocable costs, notes that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost: is incurred specifically for the Federal award; benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods; and is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in this subpart. Condition In order to test CHRCO?s conformity with the compliance requirements for activities allowed/unallowed and allowable costs/costs principles, we selected a sample 60 transactions from the detailed listing provided for testing. Of these transactions, 5 related to transactions charged to the award, the source for which were corporate credit card reports for 2 employees and exceptions were noted related to 4 of the 5 selections, as follows: ? 1 selection was posted without being properly approved, in addition to being erroneously posted twice ($705) ? 1 selection did not have appropriate supporting documentation (i.e., receipt), however, based on an understanding of the nature of the cost, it was appropriate to charge to the award ? 2 selections were charged to the award in error ($4,546) Cause The credit card holders in these instances, did not allocate their monthly credit card charges to appropriate cost centers, as required by CHRCO?s policy, instead charging all costs to one cost center (i.e., the cost center associated with this award). CHRCO?s credit card policy was inadequate in that it was not clear the approver should require receipts for all material transactions, and seek concurrence from the Principal Investigator when involving grant funds. CHRCO?s mitigating control of the Principal Investigator review of the monthly financial reports failed to detect the errors due to small dollar values. . Effect Certain credit card charges were inappropriately charged to the award. Questioned Costs $5,251 of questioned costs were noted, related to 3 of the 4 exceptions, which CHRCO management has removed from the award. Recommendation We recommend that CHRCO review their policies and procedures related to credit card transactions, including, but not limited to, formalizing the review of credit card transactions at the grant level and enhancing the overall monthly credit card review and reconciliation process. Additionally, we recommend providing training to the principal investigators and other grant personnel focusing on the policies and procedures related to the appropriate allocation of credit card transactions, including emphasizing the importance of proper supporting documentation.
2020-003 ? Costs incorrectly allocated to award CHRCO plans to strengthen the effectiveness of its controls in accordance with PWC?s recommendations through the following corrective action: 1) Description of Corrective Actions: CHRCO has discovered the inadequacies in the corporate credit card policies and procedures through its own management review in March 2020 and took immediate action beginning with training and communication and ending with the closure of the corporate credit care program in 2021. If the credit card program is reinstated, CHRCO will adopt stronger policies and procedures, including an approval routing path that includes the Principal Investigators. During this management review, we failed to detect that 2 corporate credit cards were inappropriately charged to federal awards. Upon discovery these errors in the audit, management has undertaken a full re-review of all corporate card credit charges during the federal disclosure period to ensure that we have no additional errors to remediate. This review is complicated due to the financial system conversion in 2017. To date, we have completed a substantial portion of the review have been able to determine that only 2 cardholders seem are at risk for undocumented or inappropriately allocated transactions during the disclosure period. The total credit charges for those individuals approximate $50,000, of which of this full amount may not be grant related. It is estimated the total number federal grants impact is five (5). We are in the process of finalizing the actual to federal grants and quantifying the questioned costs to disclose to the federal government. 2) Responsible Executive: MC Gaisbauer, Business and Integration Manager 3) Timeline for Completion. The review will be finalized and management will be present its finding to the federal government by December 31, 2021.
FAC accepted this audit on March 31, 2020 — management decision was due October 1, 2020.
In testing the Organization?s conformity with the compliance requirements around individual eligibility of patients to receive HIV healthcare under the award, we found 2 of our 6 selections out of a population of 40 did not have proper document retention for the period in order to validate the patients were appropriately eligible to receive treatment. Citation: 2 CFR 200.333 Criteria: Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Questioned Costs: None Cause: Approximately every six months, the clinic which obtains the eligibility documents and treats patients has a site visit by the Alameda County Public Health Office for eligibility. Once the clinic has passed this inspection, they purge all documents in which were viewed, regardless of how long the patient has been under care, causing some patient information to not be retained for our audit period. Effect: The Organization was unable to provide all required documentation to validate the patients should be receiving treatment. Recommendation: Management should implement a procedure in each affected clinic to ensure compliance with the institutional policy which requires all programs associated with Federal awards retain all required documentation for a minimum of three years from the time period required as noted above. Management?s Views and Corrective Action Plan: Management?s response is reported in ?Corrective Action Plans? included at the end of this report.
Show full finding ▾Hide full finding ▴2019-002 Eligibility Program: HIV Emergency Relief Project Grants CFDA Title: HIV Emergency Relief Project Grants CFDA Number: 93.914 Sponsoring Agency: Department of Health and Human Services Award Year: 2018 - 2019 Condition: In testing the Organization?s conformity with the compliance requirements around individual eligibility of patients to receive HIV healthcare under the award, we found 2 of our 6 selections out of a population of 40 did not have proper document retention for the period in order to validate the patients were appropriately eligible to receive treatment. Citation: 2 CFR 200.333 Criteria: Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Questioned Costs: None Cause: Approximately every six months, the clinic which obtains the eligibility documents and treats patients has a site visit by the Alameda County Public Health Office for eligibility. Once the clinic has passed this inspection, they purge all documents in which were viewed, regardless of how long the patient has been under care, causing some patient information to not be retained for our audit period. Effect: The Organization was unable to provide all required documentation to validate the patients should be receiving treatment. Recommendation: Management should implement a procedure in each affected clinic to ensure compliance with the institutional policy which requires all programs associated with Federal awards retain all required documentation for a minimum of three years from the time period required as noted above. Management?s Views and Corrective Action Plan: Management?s response is reported in ?Corrective Action Plans? included at the end of this report.
2019-002 Eligibility CHRCO plans to strengthen the effectiveness of its controls in accordance with PWC?s recommendations through the following corrective action: 1) Description of Corrective Actions: CHRCO will identify all clinics with eligibility requirements and work with the clinic department heads to develop a clinic procedure to implement SAAM Policies 30.01 ? 30.04 related to document retention. Once the procedure is developed, the clinic department head will train all clinic staff to ensure compliance with the retention policy. 2) Responsible Executive: MC Gaisbauer, Business and Integration Manager 3) Timeline for Completion. All activities will be concluded by June 2020.
FAC accepted this audit on June 9, 2019 — management decision was due December 9, 2019.
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2017-005
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Show full finding ▾Hide full finding ▴FAC accepted this audit on April 1, 2018 — management decision was due October 1, 2018.
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2016-002
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2016-003
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FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
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