EIN: 941191246
UEI: UN8AK4MQK3F1
Audited by: Clark Nuber, PS
Oversight agency: 19 [Department of State]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 20, 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 August 20, 2026 (13 days ago).
What is a management decision? →FAC accepted this audit on February 2, 2025 — management decision was due August 2, 2025.
FAC accepted this audit on June 27, 2024 — management decision was due December 27, 2024.
FAC accepted this audit on January 12, 2023 — management decision was due July 12, 2023.
FAC accepted this audit on February 13, 2022 — management decision was due August 13, 2022.
FAC accepted this audit on February 16, 2021 — management decision was due August 16, 2021.
Significant deficiency in internal controls over compliance and compliance with procurement. Federal Agency: United States Agency for International Development Assistance Listing Numbers: 98.001 Award Numbers: AID-0AA-A-10-00045, award period, September 30, 2010 through April 30, 2020 AID-497-A-16-00002; award period, March 14, 2016 through September 30, 2021 720-383-18-CA-00001; award period, November 21, 2017 through December 20, 2020 Federal Agency: United States Department of State Assistance Listing Number: 19.700 Award Number: SLMAQM19CA2284; award period, September 28, 2019 through September 28, 2022 Criteria Procurement requirements contained in Title 2 US Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements, Section 200.319 and 200.320, requires a non-Federal entity to conduct all procurement transactions in a manner providing full and open competition consistent with the standards. Procurement by noncompetitive proposals is allowed only when one or more of the following circumstances apply: (1) The item is available only from a single source; (2) The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation; (3) the Federal awarding agency or passthrough entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or (4) after solicitation of a number of sources, competition is determined inadequate. Condition/Context/Questioned Costs Our audit testing of 61 procurement transactions included 11 procurements from three countries that did not include adequate justification for a noncompetitive procurement process that complies with 2 CFR 200 standards or were based on past experience with the vendor selected. The supporting documents provided for these payments included detail of the procurement decision and qualifications of the vendor; however, the documentation was not consistent with the four criteria specified for noncompetitive procurements in 2 CFR 200. Procurements were charged to the following awards and totaled: award AID-0AA-A-10-00045, $11,532; award AID-497-A-16-00002, $11,499; award 720-383-18-CA-00001, $1,691; and award SLMAQM19CA2284, $3,275. The payments totaling $27,997 are questioned costs as they were not supported by adequate documentation of the noncompetitive procurement. Cause The Foundation did not consistently comply with the procurement policies in place in each of its country offices. Effect The effect is that certain procurements were made in various country offices following a noncompetitive process that were not adequately documented. Repeat Finding Not applicable, as Finding 2020-003 is not a repeat finding. Recommendation We recommend that management continue to train personnel in each of its country offices to ensure that noncompetitive procurement processes be implemented only when one or more of the four circumstances specified in 2 CFR 200, Subpart D - Post Federal Award Requirements, Procurement Standards is present and are fully documented to justify a noncompetitive procurement process. Views of Responsible Officials Management agrees with the finding and has provided the accompanying corrective action plan.
Show full finding ▾Hide full finding ▴Significant deficiency in internal controls over compliance and compliance with procurement. Federal Agency: United States Agency for International Development Assistance Listing Numbers: 98.001 Award Numbers: AID-0AA-A-10-00045, award period, September 30, 2010 through April 30, 2020 AID-497-A-16-00002; award period, March 14, 2016 through September 30, 2021 720-383-18-CA-00001; award period, November 21, 2017 through December 20, 2020 Federal Agency: United States Department of State Assistance Listing Number: 19.700 Award Number: SLMAQM19CA2284; award period, September 28, 2019 through September 28, 2022 Criteria Procurement requirements contained in Title 2 US Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements, Section 200.319 and 200.320, requires a non-Federal entity to conduct all procurement transactions in a manner providing full and open competition consistent with the standards. Procurement by noncompetitive proposals is allowed only when one or more of the following circumstances apply: (1) The item is available only from a single source; (2) The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation; (3) the Federal awarding agency or passthrough entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or (4) after solicitation of a number of sources, competition is determined inadequate. Condition/Context/Questioned Costs Our audit testing of 61 procurement transactions included 11 procurements from three countries that did not include adequate justification for a noncompetitive procurement process that complies with 2 CFR 200 standards or were based on past experience with the vendor selected. The supporting documents provided for these payments included detail of the procurement decision and qualifications of the vendor; however, the documentation was not consistent with the four criteria specified for noncompetitive procurements in 2 CFR 200. Procurements were charged to the following awards and totaled: award AID-0AA-A-10-00045, $11,532; award AID-497-A-16-00002, $11,499; award 720-383-18-CA-00001, $1,691; and award SLMAQM19CA2284, $3,275. The payments totaling $27,997 are questioned costs as they were not supported by adequate documentation of the noncompetitive procurement. Cause The Foundation did not consistently comply with the procurement policies in place in each of its country offices. Effect The effect is that certain procurements were made in various country offices following a noncompetitive process that were not adequately documented. Repeat Finding Not applicable, as Finding 2020-003 is not a repeat finding. Recommendation We recommend that management continue to train personnel in each of its country offices to ensure that noncompetitive procurement processes be implemented only when one or more of the four circumstances specified in 2 CFR 200, Subpart D - Post Federal Award Requirements, Procurement Standards is present and are fully documented to justify a noncompetitive procurement process. Views of Responsible Officials Management agrees with the finding and has provided the accompanying corrective action plan.
Management Response: We agree with the finding and provide below the corrective action plan. Corrective action plan: - We have already implemented a training program and a new system which will prevent these procurement documentation errors from reoccurring. The items mentioned in this finding predate the implementation of the new system and the training program. - In February 2020 we revised the criteria for the noncompetitive procurements and our rules for selecting preferred vendor were modified. - A refresher course on procurement best practices was implemented in May 2020. We will continue to provide procurement training to TAF staff. - A training session conducted by the Internal Auditor on Common Internal Audit findings related to Procurement and Payments was held in May 2020. - During FY20 we rolled out a new procurement management system (PROMS) in 6 field offices. This new system has built in controls which ensure TAF staff comply with the procurement policy. - Further planned actions - We will complete the roll out of PROMS to the remaining 12 country and 2 US offices. - We will conduct additional training for country office and US staff. Anticipated completion date: September 2021 Name(s) of the contact person(s) responsible for corrective action: Sadia Mansoor (Finance)
FAC accepted this audit on February 3, 2020 — management decision was due August 3, 2020.
FAC accepted this audit on February 2, 2019 — management decision was due August 2, 2019.
FAC accepted this audit on January 22, 2018 — management decision was due July 22, 2018.
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FAC accepted this audit on February 14, 2017 — management decision was due August 14, 2017.
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