EIN: 942800985
UEI: EUCKVXCFH2B6
Audited by: Fechter and Company, Certified Public Accountants
Oversight agency: 16 [Department of Justice]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 23, 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 23, 2026 (101 days from today).
What is a management decision? →The SEFA submitted for the audit included incorrect ALNs for certain federal programs which misidentified a Type A program and omitted a major program. Cause: The errors appear to have resulted from inadequate procedures to verify ALNs against federal award documentation during SEFA preparation. Effect: Incorrect ALNs may result in inaccurate identification of federal programs and increase the risk of misidentification in major program determination, potentially affecting audit scope and compliance conclusions. Recommendation: Management should implement procedures to verify that ALNs reported on the SEFA agree to authoritative federal award documentation prior to finalization. Management’s Response and Corrective Action Plan is found on page 28-29.
Show full finding ▾Hide full finding ▴Finding 2025-001 – Accuracy of Schedule of Expenditures of Federal Awards (SEFA) Compliance Requirement: Reporting Internal Control Deficiency: Significant Deficiency - Insufficient review over SEFA preparation Compliance Finding: SEFA reported incorrect Assistance Listing Numbers (ALNs) Questioned Costs: None Criteria: Per 2 CFR 200.510(b), auditees must prepare a SEFA that accurately identifies federal programs by the correct ALN. Condition: The SEFA submitted for the audit included incorrect ALNs for certain federal programs which misidentified a Type A program and omitted a major program. Cause: The errors appear to have resulted from inadequate procedures to verify ALNs against federal award documentation during SEFA preparation. Effect: Incorrect ALNs may result in inaccurate identification of federal programs and increase the risk of misidentification in major program determination, potentially affecting audit scope and compliance conclusions. Recommendation: Management should implement procedures to verify that ALNs reported on the SEFA agree to authoritative federal award documentation prior to finalization. Management’s Response and Corrective Action Plan is found on page 28-29.
Finding 2025-001 – Accuracy of Schedule of Expenditures of Federal Awards (SEFA) The ALN numbers identified as incorrect were on 16.588 & 16.575 under the Violence Against Women Formula Grant. These two numbers were inadvertently transposed during preparation of the SEFA. Out of the 20 ALN numbers reported, only these two were inaccurate. All expenditures reported on the SEFA were based on actual expenditures incurred consistent with prior guidance provided by the auditor. During the previous audit cycle, VALOR’s accountant sought clarification regarding whether expenditures should be reported based on actual expenditures or reimbursement amounts and was instructed to use actual expenditures incurred. In accordance with 2 CFR 200.510(b), auditees must prepare a SEFA that accurately identifies programs by the correct ALN and reports expenditures based on actual amounts expended from federal awards. Except for the inadvertent transposition of the two ALN numbers noted above, the SEFA was prepared in compliance with these requirements. As a corrective action, beginning with the next SEFA report for the 2025-2026 fiscal year, the SEFA will be prepared by the Senior Accountant, Karen Sayers, and reviewed by both the Director of Operations, Rosemary Gonzales, and the organization’s CPA, Kim Jones, prior to submission to verify the accuracy of all ALN numbers and reported amounts.
During our testing of subrecipient monitoring and federal reporting, we noted that subrecipient agreements did not include several elements required under 2 CFR § 200.332(b), (c), and (e)–(i). Specifically, the agreements reviewed were missing one or more of the following required components: • Federal award identification information, including unique entity identifier (UEI), Federal Award Identification Number (FAIN), ALN, award date, and other required identifiers. • Required access-to-records language granting the pass-through entity, auditors, and federal agencies the right to access pertinent records. • Subaward-level closeout requirements, including timelines and documentation expectations. In addition, during compliance testing we noted that the subrecipient did not include the pass-through funds received in its own SEFA, resulting in incomplete federal expenditure reporting. Cause: The deficiencies appear to result from the absence of a standardized subaward agreement template and insufficient review procedures to ensure all Uniform Guidance elements are included. The subrecipient’s SEFA omission appears to stem from a lack of communication and monitoring regarding reporting requirements. Effect: Incomplete subaward agreements increase the risk that subrecipients may not understand federal requirements, may apply incorrect cost principles, or may fail to comply with federal terms. Missing SEFA reporting by the subrecipient results in inaccurate federal expenditure reporting and may affect federal oversight, risk assessments, and audit coverage.Recommendation: Management should implement a standardized subaward agreement template that incorporates all elements required under 2 CFR § 200.332. If any of the required elements are missing, adding a short federal award information/Uniform Guidance appendix and an explicit records-access and closeout article would bring the contracts into compliance. Management should also strengthen monitoring procedures to ensure subrecipients understand and comply with SEFA reporting requirements, including verifying that pass-through funds are properly reported. Management’s Response and Corrective Action Plan is found on page 28-29.
Show full finding ▾Hide full finding ▴Finding 2025-002 – Incomplete Subrecipient Agreements and Inaccurate Subrecipient SEFA Reporting Federal Program: Violence Against Women Formula Grants Assistance Listing Number: 16.588 Compliance Requirement: Subrecipient Monitoring Internal Control Deficiency: Material Weakness - Insufficient controls over subaward agreement content and subrecipient reporting oversight Compliance Finding: Subaward agreements missing required elements; subrecipient failed to report pass-through funds on its SEFA Questioned Costs: None Criteria: Under 2 CFR § 200.332, pass-through entities must ensure that all subaward agreements contain specific federal award information, monitoring expectations, and required terms and conditions. Subrecipients must report federal expenditures on their SEFA in accordance with 2 CFR § 200.510(b). Condition: During our testing of subrecipient monitoring and federal reporting, we noted that subrecipient agreements did not include several elements required under 2 CFR § 200.332(b), (c), and (e)–(i). Specifically, the agreements reviewed were missing one or more of the following required components: • Federal award identification information, including unique entity identifier (UEI), Federal Award Identification Number (FAIN), ALN, award date, and other required identifiers. • Required access-to-records language granting the pass-through entity, auditors, and federal agencies the right to access pertinent records. • Subaward-level closeout requirements, including timelines and documentation expectations. In addition, during compliance testing we noted that the subrecipient did not include the pass-through funds received in its own SEFA, resulting in incomplete federal expenditure reporting. Cause: The deficiencies appear to result from the absence of a standardized subaward agreement template and insufficient review procedures to ensure all Uniform Guidance elements are included. The subrecipient’s SEFA omission appears to stem from a lack of communication and monitoring regarding reporting requirements. Effect: Incomplete subaward agreements increase the risk that subrecipients may not understand federal requirements, may apply incorrect cost principles, or may fail to comply with federal terms. Missing SEFA reporting by the subrecipient results in inaccurate federal expenditure reporting and may affect federal oversight, risk assessments, and audit coverage.Recommendation: Management should implement a standardized subaward agreement template that incorporates all elements required under 2 CFR § 200.332. If any of the required elements are missing, adding a short federal award information/Uniform Guidance appendix and an explicit records-access and closeout article would bring the contracts into compliance. Management should also strengthen monitoring procedures to ensure subrecipients understand and comply with SEFA reporting requirements, including verifying that pass-through funds are properly reported. Management’s Response and Corrective Action Plan is found on page 28-29.
Finding 2025-002 – Incomplete Subrecipient Agreements and Inaccurate Subrecipient SEFA Reporting Subrecipient agreements were executed based on California’s State Administrator of federal funds (CalOES) requirements applicable to second-tier subawards. Based on guidance provided during Federal Grants Advanced Training and the 2025 CalOES Subrecipient Handbook (page 65), entities receiving pass-through funding from the state are required to follow CalOES second-tier subaward requirements. Accordingly, VALOR’s agreements include the elements required for second-tier subawards. Elements of a Second-Tier Subaward (From the 2025 CalOES Subrecipient Handbook) The following elements must be included in a Second-Tier Subaward: • Name of the Subrecipient Organization and the participating agency/organization, • The titles and contact information for the individuals that will serve as the primary contacts,• The timeframe of the agreement (this must cover the Grant Subaward performance period), • The roles and responsibilities (as they relate to the specific Grant Subaward) of the Subrecipient Organization and the participating agency/organization, • Specific information concerning all non-fiscal resources shared between the Subrecipient Organization and the participating agency/organization, • Reporting requirements necessary for the Subrecipient Organization to meet Cal OES reporting requirements, • Signatures of the chief executive or designee of the Subrecipient Organization and the participating agency/organization, including the dates of those signatures, and • Specific information concerning the transfer of any Grant Subaward funds from the Subrecipient Organization to the participating agency/organization. At a minimum, this information must include the total amount of Grant Subaward funds that will be transferred, the process for transferring the Grant Subaward funds (e.g., monthly invoices, payment based on deliverables), what the Grant Subaward funds will be used for, and any match contribution provided by the participating agency/organization. Any funds included in the Second-Tier Subaward must be clearly designated (not itemized) in the Grant Subaward Budget Pages (Cal OES Form 2-106a or b). Additionally, second tier subrecipients are prohibited from charging indirect costs; therefore, indirect cost provisions were not included in the agreements. Based on the above, management believes the subrecipient agreements substantially complied with applicable CalOES requirements. Any omissions identified were administrative in nature and did not impact program performance, allowability of costs, or oversight of subrecipient activities. To strengthen internal controls and ensure full compliance with all applicable grant requirements, beginning January 1, 2027, VALOR’s Director of Operations, Rosemary Gonzales, will include all required elements identified in the finding in future subrecipient agreements. In addition, VALOR will review subrecipient Single Audit reports to verify that applicable grant funding is properly reported on the SEFA. VALOR will also notify subrecipients of the requirement to include these amounts in their future SEFA reporting. Contracts for the current year, 2026, have already been signed.
FAC accepted this audit on April 29, 2025 — management decision was due October 29, 2025.
FAC accepted this audit on May 31, 2024 — management decision was due December 1, 2024.
FAC accepted this audit on May 29, 2023 — management decision was due November 29, 2023.
FAC accepted this audit on August 14, 2022 — management decision was due February 14, 2023.
FAC accepted this audit on October 13, 2021 — management decision was due April 13, 2022.
FAC accepted this audit on May 28, 2019 — management decision was due November 28, 2019.
FAC accepted this audit on August 5, 2018 — management decision was due February 5, 2019.
FAC accepted this audit on June 22, 2017 — management decision was due December 22, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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