EIN: 943157181
UEI: EQKZLCJHJ6H4
Audited by: Badawi & Associates, CPAs
Oversight agency: 20 [Department of Transportation]
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 27, 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 August 27, 2025 (366 days ago).
What is a management decision? →C/CAG was unable to provide proof that it performed a suspension and debarment check on one of two vendors tested. C/CAG did not have evidence of a SAM.gov check on the vendor, or a timely certification from that vendor, or a clause or condition in the contract with that vendor asserting they were not suspended or debarred. Cause: The vendor had been selected for an earlier similar non-Federally-funded project, and the new amended contract did not include the suspension/debarment clause as required by C/CAG’s policy. Effect: One vendor of two tested vendors did not have sufficient evidence that they were not debarred or suspended from participating in Federal award activities.
Show full finding ▾Hide full finding ▴Criteria: Per 2 CFR 200.214, when an entity enters into a covered transaction using federal awards with a vendor, the entity must verify that the vendor is not debarred, suspended, or otherwise excluded from receiving or participating in Federal award. The entity can do this by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that entity; or (c) Adding a clause or condition to the covered transaction Condition: C/CAG was unable to provide proof that it performed a suspension and debarment check on one of two vendors tested. C/CAG did not have evidence of a SAM.gov check on the vendor, or a timely certification from that vendor, or a clause or condition in the contract with that vendor asserting they were not suspended or debarred. Cause: The vendor had been selected for an earlier similar non-Federally-funded project, and the new amended contract did not include the suspension/debarment clause as required by C/CAG’s policy. Effect: One vendor of two tested vendors did not have sufficient evidence that they were not debarred or suspended from participating in Federal award activities.
The following corrective actions have either been implemented or will be implemented to prevent recurrence: 1. Audit Documentation: For the identified contract, C/CAG obtained and affidavit from the vendor affirming their compliance with suspension and debarment requirements at the time of contract. C/CAG also confirmed that the consultant is currently not on the suspension and debarment list. This documentation has been shared with the auditors and added to the project file. 2. Quality Assurance: Staff confirmed that the C/CAG’s other federally funded contracts included the required suspension and debarment requirements. 3. Staff Training: All staff members that work or might work on federally funded activities have completed training on federal procurement requirements, including guidance on suspension and debarment protocols. This training references the necessity of conducting SAM.gov checks and obtaining certifications for all federalized contracts. The specific training was: "Navigating the Uniform Guidance: Procurement Standards," and it was conducted on December 18, 2024. The provider of the training was “Federal Grants Training.” Ten C/CAG staff attended the training, including staff in the following positions: Executive Director, Deputy Director, Stormwater Program Director, Transportation Systems Coordinator, Senior Program Specialist, and Program Specialist. Copied of the completion certificates are available upon request. To ensure ongoing compliance, all future staff working on federally funded activities will also complete training on relevant federal requirements as part of their onboarding or ongoing professional development. 4. Contract Template and Procurement Policy Update: C/CAG is in the process of updating its standard contract template and the Procurement Policy to include suspension and debarment language for all contracts, regardless of funding source. This proactive measure ensures compliance across all contracts, even if funding transitions from non-federal to federal sources. Starting in February 2025, all relevant new contracts will have suspension and debarment language. The new contract template is expected to take effect beginning in April of 2025, and all contracts signed from that time onward will use the updated template. Furthermore, C/CAG will continue to review and update its contracts and policies regularly to ensure compliance with evolving regulations and standards. 5. Verification Procedures: Moving forward, C/CAG will: o Require vendors to provide a certification of compliance with suspension and debarment requirements before executing any agreement. o Conduct SAM.gov checks for all federally funded contracts.
FAC accepted this audit on March 27, 2024 — management decision was due September 27, 2024.
Communication with the subrecipient includes the grant name and total funds committed to the subrecipient, but it does not disclose the portion that is federal funds, the federal awarding agency, or the assistance listing number and title. Cause: Grant agreements with the subrecipient have not historically included this information and templates were used from prior years to prepare the latest agreements. Effect: The subrecipient was not aware that their award included federal funds, and so did not include it on their Schedule of Expenditures of Federal Awards. Management's Response: The identified deficiency relates to the Safe Routes to School (SRTS) funds (OBAG 2 funds) passed through via agreement with the San Mateo County Office of Education (SMCOE). As noted by the auditor, the agreement describes the funding source with the same language previously used in prior grant agreements. Specifically, on page 26, the existing grant agreement states: “C/CAG and SMCOE have a joint interest in ensuring that schools and community agencies effectively implement programs that enable them to use the Federal Surface Transportation Program and Congestion Mitigation & Air Quality Improvement (STP/CMAQ) Program funds productively on behalf of students and the community.” To improve the communication of the nature of the federal funding and associated requirements, C/CAG will ensure that future federal pass-through grant agreements include the following information and language: (1) The specific portion of funding that is federal funds, the Federal Awarding Agency, full funding amount and applicable Federal Project Number, listing number and title. (2) A portion of the funds included are federal funds, and the recipient is responsible for compliance with all relevant Federal requirements, including, but not limited to § 200.501 Audit requirements and 2 CFR § 200.332 Requirements for pass-through entities.
Show full finding ▾Hide full finding ▴Criteria: Per 2 CFR § 200.332(a)(1), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and include federal award identifying information such as the total amount of federal funds committed to the subrecipient by the pass-through entity, name of the federal awarding agency, and assistance listing number and title. Condition: Communication with the subrecipient includes the grant name and total funds committed to the subrecipient, but it does not disclose the portion that is federal funds, the federal awarding agency, or the assistance listing number and title. Cause: Grant agreements with the subrecipient have not historically included this information and templates were used from prior years to prepare the latest agreements. Effect: The subrecipient was not aware that their award included federal funds, and so did not include it on their Schedule of Expenditures of Federal Awards. Management's Response: The identified deficiency relates to the Safe Routes to School (SRTS) funds (OBAG 2 funds) passed through via agreement with the San Mateo County Office of Education (SMCOE). As noted by the auditor, the agreement describes the funding source with the same language previously used in prior grant agreements. Specifically, on page 26, the existing grant agreement states: “C/CAG and SMCOE have a joint interest in ensuring that schools and community agencies effectively implement programs that enable them to use the Federal Surface Transportation Program and Congestion Mitigation & Air Quality Improvement (STP/CMAQ) Program funds productively on behalf of students and the community.” To improve the communication of the nature of the federal funding and associated requirements, C/CAG will ensure that future federal pass-through grant agreements include the following information and language: (1) The specific portion of funding that is federal funds, the Federal Awarding Agency, full funding amount and applicable Federal Project Number, listing number and title. (2) A portion of the funds included are federal funds, and the recipient is responsible for compliance with all relevant Federal requirements, including, but not limited to § 200.501 Audit requirements and 2 CFR § 200.332 Requirements for pass-through entities.
To improve the communication of the nature of the federal funding and associated requirements, C/CAG will ensure that future federal pass-through grant agreements include the following information and language: (1) The specific portion of funding that is federal funds, the Federal Awarding Agency, full funding amount and applicable Federal Project Number, listing number and title. (2) A portion of the funds included are federal funds, and the recipient is responsible for compliance with all relevant Federal requirements, including, but not limited to § 200.501 Audit requirements and 2 CFR § 200.332 Requirements for pass-through entities.
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