EIN: 943302410
UEI: GU69H9VJSSP1
Audited by: Aprio, LLP
Oversight agency: 66 [Environmental Protection Agency]
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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 August 12, 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 February 12, 2027 (163 days from today).
What is a management decision? →FAC accepted this audit on September 26, 2025 — management decision was due March 26, 2026.
FAC accepted this audit on October 1, 2024 — management decision was due April 1, 2025.
FAC accepted this audit on November 14, 2022 — management decision was due May 14, 2023.
The Corporation did not include $50,090 in expenditures related to the National Technical Assistance - Nuclear Closure Communities program, Assistance Listing Number 11.303, and $69,878 related to the Brownfields Training, Research, and Technical Assistance passed through Kansas State University, Assistance Listing Number 66.814, in the Schedule. Cause: The cooperative agreements were originally interpreted by management as a contractual relationship that did not meet the definition of a federal award. Effect or Potential Effect: This resulted in an understatement of expenditures reported on the Schedule. Auditor Non-Compliance Code: S - Internal Control Deficiencies Questioned Costs: N/A Reporting Views of Responsible Officials: See Corrective Action Plan. Context: Internal controls over compliance should include a process to monitor the complete recording of expenditures of federal awards. Recommendations: Perform a thorough review of any agreements or contracts with the federal government and pass-through agencies to determine if they are to be included in the Schedule. Auditor's Summary of the Auditee's Comments on the Findings and Recommendations: See Corrective Action Plan. Response: Agrees.
Show full finding ▾Hide full finding ▴Finding # 2021-001 Federal Grantor: U.S. Environmental Protection Agency AL # / Program : 66.814 - Brownfields Training, Research, and Technical Assistance Grants and Cooperative Agreements Type of Finding: Federal Award Finding Criteria: "In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) ?200.510(b), the auditee must prepare a schedule of expenditures of Federal awards (the Schedule) for the period covered by the auditee's financial statements which must include the total federal awards expended as determined in accordance with ?200.502. " Statement of Condition: The Corporation did not include $50,090 in expenditures related to the National Technical Assistance - Nuclear Closure Communities program, Assistance Listing Number 11.303, and $69,878 related to the Brownfields Training, Research, and Technical Assistance passed through Kansas State University, Assistance Listing Number 66.814, in the Schedule. Cause: The cooperative agreements were originally interpreted by management as a contractual relationship that did not meet the definition of a federal award. Effect or Potential Effect: This resulted in an understatement of expenditures reported on the Schedule. Auditor Non-Compliance Code: S - Internal Control Deficiencies Questioned Costs: N/A Reporting Views of Responsible Officials: See Corrective Action Plan. Context: Internal controls over compliance should include a process to monitor the complete recording of expenditures of federal awards. Recommendations: Perform a thorough review of any agreements or contracts with the federal government and pass-through agencies to determine if they are to be included in the Schedule. Auditor's Summary of the Auditee's Comments on the Findings and Recommendations: See Corrective Action Plan. Response: Agrees.
Finding 2021- 001 - Federal Funding Schedule - Significant Deficiency Corrective Action Plan: We have created an ultimate funding source spreadsheet tied to our chart of accounts. A report of aggregate funding by source will be produced at the end of each quarter to track our federal spending. Most importantly, we will produce this report at the end of the calendar year and present to our independent auditor as part of our audit materials. This report will also be a regular exhibit in our package to the Board of Directors. Person(s) Responsible Jean Hamerman, Executive Director Claire Weston, Programs and Operations Manager Noelle Folden-Mcdowell, Financial Controller Estimated Completion Date: December 31, 2022
The Corporation uses an excel spreadsheet to track federal awards invoicing. The process for billing fringe benefit costs and indirect administrative costs evolved over the term of the federal award cooperative agreement. The excel spreadsheet became an inadequate control for tracking federal awards invoiced. Cause: The Corporation identified direct and indirect costs that met the criteria for reimbursement in accordance with the cooperative agreement. These costs were identified by the Corporation months and years after the actual costs were incurred. The resulting adjustments to the excel spreadsheet used to track federal awards invoicing became error prone and overwhelming for management to maintain. Effect or Potential Effect: The Corporation may have overbilled the federal awards cooperative agreement over the duration of the cooperative agreement term. Auditor Non-Compliance Code: S - Internal Control Deficiencies Likely Questioned Costs: $60,788.56 Reporting Views of Responsible Officials: See Corrective Action Plan. Context: The supporting documentation maintained by the Corporation at the time of federal award billing was insufficient to meet the required criteria of the Uniform Guidance. Recommendations: The Corporation should establish an automated/integrated process for billing of federal awards and cooperative agreements that allows for the timely and accurate invoicing of costs to be reimbursed. The process should allow for the prevention and/or detection of duplicative or disallowed costs. Auditor's Summary of the Auditee's Comments on the Findings and Recommendations: See Corrective Action Plan. Response: Agrees.
Show full finding ▾Hide full finding ▴Finding # 2021-002 Federal Grantor: U.S. Environmental Protection Agency AL # / Program : 66.814 - Brownfields Training, Research, and Technical Assistance Grants and Cooperative Agreements Type of Finding: Federal Award Finding Criteria: 2 CFR section 200.303(a) states, ?a non-Federal entity must establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Statement of Condition: The Corporation uses an excel spreadsheet to track federal awards invoicing. The process for billing fringe benefit costs and indirect administrative costs evolved over the term of the federal award cooperative agreement. The excel spreadsheet became an inadequate control for tracking federal awards invoiced. Cause: The Corporation identified direct and indirect costs that met the criteria for reimbursement in accordance with the cooperative agreement. These costs were identified by the Corporation months and years after the actual costs were incurred. The resulting adjustments to the excel spreadsheet used to track federal awards invoicing became error prone and overwhelming for management to maintain. Effect or Potential Effect: The Corporation may have overbilled the federal awards cooperative agreement over the duration of the cooperative agreement term. Auditor Non-Compliance Code: S - Internal Control Deficiencies Likely Questioned Costs: $60,788.56 Reporting Views of Responsible Officials: See Corrective Action Plan. Context: The supporting documentation maintained by the Corporation at the time of federal award billing was insufficient to meet the required criteria of the Uniform Guidance. Recommendations: The Corporation should establish an automated/integrated process for billing of federal awards and cooperative agreements that allows for the timely and accurate invoicing of costs to be reimbursed. The process should allow for the prevention and/or detection of duplicative or disallowed costs. Auditor's Summary of the Auditee's Comments on the Findings and Recommendations: See Corrective Action Plan. Response: Agrees.
Finding 2021-002 - Insufficient Internal Controls - Significant Deficiency Corrective Action Plan: CCLR has implemented robust internal controls and protocols to address challenges and deficiencies stemming from unintentional clerical errors identified during this audit process and managing a multi-year grant. Issues addressed include cash versus accrual invoicing, ensuring calculations for fringe and indirect expenses are in compliance and instituting new checks and balances. These corrective actions are intended to address clerical errors. Changes in senior management may have played a significant part in earlier deficiencies, however, these new internal controls and protocols are intended to mitigate errors related to future personnel changes. We also recognized the need for a more competent and responsive controller, so we replaced our bookkeeper in February 2022 with someone more knowledgeable about our business. Other changes include: 1. Bill.com. We have moved our bill paying to Bill.com to consolidate and allow for better expense tracking and accountability. 2. Cash versus Accrual. We have created a new spreadsheet to track EPA expenses when we receive an invoice from a ?closed? month. Any time an expense from a closed month is added to Quickbooks (?QB?) it must also be added to this log, allowing us to properly reconcile each direct expense invoice and better reconcile our cash and accrual systems each month. 3. Formula verification. A calculation check has been created to ensure that the total amount invoiced to EPA aligns with the total direct expenses from QuickBooks + admin + fringe for the month in question. 4. Indirect costs. We have developed a formula with our outside auditor that we will apply to our administrative expenses each month to limit our indirect billing at 5%. 5. Training on TAB coding. We are training our staff and consultants will code timesheets and invoices. 6. PEX cards. We implemented PEX cards (prepaid cards that provide better control and visibility of employee-paid expenses and prevent back-billing) for staff and consultant expenses. 7. Accounting Manual. We are instituting an annual review and update of the Accounting Manual and Procedures that will be performed by the Controller, Programs and Operations Manager, and Executive Director. CCLR will meet with USEPA Administration expeditiously about these findings. CCLR will meet with USEPA Administration expeditiously about these findings. CCLR is prepared to reimburse the USEPA or take corrective actions to satisfy the USEPA. Person(s) Responsible Jean Hamerman, Executive Director Claire Weston, Programs and Operations Manager Noelle Folden-Mcdowell, Financial Controller Estimated Completion Date: December 31, 2022
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