EIN: 954191698
UEI: RZ4NKR9DQN84
Single Audit filed under EIN: 995127205
That audit also covers EIN: 560942853
Audited by: BDO USA, P.C.
Cognizant agency: 93 [Department of Health and Human Services]
View federal awards & risk assessment →
Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 21, 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 February 21, 2026 (192 days ago).
What is a management decision? →FAC accepted this audit on October 7, 2024 — management decision was due April 7, 2025.
The Foundation has documented expenditure policies and procedures. However, as identified below, the review and approval process did not operate as designed. The Foundation’s policies are designed to ensure expenses are reviewed and approved timely to ensure proper recording in the books and records. During our indirect cost pool testing of 40 (forty) samples, one (1) of the 40 transactions tested was recorded at the pro-forma invoice amount. Based on the final authorized invoice, a variance of approximately $1,420 was identified. As this is an indirect allocated pool, this impacts all awards within the major program. Cause: The Foundation has documented expenditure policies and procedures regarding the timely processing and approval of expenditures incurred. However, as identified above, the review and approval process for the samples identified above did not operate as designed. Effect: The lack of adherence to established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of award agreements which could ultimately lead to disallowed costs for the major program. Questioned Costs: $1,420 of known costs. Context: This is a condition identified per review of the Foundation’s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of this finding is detailed in the condition section above. Samples were selected using a non-statistical method. Recommendation: BDO recommends the Foundation adhere to its documented policies and procedures regarding authorization and timely approval and recording of expenditures. Views of Responsible Officials: Foundation management agrees with the finding and recommendations set forth within and will provide additional training to staff members to ensure compliance with established policies and procedures. Refer to management’s corrective action plan for additional information.
Show full finding ▾Hide full finding ▴2023-002 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Identification of the Major Federal Program: United States Department of Health and Human Services Assistance Listing Number: 93.067 Assistance Listing Name: Global AIDS Award Number(s): All awards presented on the SEFA for the year ended December 31, 2023. Criteria or Specific Requirement: In accordance with §200.302 Financial Management, a non- federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Additionally, §200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Foundation has documented expenditure policies and procedures. However, as identified below, the review and approval process did not operate as designed. The Foundation’s policies are designed to ensure expenses are reviewed and approved timely to ensure proper recording in the books and records. During our indirect cost pool testing of 40 (forty) samples, one (1) of the 40 transactions tested was recorded at the pro-forma invoice amount. Based on the final authorized invoice, a variance of approximately $1,420 was identified. As this is an indirect allocated pool, this impacts all awards within the major program. Cause: The Foundation has documented expenditure policies and procedures regarding the timely processing and approval of expenditures incurred. However, as identified above, the review and approval process for the samples identified above did not operate as designed. Effect: The lack of adherence to established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of award agreements which could ultimately lead to disallowed costs for the major program. Questioned Costs: $1,420 of known costs. Context: This is a condition identified per review of the Foundation’s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of this finding is detailed in the condition section above. Samples were selected using a non-statistical method. Recommendation: BDO recommends the Foundation adhere to its documented policies and procedures regarding authorization and timely approval and recording of expenditures. Views of Responsible Officials: Foundation management agrees with the finding and recommendations set forth within and will provide additional training to staff members to ensure compliance with established policies and procedures. Refer to management’s corrective action plan for additional information.
2023-002 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Contact: Sam Kimball Title: Corporate Controller Phone Number: 202-296-9165 Estimated Completion Date – May 2024 Corrective Action: Management acknowledges the finding and notes that there are policies and procedures in place at the Foundation designed to mitigate this risk, as evidenced by the auditors noting no issues in the overwhelming majority of samples selected. In this specific instance, the Foundation overpaid the final invoiced amount and was issued a refund for the difference from the vendor during 2024.
During our period of performance completeness testing, BDO identified $74,584 of costs that were recorded after the period of performance. This was identified as part of our sampling analytics. Cause: The Foundation management has procedures in place to review expenditures to determine the appropriate period of performance; however, those procedures were not performed to a level of detail at the international office to identify expenses that were incurred outside the period of performance. Effect: The lack of adherence to the established internal control procedures around the period of performance of the award resulted in noncompliance and questioned costs that need to be returned to the Centers for Disease Control. Continued noncompliance with federal statutes,regulations, and the provisions of the award agreements could ultimately result in additional disallowed costs for the major program. Questioned Costs: $74,584 of known costs. Context: BDO’s testing of the period of performance compliance requirement was performed by examining whether the expenses selected as part of our testing of allowable costs and allowable activities were incurred within the proper period of performance of the award. Our subsequent testing of additional detailed expenditures identified no further samples that were recorded incorrectly. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance in order to prevent the charging of costs outside of the period of performance of the award. Furthermore, we believe an option would be to close the project within the accounting system, and create a separate project to accumulate any costs incurred after the end of the period of performance. The costs incurred subsequent to the end of the period of performance should go through the review and approval of individuals at the Foundation’s Headquarters. Views of Responsible Officials: The Foundation management agrees with the finding and recommendations set forth within and will provide training to appropriate staff responsible for monitoring expenses on the program. Refer to management’s corrective action plan for additional information.
Show full finding ▾Hide full finding ▴2023-003 Internal Controls over Compliance and Compliance with the Period of Performance Compliance Requirement Identification of the Major Federal Program: United States Department of Health and Human Services Assistance Listing Number: 93.067 Assistance Listing Name: Global AIDS Award Number: NU2GGH002010 Award Period: September 30, 2021 to March 31, 2023 Criteria or Specific Requirement: In accordance with §200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by §200.344(b). When used in connection with a non-Federal entity’s utilization of funds under a Federal award, “obligations” means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in §200.71. Condition: During our period of performance completeness testing, BDO identified $74,584 of costs that were recorded after the period of performance. This was identified as part of our sampling analytics. Cause: The Foundation management has procedures in place to review expenditures to determine the appropriate period of performance; however, those procedures were not performed to a level of detail at the international office to identify expenses that were incurred outside the period of performance. Effect: The lack of adherence to the established internal control procedures around the period of performance of the award resulted in noncompliance and questioned costs that need to be returned to the Centers for Disease Control. Continued noncompliance with federal statutes,regulations, and the provisions of the award agreements could ultimately result in additional disallowed costs for the major program. Questioned Costs: $74,584 of known costs. Context: BDO’s testing of the period of performance compliance requirement was performed by examining whether the expenses selected as part of our testing of allowable costs and allowable activities were incurred within the proper period of performance of the award. Our subsequent testing of additional detailed expenditures identified no further samples that were recorded incorrectly. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance in order to prevent the charging of costs outside of the period of performance of the award. Furthermore, we believe an option would be to close the project within the accounting system, and create a separate project to accumulate any costs incurred after the end of the period of performance. The costs incurred subsequent to the end of the period of performance should go through the review and approval of individuals at the Foundation’s Headquarters. Views of Responsible Officials: The Foundation management agrees with the finding and recommendations set forth within and will provide training to appropriate staff responsible for monitoring expenses on the program. Refer to management’s corrective action plan for additional information.
2023-003 Internal Controls over Compliance and Compliance with the Period of Performance Compliance Requirement Contact: Sam Kimball Title: Corporate Controller Phone Number: 202-296-9165 Estimated Completion Date – October 2024 Corrective Action: Management acknowledges the finding and notes that the costs identified related to a project that ended in March 2023. On October 1, 2023, the Foundation implemented a new ERP system that includes better controls around the period of performance, preventing transactions from being entered after the award end date and/or close out date, reducing the risk of recording transactions to projects outside of the stated period of performance. Therefore, management does not anticipate similar issues around period of performance going forward, as the risks are additionally addressed with the new system design.
FAC accepted this audit on July 11, 2023 — management decision was due January 11, 2024.
Management is required to ensure property records are maintained to ensure adequate recordkeeping for equipment acquired with U.S. government funding including both additions to, and disposals of, equipment. During our testing to ensure management provided an accurate listing of equipment held to perform our equipment completeness testing for which a sample would be selected, BDO identified the following matters in related to the equipment population provided by management: We examined the 2022 inventory records designated to the major federal program; however, matters were noted as listed below: Direct Award Number Errors on Year-end Inventory Listing 72062122C00001 One asset was not included in the December 31, 2022 equipment listing that should have been included. 5U62PS123541 One asset selected for testing was unable to be located. AID-621-A-16-00004 One asset selected for testing was unable to be located. Direct Award Number Assets Correctly Disposed or Transferred As Per U.S. Government Regulations - Not Included on the Equipment Disposals Listing 5U62PS123541 One asset AID-621-A-16-00004 Two assets AID617A1500010 Three assets Cause: The Foundation?s country offices did not fully comply with established internal procedures related to equipment tracking requirements for equipment procured with U.S. Government funds. This resulted in both incorrect year-end inventory listings, but also incomplete transfer and disposal listing. Effect: Failure to properly track and maintain equipment purchased with U.S. Government funds could ultimately lead to loss of equipment procured with U.S. funds, reduced funding, or cancellation of a federal award. Questioned Costs: None. Context: This is a condition identified per examination of the Foundation?s compliance with the equipment provisions within the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Recommendation: We recommend management perform trainings to address the deficiencies identified above given the equipment inventory process did not ensure a complete and accurate disposal population or equipment listing as of December 31, 2022. We also recommend management establish a periodic review of the documentation that is maintained to comply with ?200.313, Equipment, to ensure that the documentation encompasses all the required elements of the regulation, including sale or transfer requirements. Views of Responsible Officials: The Foundation?s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴Identification of the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Direct Award Number(s) Award Period 72062122C00001 November 9, 2021 through November, 8, 2026s 5U62PS123541 February 23, 2004 through February 22, 2012 AID-621-A-16-00004 October 1, 2016 through December 31, 2021 AID-617-A-15-00010 November 15, 2015 through September 30, 2023 Criteria or Specific Requirement: In accordance with ?200.313(d), Equipment, a non-federal entity must establish and adhere to procedures for managing equipment, whether acquired in whole or in part under a Federal award, until disposition takes place. The non-federal entity must meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal Award Identification Number), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award number under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: Management is required to ensure property records are maintained to ensure adequate recordkeeping for equipment acquired with U.S. government funding including both additions to, and disposals of, equipment. During our testing to ensure management provided an accurate listing of equipment held to perform our equipment completeness testing for which a sample would be selected, BDO identified the following matters in related to the equipment population provided by management: We examined the 2022 inventory records designated to the major federal program; however, matters were noted as listed below: Direct Award Number Errors on Year-end Inventory Listing 72062122C00001 One asset was not included in the December 31, 2022 equipment listing that should have been included. 5U62PS123541 One asset selected for testing was unable to be located. AID-621-A-16-00004 One asset selected for testing was unable to be located. Direct Award Number Assets Correctly Disposed or Transferred As Per U.S. Government Regulations - Not Included on the Equipment Disposals Listing 5U62PS123541 One asset AID-621-A-16-00004 Two assets AID617A1500010 Three assets Cause: The Foundation?s country offices did not fully comply with established internal procedures related to equipment tracking requirements for equipment procured with U.S. Government funds. This resulted in both incorrect year-end inventory listings, but also incomplete transfer and disposal listing. Effect: Failure to properly track and maintain equipment purchased with U.S. Government funds could ultimately lead to loss of equipment procured with U.S. funds, reduced funding, or cancellation of a federal award. Questioned Costs: None. Context: This is a condition identified per examination of the Foundation?s compliance with the equipment provisions within the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Recommendation: We recommend management perform trainings to address the deficiencies identified above given the equipment inventory process did not ensure a complete and accurate disposal population or equipment listing as of December 31, 2022. We also recommend management establish a periodic review of the documentation that is maintained to comply with ?200.313, Equipment, to ensure that the documentation encompasses all the required elements of the regulation, including sale or transfer requirements. Views of Responsible Officials: The Foundation?s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-003 Equipment Real Property Management Contact: Evelyn Nkatha Title: Associate Director of Regional Operations Phone Number: 202-296-9165 Estimated Completion Date: June 2023 Corrective Action: During the first half of 2023, the Foundation implemented a new equipment inventory tracking system called Asset Tiger, which will allow for better tracking of all equipment and vehicles within the country offices. Staff in each country were trained on the new system and will conduct regular reviews on the inventory in compliance with 2 C.F.R. ?200.313.
The Foundation has documented payroll policies and procedures. However, as identified below, the review and approval process did not operate as designed. ? BDO tested 40 payroll expenditures identifying two errors. In both instances, the expenditures did not have evidence of compliance with documented policies. For one sample, an employee?s contract was not authorized by the employee via certified approval email or manual signature. For the second sample, an employee?s monthly timesheet for the year ended December 31, 2022 was not properly approved by their assigned manager. Cause: Foundation personnel did not comply with documented policies and procedures surrounding the payroll process. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Questioned Costs: None. Context: This is a condition identified per review of the Foundation?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. Samples were selected using a non-statistical method. Recommendation: BDO recommends that the Foundation adhere to its documented policies and procedures regarding proper review and approval of expenditures. Views of Responsible Officials: The Foundation agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴2022-004 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Identification of the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Direct Award Number Award Period AID-674-A-16-00005 June 20, 2016 through June 18, 2024 Criteria or Specific Requirement: In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Additionally, ?200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Foundation has documented payroll policies and procedures. However, as identified below, the review and approval process did not operate as designed. ? BDO tested 40 payroll expenditures identifying two errors. In both instances, the expenditures did not have evidence of compliance with documented policies. For one sample, an employee?s contract was not authorized by the employee via certified approval email or manual signature. For the second sample, an employee?s monthly timesheet for the year ended December 31, 2022 was not properly approved by their assigned manager. Cause: Foundation personnel did not comply with documented policies and procedures surrounding the payroll process. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Questioned Costs: None. Context: This is a condition identified per review of the Foundation?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. Samples were selected using a non-statistical method. Recommendation: BDO recommends that the Foundation adhere to its documented policies and procedures regarding proper review and approval of expenditures. Views of Responsible Officials: The Foundation agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-004 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Contact: Sherian Abramaitys-yi Title: Chief Human Resources Officer Phone Number: 202-296-9165 Estimated Completion Date: December 2023 Corrective Action: Management acknowledges the finding and notes that policies and procedures in place at the Foundation are designed to mitigate these risks, as evidenced by the auditors noting no issues in the overwhelming majority of samples selected. The Foundation will remind staff, particularly those in HR, as well as supervisors, of the importance of a complete personnel record for each employee, as well as the importance of reviewing and approving timesheets in a timely manner.
The Foundation?s policies are designed to ensure expenses are accurate, current and reported within the financial results timely for grant reporting. For one non-payroll expenditure sample of 40 non-payroll expenditure samples tested, the expenditure was not recorded timely resulting in the expenditure being recorded in the incorrect audit period on the SEFA. In this instance, the expenditure was incurred during the grant?s overall period of performance. The expenditure for AID-617-A-15-00010 totaled $513. Cause: Foundation management has procedures in place to review expenditures to ensure timely review and reporting; however, those procedures performed by management were not performed to a level of detail to ensure the error identified was reported timely on the SEFA. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Questioned Costs: None Context: This is a condition identified per review of the Foundation?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of this finding is detailed in the condition section above. Samples were selected using a non-statistical method. Recommendation: BDO recommends that the Foundation adhere to its documented policies and procedures regarding authorization and timely approval and reporting of expenditures to ensure compliance with ?200.302 Financial Management. Views of Responsible Officials: Foundation?s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Show full finding ▾Hide full finding ▴2022-005 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Identification of the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Direct Award Number Award Period AID-617-A-15-00010 November 15, 2015 through September 30, 2023 Criteria or Specific Requirement: In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in ?200.327 Financial Reporting and ?200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Additionally, ?200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Foundation?s policies are designed to ensure expenses are accurate, current and reported within the financial results timely for grant reporting. For one non-payroll expenditure sample of 40 non-payroll expenditure samples tested, the expenditure was not recorded timely resulting in the expenditure being recorded in the incorrect audit period on the SEFA. In this instance, the expenditure was incurred during the grant?s overall period of performance. The expenditure for AID-617-A-15-00010 totaled $513. Cause: Foundation management has procedures in place to review expenditures to ensure timely review and reporting; however, those procedures performed by management were not performed to a level of detail to ensure the error identified was reported timely on the SEFA. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Questioned Costs: None Context: This is a condition identified per review of the Foundation?s compliance with allocability and allowability provisions of the Uniform Guidance. The prevalence of this finding is detailed in the condition section above. Samples were selected using a non-statistical method. Recommendation: BDO recommends that the Foundation adhere to its documented policies and procedures regarding authorization and timely approval and reporting of expenditures to ensure compliance with ?200.302 Financial Management. Views of Responsible Officials: Foundation?s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-005 Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Contact: Sam Kimball Title: Corporate Controller Phone Number: 202-296-9165 Estimated Completion Date: December 2023 Corrective Action: During 2023, the Foundation is implementing a new ERP system with an anticipated go-live date of October 1, 2023. This new system will allow for better structure around the period-end accrual process and allow the Foundation to more clearly and effectively accrue for costs in the period of performance. Additionally, the Foundation will hold informal training sessions to remind staff of the importance of recording expenditures in the appropriate period and the policies around year-end accruals for costs that have not yet been invoiced.
FAC accepted this audit on July 12, 2022 — management decision was due January 12, 2023.
During our testing of compliance, we identified the following matter: The Foundation?s procurement policy, which complies with Federal procurement regulations, applies to procurements in excess of the Foundation?s micro-purchase threshold, which is $10,000. Country Directors may elect to set a lower purchase threshold for requiring competition based on the local economy and environment. For one sample, the procurement contract was originally valued at the micro-purchase threshold with no competition required. However, the procurement contract was later amended with a total procurement contract value in excess of $25,000. The Foundation staff did not identify that an amendment to the procurement agreement would exceed the threshold requiring procurement competition within the proper threshold. Questioned Costs: No known questioned costs were identified. Context: This is a condition based on testing of the Foundation?s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: The Foundation?s personnel did not comply with the Foundation?s documented policies and procedures over the procurement process. Effect: Failure to comply with documented procurement procedures in accordance with the Foundation?s documented procurement policies and procedures could result in the procurement being disallowed. Repeat Finding: This is not a repeat finding. Recommendation: We recommend management provide new learning opportunities over the procurement tracking method by clarifying established policies and procedures to create more consistency across all of the Foundation?s international office locations. Views of Responsible Officials: The Foundation?s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instance of noncompliance identified and lapse in prescribed internal controls.
Show full finding ▾Hide full finding ▴In accordance with ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in a manner providing full and open competition consistent in accordance with ?200.319 and must be performed using the appropriate procurement method as outlined in ?200.320. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of compliance, we identified the following matter: The Foundation?s procurement policy, which complies with Federal procurement regulations, applies to procurements in excess of the Foundation?s micro-purchase threshold, which is $10,000. Country Directors may elect to set a lower purchase threshold for requiring competition based on the local economy and environment. For one sample, the procurement contract was originally valued at the micro-purchase threshold with no competition required. However, the procurement contract was later amended with a total procurement contract value in excess of $25,000. The Foundation staff did not identify that an amendment to the procurement agreement would exceed the threshold requiring procurement competition within the proper threshold. Questioned Costs: No known questioned costs were identified. Context: This is a condition based on testing of the Foundation?s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: The Foundation?s personnel did not comply with the Foundation?s documented policies and procedures over the procurement process. Effect: Failure to comply with documented procurement procedures in accordance with the Foundation?s documented procurement policies and procedures could result in the procurement being disallowed. Repeat Finding: This is not a repeat finding. Recommendation: We recommend management provide new learning opportunities over the procurement tracking method by clarifying established policies and procedures to create more consistency across all of the Foundation?s international office locations. Views of Responsible Officials: The Foundation?s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instance of noncompliance identified and lapse in prescribed internal controls.
The Foundation will perform trainings with all of its international offices that include information on purchase thresholds, the competition requirements for each threshold, and the impact of amendments on procurement thresholds.
FAC accepted this audit on June 21, 2021 — management decision was due December 21, 2021.
FAC accepted this audit on July 1, 2020 — management decision was due January 1, 2021.
To test equipment compliance, we selected 40 samples of equipment purchased with federal funds from management's equipment listing. We obtained and examined the property records for those samples. Our testing identified the following instances of noncompliance that resulted in the lack of adherence to internal control policies and procedures around management of equipment. Management is required to perform a physical inventory of equipment and match the physical inventory with the equipment records. We examined the 2019 physical inventory records of equipment for the awards listed below; however, in each of the five instances, the equipment selected had been previously legally transferred to a 3rd party, but not removed from the Foundation's 2019 physical inventory listing. Therefore, the physical inventory was not properly reconciled to the equipment listing nor the transfer accurately recorded within the equipment listing. Award Number Instances U62/CCU123541 3 1U2GGH000422 2 Cause: The Foundation's country offices did not comply with established internal procedures in relation to equipment record maintenance requirements for equipment procured with Federal funds nor related requirements to have an accurate physical inventory performed. Effect: Failure to properly track and maintain equipment purchased with U.S. Government funds could ultimately lead to loss of equipment procured with Federal funds, reduced funding, or cancellation of a federal award. Questioned Costs: None. Context: This is a condition identified per examination of the Foundation's compliance with the equipment provisions within the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Recommendation: We recommend management perform a training to address the deficiencies identified above given the equipment inventory process was not performed in a manner that complied with documented policies and procedures. We also recommend management establish a periodic review of the documentation that is maintained to comply with ?200.313, Equipment, to ensure that the documentation encompasses all the required elements of the regulation, including sale or transfer requirements.
Show full finding ▾Hide full finding ▴2019-001 Equipment Real Property Management Information on the Federal Program: United States Department of Health and Human Services CFDA Number: 93.067 CFDA Name: Global AIDS Grant Award Numbers under the Uniform Guidance Requirements: Award Number Award Period U62/CCU123541 02/23/2004 - 02/22/2012 1U2GGH000422 09/30/2011 - 09/28/2018 Criteria or Specific Requirement: In accordance with ?200.313(d), Equipment, a non-federal entity must establish and adhere to procedures for managing equipment, whether acquired in whole or in part under a Federal award, until disposition takes place. The non-federal entity must meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal Award Identification Number), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award number under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition: To test equipment compliance, we selected 40 samples of equipment purchased with federal funds from management's equipment listing. We obtained and examined the property records for those samples. Our testing identified the following instances of noncompliance that resulted in the lack of adherence to internal control policies and procedures around management of equipment. Management is required to perform a physical inventory of equipment and match the physical inventory with the equipment records. We examined the 2019 physical inventory records of equipment for the awards listed below; however, in each of the five instances, the equipment selected had been previously legally transferred to a 3rd party, but not removed from the Foundation's 2019 physical inventory listing. Therefore, the physical inventory was not properly reconciled to the equipment listing nor the transfer accurately recorded within the equipment listing. Award Number Instances U62/CCU123541 3 1U2GGH000422 2 Cause: The Foundation's country offices did not comply with established internal procedures in relation to equipment record maintenance requirements for equipment procured with Federal funds nor related requirements to have an accurate physical inventory performed. Effect: Failure to properly track and maintain equipment purchased with U.S. Government funds could ultimately lead to loss of equipment procured with Federal funds, reduced funding, or cancellation of a federal award. Questioned Costs: None. Context: This is a condition identified per examination of the Foundation's compliance with the equipment provisions within the Uniform Guidance. The prevalence of these findings is detailed in the condition section above. The sample was selected using a non-statistical method. Recommendation: We recommend management perform a training to address the deficiencies identified above given the equipment inventory process was not performed in a manner that complied with documented policies and procedures. We also recommend management establish a periodic review of the documentation that is maintained to comply with ?200.313, Equipment, to ensure that the documentation encompasses all the required elements of the regulation, including sale or transfer requirements.
Views of Responsible Officials: The Foundation's management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls. NOTE - Although the specific finding pertained to awards that have already expired, the Foundation's management will implement the corrective action plan on all active awards, including the expired awards' follow-on award (1 NU2GGH001945).
FAC accepted this audit on June 15, 2019 — management decision was due December 15, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
FAC accepted this audit on June 4, 2018 — management decision was due December 4, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on June 6, 2017 — management decision was due December 6, 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.
Browse other Single Audit organizations in District of Columbia →
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and filing records.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
