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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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.
2023-003 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.
2023-002 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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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.
2023-003 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.