Audit 368984

FY End
2024-12-31
Total Expended
$1.02M
Findings
1
Programs
1
Year: 2024 Accepted: 2025-09-30
Auditor: Sax LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
1156637 2024-001 Material Weakness Yes I

Programs

ALN Program Spent Major Findings
59.059 Congressional Grants $1.02M Yes 1

Contacts

Name Title Type
P5NGR6DB51L4 Thomas Grech Auditee
7188988500 David Ashenfarb Auditor
No contacts on file

Notes to SEFA

The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal grant activity of the Organization under programs of the federal government for the year ended December 31, 2024. The information in this schedule is presented in accordance with requirements of the Title 2 U.S. Code of Federal Regulations (“CFR”) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Because the schedule presents only a selected portion of the operations of the Organization, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Organization.
Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available.
There were no amounts provided to subrecipients from federal awards received during the year ended December 31, 2024.
The Organization has elected not to use the 10-percent de minimis cost rate allowed under the Uniform Guidance

Finding Details

Finding No. 2024-001: Procurement Policy Program: AL# 59.059 – Congressional Grants Federal Grantor: U.S. Small Business Administration Criteria – Non-Federal entities must maintain documented procurement procedures that conform to applicable Federal statutes and the procurement standards identified in the Uniform Guidance, including thresholds, procurement methods, standards of conduct, and contract provisions. Citation – 2 CFR 200.319 & 2 CFR 200.320 Condition – The Organization has adopted both a grant-specific procurement policy and entity-wide procurement procedures included in its overall financial policy manual. However, neither policy is fully compliant with the federal procurement requirements. The following outlines the specific deficiencies in the policies: 1. Standard of Conduct for Conflicts of Interest (§200.318(c)): The policies do not contain written standards of conduct covering personal and organizational conflicts of interest in procurement. 2. Full and Open Competition (§200.319): While the policy in the financial manual requires three bids for purchases of $20,000 and greater, there is no overarching requirement that all procurements be conducted to provide full and open competition. 3. Procurement Methods (§200.320): The policies do not address all five procurement methods (micro-purchases, small purchases, sealed bids, competitive proposals, noncompetitive proposals). Additionally, micro-purchase and small purchase thresholds are not aligned with Uniform Guidance (the financial manual sets approval thresholds at $250 and $20,000 but does not incorporate the federal $10,000 micro-purchase threshold or $250,000 simplified acquisition threshold) 4. Noncompetitive Proposals (§200.320(f)): The policies do not identify circumstances where noncompetitive (sole-source) procurements are allowable or require documentation of justification Cause – The Organization’s procurement policies were originally designed around internal approval structures. Upon receiving federal funds for the first time in 2024, a grant specific policy was implemented to meet the grant requirements but neither policy was updated to reflect the detailed procurement requirements under Uniform Guidance. Effect – Since the procurement policies are not fully compliant with federal requirements, there is increased risk that procurements made under federal awards may not be conducted in an appropriate manner. If there were additional contracts with federal funds, this could result in potential questioned costs or disallowed expenditures. Questioned Costs – None. The finding is about deficiencies in written policies and procedures (compliance framework), not about an actual procurement transaction that violated the rules.