Finding 1187326 (2024-004)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2024
Accepted
2026-03-26

AI Summary

  • Core Issue: The Single Audit reporting package was submitted late for the third consecutive year, violating 2 CFR §200.512(a).
  • Impacted Requirements: Noncompliance with federal submission deadlines could lead to STDC being classified as a high-risk auditee, affecting federal funding and oversight.
  • Recommended Follow-Up: Implement a formal audit preparation timeline with monthly progress checks by leadership to ensure timely submission of future audit reports.

Finding Text

Finding 2024-004 | Untimely Submission of Single Audit Reporting Package Noncompliance | Repeat Finding | Third Consecutive Year (2022-001, 2023-006, 2024-004) Program: Multiple Programs — Entity-Wide Compliance Requirement: 2 CFR §200.512(a) — Federal Audit Clearinghouse Submission Required Deadline: June 30, 2025 (9 months after September 30, 2024 fiscal year end) Questioned Costs: $0 Known / $0 Likely Repeat Finding: Yes — Repeat of Finding 2023-006 and Finding 2022-001 (third consecutive year) Condition: The Single Audit reporting package for the fiscal year ended September 30, 2024, was not submitted to the Federal Audit Clearinghouse (FAC) by the required deadline of June 30, 2025, under 2 CFR §200.512(a). The package was submitted approximately nine months after the required deadline. Criteria: 2 CFR §200.512(a) requires non-federal entities that expend $750,000 or more in federal awards during a fiscal year to submit their single audit reporting package to the FAC within the earlier of 30 calendar days after receipt of the auditor's reports, or nine months after the end of the audit period. For the fiscal year ended September 30, 2024, the required submission deadline was June 30, 2025. Cause: The late submission is attributable to the cumulative effect of significant operational disruptions beginning in FY2022. On November 3, 2023, STDC suffered a ransomware attack that impacted its accounting system. Database recovery was not completed until January 2024, after which staff were required to perform extensive data entry and catch-up work for all reporting periods affected by the system outage. The transition to the AccuFund accounting system and the subsequent ransomware recovery created cascading delays in the preparation of financial records sufficient for audit, which in turn delayed the completion and submission of the FY2024 single audit reporting package. This finding represents the third consecutive year in which the single audit was submitted late, following Finding 2022-001 and Finding 2023-006. Effect: The late submission constitutes noncompliance with 2 CFR §200.512(a). As a result of prior year late submissions, STDC has been designated as a high-risk auditee for the current audit year. Continued late submissions may result in additional oversight requirements, conditions on federal awards, or other adverse actions by federal oversight agencies. Recommendation: STDC should establish a formal audit preparation timeline at the beginning of each fiscal year, with milestone dates for completion of the trial balance, resolution of audit adjustments, and delivery of final financial records to the auditor. The Executive Director and Finance Director should monitor progress against this timeline monthly and report status to the Board of Directors. STDC should target submission of the FY2025 single audit reporting package by June 30, 2026.

Corrective Action Plan

Finding 2024-004 | Untimely Submission of Single Audit Reporting Package Noncompliance | Repeat Finding | Third Consecutive Year (2022-001, 2023-006, 2024-004) | 2 CFR §200.512(a) Finding Number: 2024-004 Planned Completion Date: June 30, 2026 (FY2025 single audit submitted to FAC on or before this date) Responsible Official(s): Josafat Saldivar, Finance Director (primary); Juan E. Rodriguez, Executive Director (oversight and Board reporting) Agency Response: STDC acknowledges the finding and concurs that the Single Audit reporting package for the fiscal year ended September 30, 2024 was not submitted to the Federal Audit Clearinghouse (FAC) by the required deadline of June 30, 2025, under 2 CFR §200.512(a). STDC recognizes that this represents the third consecutive year in which the single audit has been submitted late, following Finding 2022-001 and Finding 2023-006, and takes seriously the compliance obligation and the operational risks associated with continued noncompliance with the submission deadline. The late submissions across FY2022, FY2023, and FY2024 are the direct result of a series of compounding operational disruptions originating with the Council's transition to a new accounting system in January 2022, further complicated by a ransomware attack in November 2023. Management provides the following chronological context to demonstrate the depth and duration of the disruptions that collectively prevented timely audit completion across three consecutive fiscal years: Accounting System Transition (2021-2022): In March 2021, following a six-month procurement process, STDC contracted with Lance, Soil & Lunghard, LLP (LSL, LLP), an authorized AccuFund reseller, to implement AccuFund as its new accounting platform. The go-live date was delayed from October 1, 2021 to January 1, 2022 to allow the Board of Directors to approve related payroll and operational changes. When the system launched on January 1, 2022, critical components — including the fringe benefit and indirect cost allocation pools, timesheet approvals, budget, requisitions, funding reports, and travel modules — had not been configured. Transaction history and beginning balances were imported incorrectly. Work with LSL, LLP concluded in September 2022 without resolution of these deficiencies. AccuFund Remediation (2022-2023): Beginning in October 2022, STDC engaged AccuFund directly to identify and correct the configuration deficiencies. In February 2023, AccuFund assigned a Senior Consultant to the engagement. Between March and October 2023, the Consultant worked with STDC to configure the fringe benefit and indirect cost pools, reconfigure payroll, and correct the transaction history and trial balances that had been incorrectly imported during the original implementation. This remediation work was still ongoing at the time of the ransomware attack. Ransomware Attack and Recovery (November 2023 – September 2024): On November 4, 2023, STDC suffered a ransomware attack that compromised the SQL database housing all AccuFund financial data. Following recovery efforts, STDC migrated to AccuFund Anywhere, a cloud-hosted version of the platform, and regained system access in late December 2023. Between January and March 2024, staff manually re-entered transaction data that had been processed offline during the system outage. Between April and September 2024, STDC continued working with the AccuFund Senior Consultant to finalize system configurations and correct remaining beginning balance and transaction history issues — many of which dated back to the original 2022 implementation errors. Sequential Audit Completion (2024-2026): The cumulative effect of these disruptions required STDC to complete three fiscal year audits in sequence rather than on schedule. The FY2022 audit was completed in December 2024 and submitted to the FAC, with a revised submission in January 2025 following an HHSC review that identified a misclassification of assistance listing number balances. The FY2023 audit was completed and submitted to the FAC in July 2025. Work on the FY2024 audit commenced in August 2025 and is being finalized for Board approval on March 26, 2026, with FAC submission to follow immediately. The FY2025 fiscal year ended September 30, 2025, and STDC is actively preparing for that audit with a target FAC submission date of June 30, 2026. Management acknowledges that the cumulative nature of these disruptions resulted in a multi-year audit backlog that could not be resolved within the annual submission deadlines. STDC is committed to breaking this cycle. With the AccuFund system now stable, the cloud migration complete, and three years of corrected financial records in place, STDC has the accounting infrastructure necessary to support timely audit completion going forward. The corrective actions below reflect the specific steps being taken to achieve the June 30, 2026 FY2025 submission target and to prevent recurrence in future years. Note: Because the FY2025 fiscal year ended September 30, 2025 and the FY2024 audit is being finalized concurrently, several of the steps below are already underway as of the date of this report (March 2026). Target dates reflect the current accelerated timeline required to achieve FAC submission by June 30, 2026. Corrective Actions to Be Implemented: Action 1 (Target: In progress — April 15, 2026): FY2025 Audit Preparation Timeline — A compressed audit preparation schedule has been established for the FY2025 audit (year ended September 30, 2025) with the following key milestones: final trial balance and year-end reconciliations delivered to the auditor by April 15, 2026; draft financial statements completed by the auditor by May 31, 2026; management review and final adjustments completed by June 10, 2026; final audit report issued by the auditor and reviewed and approved by the STDC Board of Directors by June 25, 2026; and submission of the complete reporting package to the Federal Audit Clearinghouse by June 30, 2026. Action 2 (Target: In progress — March 31, 2026): Auditor Engagement — FY2025 — De La Garza CPA Firm, P.C. has been engaged for the FY2025 audit. Fieldwork scheduling and document request lists are being coordinated to ensure the auditor can begin and complete work within the compressed timeline. STDC will provide all requested documentation on a priority basis to avoid delays in fieldwork. Action 3 (Targets: March 26, 2026; April 22, 2026; June 25, 2026): Board Reporting — The Executive Director will present audit status to the Board of Directors at the March 26, 2026 board meeting and at each subsequent board meeting. The June 30, 2026 FAC submission target will be tracked as a standing Board-level performance objective with final review and approval of the FY2025 audit report by the Board of Directors targeted for June 25, 2026. Action 4 (Target: July 31, 2026): FY2026 Audit Preparation Timeline — Upon submission of the FY2025 audit, STDC will immediately follow its formal written audit preparation timeline for the FY2026 audit (year ended September 30, 2026), with milestone dates beginning at fiscal year-end and targeting FAC submission by June 30, 2027. The timeline will be modeled on the Single Audit Submission Timeline Protocol adopted under Findings 2022-001 and 2023-006 and approved by the Executive Director. Monitoring and Evaluation: The Finance Director will maintain a running audit preparation status log updated weekly through June 30, 2026, and monthly thereafter. The Executive Director will report audit status to the Board of Directors at each meeting. The immediate target outcome is submission of the FY2025 single audit reporting package to the Federal Audit Clearinghouse on or before June 30, 2026. Achievement of this milestone will demonstrate STDC's return to timely compliance and is expected to support removal of the high-risk auditee designation in the FY2025 audit cycle.

Categories

Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1187291 2024-001
    Material Weakness Repeat
  • 1187292 2024-001
    Material Weakness Repeat
  • 1187293 2024-002
    Material Weakness Repeat
  • 1187294 2024-002
    Material Weakness Repeat
  • 1187295 2024-002
    Material Weakness Repeat
  • 1187296 2024-002
    Material Weakness Repeat
  • 1187297 2024-003
    Material Weakness Repeat
  • 1187298 2024-003
    Material Weakness Repeat
  • 1187299 2024-004
    Material Weakness Repeat
  • 1187300 2024-004
    Material Weakness Repeat
  • 1187301 2024-004
    Material Weakness Repeat
  • 1187302 2024-004
    Material Weakness Repeat
  • 1187303 2024-004
    Material Weakness Repeat
  • 1187304 2024-004
    Material Weakness Repeat
  • 1187305 2024-004
    Material Weakness Repeat
  • 1187306 2024-004
    Material Weakness Repeat
  • 1187307 2024-004
    Material Weakness Repeat
  • 1187308 2024-004
    Material Weakness Repeat
  • 1187309 2024-004
    Material Weakness Repeat
  • 1187310 2024-004
    Material Weakness Repeat
  • 1187311 2024-004
    Material Weakness Repeat
  • 1187312 2024-004
    Material Weakness Repeat
  • 1187313 2024-004
    Material Weakness Repeat
  • 1187314 2024-004
    Material Weakness Repeat
  • 1187315 2024-004
    Material Weakness Repeat
  • 1187316 2024-004
    Material Weakness Repeat
  • 1187317 2024-004
    Material Weakness Repeat
  • 1187318 2024-004
    Material Weakness Repeat
  • 1187319 2024-004
    Material Weakness Repeat
  • 1187320 2024-004
    Material Weakness Repeat
  • 1187321 2024-004
    Material Weakness Repeat
  • 1187322 2024-004
    Material Weakness Repeat
  • 1187323 2024-004
    Material Weakness Repeat
  • 1187324 2024-004
    Material Weakness Repeat
  • 1187325 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.917 HIV CARE FORMULA GRANTS $1.51M
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $176,323
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $115,429
93.569 COMMUNITY SERVICES BLOCK GRANT $106,251
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $85,778
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $61,296
97.067 HOMELAND SECURITY GRANT PROGRAM $40,000
93.499 LOW INCOME HOUSEHOLD WATER ASSISTANCE PROGRAM $23,482
11.302 ECONOMIC DEVELOPMENT SUPPORT FOR PLANNING ORGANIZATIONS $22,014
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $16,074
93.324 STATE HEALTH INSURANCE ASSISTANCE PROGRAM $7,865
93.071 MEDICARE ENROLLMENT ASSISTANCE PROGRAM $5,779
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $4,422
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $4,318
93.791 MONEY FOLLOWS THE PERSON REBALANCING DEMONSTRATION $3,898
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $3,305
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $22
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $14