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Finding 2025-003 – Late Submission of Reporting Package and Data Collection Form Federal Reporting Requirement: Uniform Guidance – Subpart F Reporting Requirements Type of Finding: Significant Deficiency in Internal Control Over Compliance Noncompliance with Federal Reporting Requirements No Questioned Costs Criteria: Under 2 CFR § 200.512(a)(1), the audit, Data Collection Form, and reporting package must be submitted to the Federal Audit Clearinghouse within 30 calendar days after the auditee receives the auditor’s report or nine months after the end of the audit period, whichever is earlier. In addition, 2 CFR § 200.303 requires recipients and subrecipients to establish, document, and maintain effective internal control over Federal awards that provides reasonable assurance of compliance with applicable Federal statutes, regulations, and the terms and conditions of Federal awards. Recipients and subrecipients are also required to evaluate and monitor compliance and take prompt action when instances of noncompliance are identified. Condition: The Organization did not timely submit its reporting packages and Data Collection Forms for the two preceding audit periods. For the year ended December 31, 2023, the reporting package was due no later than September 30, 2024. The Organization submitted the reporting package to the Federal Audit Clearinghouse on March 15, 2025, 166 days after the required submission date. For the year ended December 31, 2024, the reporting package was due no later than September 30, 2025. The Organization submitted the reporting package to the Federal Audit Clearinghouse on March 13, 2026, 164 days after the required submission date. Accordingly, the Organization did not comply with the reporting deadlines prescribed by 2 CFR § 200.512(a). Cause: The Organization did not have sufficiently effective procedures in place to monitor the status and timely completion of the annual audit and related Federal Audit Clearinghouse submission. Delays in completing the annual audit, including delays associated with obtaining and providing information necessary for completion of the audit, contributed to the late submissions. Effect or Potential Effect: Failure to timely submit the audit, reporting package, and Data Collection Form constitutes noncompliance with the reporting requirements of 2 CFR § 200.512. Late submission delays the availability of required audit information to Federal agencies and pass-through entities and may affect the Organization’s ability to qualify as a low-risk auditee in future periods or otherwise result in increased Federal or pass-through entity oversight. Recommendation: We recommend that management maintain a formal compliance calendar identifying the applicable Federal Audit Clearinghouse submission deadline and assign responsibility for monitoring compliance with that deadline. Management should regularly monitor the status of the annual audit, timely provide requested information to the auditors, promptly address outstanding audit items, and communicate with the auditors throughout the audit process to facilitate completion of the audit and submission of the reporting package and Data Collection Form within the required timeframe. Views of Responsible Officials and Planned Corrective Action: Management has added the Federal Audit Clearinghouse submission deadline to its annual compliance calendar and assigned responsibility for monitoring the deadline to the Executive Director. Management will actively monitor the progress of the annual audit, timely respond to auditor requests, and communicate with the auditors regarding outstanding items that could delay completion of the audit. The Board will provide oversight of the process. Management intends for these procedures to facilitate timely completion of the annual audit and submission of the reporting package and Data Collection Form within the timeframe required by Uniform Guidance. Repeat Finding: Yes. This finding is a repeat of Finding 2024-006.