FAC Explorer

Audit 11626

FY End
2023-06-30
Total Expended
$2.12M
Findings
12
Programs
2
Organization: Asylum Access (CA)
Year: 2023 Accepted: 2024-01-16
Auditor: Gelman Rosenberg & Freedman

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
8589 2023-001 Significant Deficiency - I
8590 2023-001 Significant Deficiency - I
8591 2023-001 Significant Deficiency - I
8592 2023-002 Significant Deficiency - L
8593 2023-001 Significant Deficiency - I
8594 2023-002 Significant Deficiency - L
585031 2023-001 Significant Deficiency - I
585032 2023-001 Significant Deficiency - I
585033 2023-001 Significant Deficiency - I
585034 2023-002 Significant Deficiency - L
585035 2023-001 Significant Deficiency - I
585036 2023-002 Significant Deficiency - L

Programs

ALN Program Spent Major Findings
19.518 Overseas Refugee Assistance Programs for Western Hemisphere $1.25M Yes 2
19.511 Overseas Refugee Assistance Programs for East Asia $408,532 - 1

Contacts

Name Title Type
W3TKFGPT6T58 Rouba Anka Auditee
5108918799 Andreas Alexandrou Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: N Rate Explanation: Such expenditures are recognized based on the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. Asylum Access has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the Federal award activity of Asylum Access under programs of the Federal government for the year ended June 30, 2023. Information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule presents only a selected portion of the operations of Asylum Access; accordingly, it is not intended to and does not present the financial position, changes in net assets or cash flows of Asylum Access.
Title: Note 2. Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: N Rate Explanation: Such expenditures are recognized based on the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. Asylum Access has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized based on the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. Asylum Access has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance.

Finding Details

Finding 2023-001
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-001
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-001
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Information on the Federal Programs: Assistance Listing Number 19.518 Criteria: The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their firsttier subawards to meet the FFATA reporting requirements. Prime Awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Criteria (continued): CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant governmentwide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: Asylum Access has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: Asylum Access does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Context: Absent proper policies and procedures, Asylum Access is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Effect: Asylum Access did not comply with the requirements noted above. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where Asylum Access is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-001
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Information on the Federal Programs: Assistance Listing Number 19.518 Criteria: The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their firsttier subawards to meet the FFATA reporting requirements. Prime Awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Criteria (continued): CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant governmentwide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: Asylum Access has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: Asylum Access does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Context: Absent proper policies and procedures, Asylum Access is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Effect: Asylum Access did not comply with the requirements noted above. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where Asylum Access is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-001
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-001
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-001
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Information on the Federal Programs: Assistance Listing Number 19.518 Criteria: The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their firsttier subawards to meet the FFATA reporting requirements. Prime Awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Criteria (continued): CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant governmentwide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: Asylum Access has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: Asylum Access does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Context: Absent proper policies and procedures, Asylum Access is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Effect: Asylum Access did not comply with the requirements noted above. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where Asylum Access is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-001
Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Information on the Federal Programs: Assistance Listing Number 19.518 Criteria: The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their firsttier subawards to meet the FFATA reporting requirements. Prime Awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Criteria (continued): CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant governmentwide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: Asylum Access has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: Asylum Access does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Context: Absent proper policies and procedures, Asylum Access is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Effect: Asylum Access did not comply with the requirements noted above. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where Asylum Access is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.