Audit 304203

FY End
2022-12-31
Total Expended
$2.00M
Findings
6
Programs
1
Organization: Team Rubicon, Inc. (CA)
Year: 2022 Accepted: 2024-04-23

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
394233 2022-001 Material Weakness - P
394234 2022-002 Significant Deficiency - I
394235 2022-003 - - N
970675 2022-001 Material Weakness - P
970676 2022-002 Significant Deficiency - I
970677 2022-003 - - N

Programs

ALN Program Spent Major Findings
19.510 U.s. Refugee Admissions Program $2.00M Yes 3

Contacts

Name Title Type
ZYG9HSNJ41F1 Dane Barata Auditee
3106408787 Amy Eybsen Auditor
No contacts on file

Notes to SEFA

Title: 1. Basis of Presentation Accounting Policies: 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. De Minimis Rate Used: Y Rate Explanation: Team Rubicon has elected to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (Schedule) includes the federal grant activities of Team Rubicon, Inc. and Team Rubicon International LLC (Team Rubicon) for the year ended December 31, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of Team Rubicon's operations, it is not intended to and does not present the consolidated financial position, changes in consolidated net assets, or consolidated cash flows of Team Rubicon.
Title: 2. Summary of Significant Accounting Policies Accounting Policies: 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. De Minimis Rate Used: Y Rate Explanation: Team Rubicon has elected to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. 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.
Title: 3. Indirect Cost Rate Accounting Policies: 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. De Minimis Rate Used: Y Rate Explanation: Team Rubicon has elected to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. Team Rubicon has elected to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: 4. Subrecipients Accounting Policies: 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. De Minimis Rate Used: Y Rate Explanation: Team Rubicon has elected to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. Of the Federal expenditures presented in the Schedule, Team Rubicon provided no Federal awards to subrecipients.

Finding Details

Finding 2022-001: Identification of Federal Award Compliance Requirements  Assistance Listing Number: 19.510  Federal Program: U.S. Refugee Admissions Program  Federal Agency: U.S. Department of State  Pass-Through Entity: Church World Service  Type of Finding: Material Weakness in Internal Control over Compliance Criteria: Per Title 2 of the Code of Federal Regulations (2 CFR) section 200.501, non-federal entities that expend $750,000 or more during the non-federal entity’s fiscal year in federal awards must have a Single Audit conducted in accordance with 2 CFR section 200.514. Condition: We noted Team Rubicon received a federal subaward in excess of $750,000 requiring a Single Audit. Cause: The error was primarily due to a misunderstanding of the $750,000 limit above which a Single Audit would be required. Effect or Potential Effect: A failure to identify federal compliance requirements could result in Team Rubicon not being in compliance with federal statutes, regulations and the terms and conditions of federal awards. Questioned Costs: None identified Context: During the year ended December 31, 2022, Team Rubicon received a grant in excess of $750,000 from a recipient of a federal award, making Team Rubicon a subrecipient of the award and subject to certain federal compliance requirements including a Single Audit. Repeat Finding: Not applicable Recommendation: Management is responsible for establishing controls and procedures to ensure contracts and grants are reviewed for key terms and conditions that may indicate federal funding to ensure the proper identification and compliance with federal statutes, regulations and the terms and conditions of the federal awards including the requirement for a Single Audit. Views of Responsible Official: Management agrees and acknowledges the finding.
Finding 2022-002: Procurement and Suspension and Debarment  Assistance Listing Number: 19.510  Federal Program: U.S. Refugee Admissions Program  Federal Agency: U.S. Department of State  Pass-Through Entity: Church World Service  Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per guidance 2 CFR section 200.320, non-Federal entities must have and use documented procurement procedures, consistent with the standards of 2 CFR sections 200.320, 200.317, 200.318, and 200.319. Condition: We noted Team Rubicon’s procurement policy was missing key detail, including procurement procedures related to conflicts of interest, the search for suspended and debarred parties, and approved methods of procurement, including the specific situations where noncompetitive procurement is appropriate. Cause: The error was primarily due to a misunderstanding of certain federal compliance requirements. Effect or Potential Effect: A failure to identify federal compliance requirements could result in Team Rubicon not being in compliance with federal statutes, regulations and the terms and conditions of federal awards. Questioned Costs: None noted Context: During the year ended December 31, 2022, Team Rubicon was a recipient of a federal award, making Team Rubicon a subrecipient of the award and subject to certain federal compliance requirements including Procurement and Suspension and Debarment. Repeat Finding: Not applicable Recommendation: Management is responsible for establishing controls and procedures to ensure compliance with federal statutes, regulations and the terms and conditions of the federal awards. Views of Responsible Official: Management agrees and acknowledges the finding.
Finding 2022-003: Special Tests and Provisions  Assistance Listing Number: 19.510  Federal Program: U.S. Refugee Admissions Program  Federal Agency: U.S. Department of State  Pass-Through Entity: Church World Service  Type of Finding: Deficiency in Internal Control over Compliance Criteria: Per the U.S. Department of State, Bureau of Population, Refugees, and Migration, all forcibly displaced and stateless populations are considered at-risk and vulnerable requiring partners to assess the protection needs and to demonstrate accountability to these affected populations. Condition: We noted Team Rubicon had procedures in place to identify, vet, train and deploy volunteers; however, for external volunteers there were no formal internal control procedures to confirm these external volunteers were properly screened and oriented on and agreed to adhere to the program policies. Cause: An external volunteer had been borrowed from an adjacent federally funded entity that served a similar mission and population. Effect or Potential Effect: A failure to properly vet and train volunteers could result in Team Rubicon not being in compliance with federal statutes, regulations and the terms and conditions of federal awards. Questioned Costs: None identified Context: We noted that for an external volunteer, Team Rubicon could not produce evidence that the volunteer was properly screened and oriented, or had agreed to adhere to the program policies. Repeat Finding: Not applicable Recommendation: Management is responsible for establishing controls and procedures to ensure compliance with federal statutes, regulations and the terms and conditions of the federal awards. Views of Responsible Official: Management agrees and acknowledges the finding.
Finding 2022-001: Identification of Federal Award Compliance Requirements  Assistance Listing Number: 19.510  Federal Program: U.S. Refugee Admissions Program  Federal Agency: U.S. Department of State  Pass-Through Entity: Church World Service  Type of Finding: Material Weakness in Internal Control over Compliance Criteria: Per Title 2 of the Code of Federal Regulations (2 CFR) section 200.501, non-federal entities that expend $750,000 or more during the non-federal entity’s fiscal year in federal awards must have a Single Audit conducted in accordance with 2 CFR section 200.514. Condition: We noted Team Rubicon received a federal subaward in excess of $750,000 requiring a Single Audit. Cause: The error was primarily due to a misunderstanding of the $750,000 limit above which a Single Audit would be required. Effect or Potential Effect: A failure to identify federal compliance requirements could result in Team Rubicon not being in compliance with federal statutes, regulations and the terms and conditions of federal awards. Questioned Costs: None identified Context: During the year ended December 31, 2022, Team Rubicon received a grant in excess of $750,000 from a recipient of a federal award, making Team Rubicon a subrecipient of the award and subject to certain federal compliance requirements including a Single Audit. Repeat Finding: Not applicable Recommendation: Management is responsible for establishing controls and procedures to ensure contracts and grants are reviewed for key terms and conditions that may indicate federal funding to ensure the proper identification and compliance with federal statutes, regulations and the terms and conditions of the federal awards including the requirement for a Single Audit. Views of Responsible Official: Management agrees and acknowledges the finding.
Finding 2022-002: Procurement and Suspension and Debarment  Assistance Listing Number: 19.510  Federal Program: U.S. Refugee Admissions Program  Federal Agency: U.S. Department of State  Pass-Through Entity: Church World Service  Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per guidance 2 CFR section 200.320, non-Federal entities must have and use documented procurement procedures, consistent with the standards of 2 CFR sections 200.320, 200.317, 200.318, and 200.319. Condition: We noted Team Rubicon’s procurement policy was missing key detail, including procurement procedures related to conflicts of interest, the search for suspended and debarred parties, and approved methods of procurement, including the specific situations where noncompetitive procurement is appropriate. Cause: The error was primarily due to a misunderstanding of certain federal compliance requirements. Effect or Potential Effect: A failure to identify federal compliance requirements could result in Team Rubicon not being in compliance with federal statutes, regulations and the terms and conditions of federal awards. Questioned Costs: None noted Context: During the year ended December 31, 2022, Team Rubicon was a recipient of a federal award, making Team Rubicon a subrecipient of the award and subject to certain federal compliance requirements including Procurement and Suspension and Debarment. Repeat Finding: Not applicable Recommendation: Management is responsible for establishing controls and procedures to ensure compliance with federal statutes, regulations and the terms and conditions of the federal awards. Views of Responsible Official: Management agrees and acknowledges the finding.
Finding 2022-003: Special Tests and Provisions  Assistance Listing Number: 19.510  Federal Program: U.S. Refugee Admissions Program  Federal Agency: U.S. Department of State  Pass-Through Entity: Church World Service  Type of Finding: Deficiency in Internal Control over Compliance Criteria: Per the U.S. Department of State, Bureau of Population, Refugees, and Migration, all forcibly displaced and stateless populations are considered at-risk and vulnerable requiring partners to assess the protection needs and to demonstrate accountability to these affected populations. Condition: We noted Team Rubicon had procedures in place to identify, vet, train and deploy volunteers; however, for external volunteers there were no formal internal control procedures to confirm these external volunteers were properly screened and oriented on and agreed to adhere to the program policies. Cause: An external volunteer had been borrowed from an adjacent federally funded entity that served a similar mission and population. Effect or Potential Effect: A failure to properly vet and train volunteers could result in Team Rubicon not being in compliance with federal statutes, regulations and the terms and conditions of federal awards. Questioned Costs: None identified Context: We noted that for an external volunteer, Team Rubicon could not produce evidence that the volunteer was properly screened and oriented, or had agreed to adhere to the program policies. Repeat Finding: Not applicable Recommendation: Management is responsible for establishing controls and procedures to ensure compliance with federal statutes, regulations and the terms and conditions of the federal awards. Views of Responsible Official: Management agrees and acknowledges the finding.