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.