Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.
Finding 2023-004 Subrecipient Pre-award Risk Assessment (Significant Deficiency)
Information on the Federal Programs: ALN #93.576 Refugee and Entrant Assistance Discretionary
Grants, ALN # U.S. Refugee Admissions Program
Criteria or Specific Requirement: CFR § 200.332, "Requirements for pass-through entities", requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the appropriate
subrecipient monitoring.
Condition: As part of our audit, we selected a sample of subawards charged to the major Federal
programs. We noted that subaward risk assessments were not available for our inspection for those
samples selected. Based on discussion with HIAS, the process for performing annual pre-award risk
assessments for new subrecipients as well as determining and documenting the appropriate level of
ongoing monitoring for existing sub recipients was implemented during January 2024 (during the time
of our audit fieldwork).
Cause: HIAS did not perform subaward risk assessments as required by Federal regulation.
Effect or Potential Effect: HIAS may have inadvertently failed to perform monitoring procedures
appropriate for a subrecipient’s assessed level of risk.
Questioned Costs: N/A
Context: HIAS executes subaward agreements under US Federal grants. Therefore, HIAS is subject
to CFR § 200.332 "Requirements for pass-through entities". Our audit procedures consisted of test
work completed on subawards and individual expenditures charged to the Federal awards. The report
in which samples were selected was generated directly from HIAS' general ledger (accounting system).
We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS strictly adhere to its new pre-award risk assessment
policy for all subaward relationships in the upcoming fiscal year.