Audit 317239

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition: For six out of seven performance reports selected for testing (three in the Court Appointed Special Advocates, three in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. For three out of the 14 SF-425s selected for testing (one in the Court Appointed Special Advocates program, two in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. Cause: While National CASA/GAL has a procedure in place that requires the program manager to review performance reports and SF-425s prior to submission, the procedure was not formalized as part of National CASA/GAL’s policies, and thus, due to turnover, proper documentation to support the review was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. National CASA/GAL does not have the documentation required regarding review/approval of the performance reports and SF-425s. Questioned Costs: None. Context: There were three performance reports submitted for the Court Appointed Special Advocates and four performance reports submitted for the Juvenile Mentoring Program; all seven performance reports were tested. There were six SF-425 reports submitted for the Court Appointed Special Advocates and eight SF-425 reports submitted for the Juvenile Mentoring Program; all 14 reports were tested. This is a condition identified per review of National CASA/GAL’s compliance with specified requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL implement controls to ensure proper documentation of review and approval of reports. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval was not maintained. Management modified their policies and procedures during the 2022 audit to ensure documentation of review and approval of reports is prepared and maintained for future reports.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition: For six out of seven performance reports selected for testing (three in the Court Appointed Special Advocates, three in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. For three out of the 14 SF-425s selected for testing (one in the Court Appointed Special Advocates program, two in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. Cause: While National CASA/GAL has a procedure in place that requires the program manager to review performance reports and SF-425s prior to submission, the procedure was not formalized as part of National CASA/GAL’s policies, and thus, due to turnover, proper documentation to support the review was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. National CASA/GAL does not have the documentation required regarding review/approval of the performance reports and SF-425s. Questioned Costs: None. Context: There were three performance reports submitted for the Court Appointed Special Advocates and four performance reports submitted for the Juvenile Mentoring Program; all seven performance reports were tested. There were six SF-425 reports submitted for the Court Appointed Special Advocates and eight SF-425 reports submitted for the Juvenile Mentoring Program; all 14 reports were tested. This is a condition identified per review of National CASA/GAL’s compliance with specified requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL implement controls to ensure proper documentation of review and approval of reports. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval was not maintained. Management modified their policies and procedures during the 2022 audit to ensure documentation of review and approval of reports is prepared and maintained for future reports.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition: For six out of seven performance reports selected for testing (three in the Court Appointed Special Advocates, three in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. For three out of the 14 SF-425s selected for testing (one in the Court Appointed Special Advocates program, two in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. Cause: While National CASA/GAL has a procedure in place that requires the program manager to review performance reports and SF-425s prior to submission, the procedure was not formalized as part of National CASA/GAL’s policies, and thus, due to turnover, proper documentation to support the review was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. National CASA/GAL does not have the documentation required regarding review/approval of the performance reports and SF-425s. Questioned Costs: None. Context: There were three performance reports submitted for the Court Appointed Special Advocates and four performance reports submitted for the Juvenile Mentoring Program; all seven performance reports were tested. There were six SF-425 reports submitted for the Court Appointed Special Advocates and eight SF-425 reports submitted for the Juvenile Mentoring Program; all 14 reports were tested. This is a condition identified per review of National CASA/GAL’s compliance with specified requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL implement controls to ensure proper documentation of review and approval of reports. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval was not maintained. Management modified their policies and procedures during the 2022 audit to ensure documentation of review and approval of reports is prepared and maintained for future reports.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition: For six out of seven performance reports selected for testing (three in the Court Appointed Special Advocates, three in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. For three out of the 14 SF-425s selected for testing (one in the Court Appointed Special Advocates program, two in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. Cause: While National CASA/GAL has a procedure in place that requires the program manager to review performance reports and SF-425s prior to submission, the procedure was not formalized as part of National CASA/GAL’s policies, and thus, due to turnover, proper documentation to support the review was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. National CASA/GAL does not have the documentation required regarding review/approval of the performance reports and SF-425s. Questioned Costs: None. Context: There were three performance reports submitted for the Court Appointed Special Advocates and four performance reports submitted for the Juvenile Mentoring Program; all seven performance reports were tested. There were six SF-425 reports submitted for the Court Appointed Special Advocates and eight SF-425 reports submitted for the Juvenile Mentoring Program; all 14 reports were tested. This is a condition identified per review of National CASA/GAL’s compliance with specified requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL implement controls to ensure proper documentation of review and approval of reports. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval was not maintained. Management modified their policies and procedures during the 2022 audit to ensure documentation of review and approval of reports is prepared and maintained for future reports.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Per 2 CFR §200.430, Compensation – Personal Services:   “Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.” Condition: For both programs, National CASA/GAL did not include the retention of reviewed payroll allocation workbooks (journal entry support) in its procedures. No transactions were selected for testing related to the review of these workbooks as the control was determined to not be functioning prior to testing. Additionally, we noted that National CASA/GAL allocated year-end payroll accrual expenditures to the Juvenile Mentoring Program based on budget allocation rates. There was no procedure in place to determine if a true-up was necessary from allocated costs. 37 transactions were tested, of which three were charged based on budgets and were not trued-up. Cause: National CASA/GAL did not have policies and procedures in place requiring the retention of the review and approval of timesheet allocations (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure allocations are adequately reviewed and approved, and document this review and approval, National CASA/GAL could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement National CASA/GAL is entitled to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. There were 61 total timesheets tested for controls across both programs (51 within Court Appointed Special Advocates and ten within the Juvenile Mentoring Program). 97 total payroll transactions were tested across both programs (60 for Court Appointed Special Advocates and 37 for the Juvenile Mentoring Program) for compliance. Payroll costs for the Court Appointed Special Advocates in 2022 were $3,734,509. Payroll costs for the Juvenile Mentoring Program in 2022 were $160,643. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL consistently document the review and approval of the payroll allocations (journal entries), including any budget true-ups that are required for estimates at year end. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval of journal entries was not retained and that a true-up of estimates was not specified in procedures. Management revised the control process in 2023 to include detailed review and approval of allocation workbooks within the general ledger. Management additionally has updated their policies and procedures to evaluate year-end payroll accruals and the considerations for any necessary true-ups.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Per 2 CFR §200.430, Compensation – Personal Services:   “Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.” Condition: For both programs, National CASA/GAL did not include the retention of reviewed payroll allocation workbooks (journal entry support) in its procedures. No transactions were selected for testing related to the review of these workbooks as the control was determined to not be functioning prior to testing. Additionally, we noted that National CASA/GAL allocated year-end payroll accrual expenditures to the Juvenile Mentoring Program based on budget allocation rates. There was no procedure in place to determine if a true-up was necessary from allocated costs. 37 transactions were tested, of which three were charged based on budgets and were not trued-up. Cause: National CASA/GAL did not have policies and procedures in place requiring the retention of the review and approval of timesheet allocations (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure allocations are adequately reviewed and approved, and document this review and approval, National CASA/GAL could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement National CASA/GAL is entitled to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. There were 61 total timesheets tested for controls across both programs (51 within Court Appointed Special Advocates and ten within the Juvenile Mentoring Program). 97 total payroll transactions were tested across both programs (60 for Court Appointed Special Advocates and 37 for the Juvenile Mentoring Program) for compliance. Payroll costs for the Court Appointed Special Advocates in 2022 were $3,734,509. Payroll costs for the Juvenile Mentoring Program in 2022 were $160,643. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL consistently document the review and approval of the payroll allocations (journal entries), including any budget true-ups that are required for estimates at year end. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval of journal entries was not retained and that a true-up of estimates was not specified in procedures. Management revised the control process in 2023 to include detailed review and approval of allocation workbooks within the general ledger. Management additionally has updated their policies and procedures to evaluate year-end payroll accruals and the considerations for any necessary true-ups.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Per 2 CFR §200.430, Compensation – Personal Services:   “Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.” Condition: For both programs, National CASA/GAL did not include the retention of reviewed payroll allocation workbooks (journal entry support) in its procedures. No transactions were selected for testing related to the review of these workbooks as the control was determined to not be functioning prior to testing. Additionally, we noted that National CASA/GAL allocated year-end payroll accrual expenditures to the Juvenile Mentoring Program based on budget allocation rates. There was no procedure in place to determine if a true-up was necessary from allocated costs. 37 transactions were tested, of which three were charged based on budgets and were not trued-up. Cause: National CASA/GAL did not have policies and procedures in place requiring the retention of the review and approval of timesheet allocations (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure allocations are adequately reviewed and approved, and document this review and approval, National CASA/GAL could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement National CASA/GAL is entitled to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. There were 61 total timesheets tested for controls across both programs (51 within Court Appointed Special Advocates and ten within the Juvenile Mentoring Program). 97 total payroll transactions were tested across both programs (60 for Court Appointed Special Advocates and 37 for the Juvenile Mentoring Program) for compliance. Payroll costs for the Court Appointed Special Advocates in 2022 were $3,734,509. Payroll costs for the Juvenile Mentoring Program in 2022 were $160,643. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL consistently document the review and approval of the payroll allocations (journal entries), including any budget true-ups that are required for estimates at year end. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval of journal entries was not retained and that a true-up of estimates was not specified in procedures. Management revised the control process in 2023 to include detailed review and approval of allocation workbooks within the general ledger. Management additionally has updated their policies and procedures to evaluate year-end payroll accruals and the considerations for any necessary true-ups.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Per 2 CFR §200.430, Compensation – Personal Services:   “Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.” Condition: For both programs, National CASA/GAL did not include the retention of reviewed payroll allocation workbooks (journal entry support) in its procedures. No transactions were selected for testing related to the review of these workbooks as the control was determined to not be functioning prior to testing. Additionally, we noted that National CASA/GAL allocated year-end payroll accrual expenditures to the Juvenile Mentoring Program based on budget allocation rates. There was no procedure in place to determine if a true-up was necessary from allocated costs. 37 transactions were tested, of which three were charged based on budgets and were not trued-up. Cause: National CASA/GAL did not have policies and procedures in place requiring the retention of the review and approval of timesheet allocations (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure allocations are adequately reviewed and approved, and document this review and approval, National CASA/GAL could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement National CASA/GAL is entitled to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. There were 61 total timesheets tested for controls across both programs (51 within Court Appointed Special Advocates and ten within the Juvenile Mentoring Program). 97 total payroll transactions were tested across both programs (60 for Court Appointed Special Advocates and 37 for the Juvenile Mentoring Program) for compliance. Payroll costs for the Court Appointed Special Advocates in 2022 were $3,734,509. Payroll costs for the Juvenile Mentoring Program in 2022 were $160,643. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL consistently document the review and approval of the payroll allocations (journal entries), including any budget true-ups that are required for estimates at year end. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval of journal entries was not retained and that a true-up of estimates was not specified in procedures. Management revised the control process in 2023 to include detailed review and approval of allocation workbooks within the general ledger. Management additionally has updated their policies and procedures to evaluate year-end payroll accruals and the considerations for any necessary true-ups.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.332 details requirements for pass-through entities in regard to subrecipient monitoring and management. Per 2 CFR §200.332, Requirements for Pass-Through Entities: “All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes: (1) Federal award identification. i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient’s unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of federal award date in §200.1 of this part) of award to the recipient by the federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity, including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings Number and Title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the federal awarding agency, including identification of any required financial and performance reports; (4) i. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient, which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. ii. The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with §200.405(d). (5) A requirement that the subrecipient permits the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward.” Condition: National CASA/GAL’s subrecipient agreements do not contain a level of specificity to fully comply with federal subrecipient regulations. During our testing of subrecipient monitoring, we selected 20 subrecipient awards within Court Appointed Special Advocates and 17 subrecipient awards within the Juvenile Mentoring Program. For all awards tested, National CASA/GAL’s subaward agreements did not comply with 2 CFR §200.332, Requirements for Pass-Through Entities, as they do not contain a specific scope of work or project description. Cause: National CASA/GAL did not have the proper policies and procedures in place to ensure subaward agreements complied to relevant federal regulation, and that all required elements are located in subaward agreements, and not in the application or by reference to other documents. Effect or Potential Effect: Without adequate controls in place to ensure conformity with subaward requirements, grantees may not ensure compliance with any award special conditions or revised budgets agreed upon at contract implementation. Questioned Costs: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. For the Court Appointed Special Advocates Program, the population consisted of 100 subawards made totaling to $1,471,827 provided to subrecipients in 2022. The sample consisted of 20 subawards totaling $410,352 provided to subrecipients in 2022. For the Juvenile Mentoring Program, the population consisted of 83 subawards totaling to $2,339,039 provided to subrecipients in 2022. The sample consisted of 17 subawards totaling $441,399 provided to subrecipients in 2022. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend establishing and maintaining written policies and procedures to ensure subaward agreements conform to the requirements outlined in 2 CFR §200.332. Views of Responsible Officials: Management agrees that subrecipient agreements in place in 2022 did not fully comply with 2 CFR §200.332. Updates were made to the policies and procedures as well to ensure subaward files contain the requisite components. Management has additionally implemented a Grant Master File Checklist to ensure compliance with terms and conditions required in subaward agreements.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.332 details requirements for pass-through entities in regard to subrecipient monitoring and management. Per 2 CFR §200.332, Requirements for Pass-Through Entities: “All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes: (1) Federal award identification. i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient’s unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of federal award date in §200.1 of this part) of award to the recipient by the federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity, including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings Number and Title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the federal awarding agency, including identification of any required financial and performance reports; (4) i. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient, which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. ii. The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with §200.405(d). (5) A requirement that the subrecipient permits the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward.” Condition: National CASA/GAL’s subrecipient agreements do not contain a level of specificity to fully comply with federal subrecipient regulations. During our testing of subrecipient monitoring, we selected 20 subrecipient awards within Court Appointed Special Advocates and 17 subrecipient awards within the Juvenile Mentoring Program. For all awards tested, National CASA/GAL’s subaward agreements did not comply with 2 CFR §200.332, Requirements for Pass-Through Entities, as they do not contain a specific scope of work or project description. Cause: National CASA/GAL did not have the proper policies and procedures in place to ensure subaward agreements complied to relevant federal regulation, and that all required elements are located in subaward agreements, and not in the application or by reference to other documents. Effect or Potential Effect: Without adequate controls in place to ensure conformity with subaward requirements, grantees may not ensure compliance with any award special conditions or revised budgets agreed upon at contract implementation. Questioned Costs: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. For the Court Appointed Special Advocates Program, the population consisted of 100 subawards made totaling to $1,471,827 provided to subrecipients in 2022. The sample consisted of 20 subawards totaling $410,352 provided to subrecipients in 2022. For the Juvenile Mentoring Program, the population consisted of 83 subawards totaling to $2,339,039 provided to subrecipients in 2022. The sample consisted of 17 subawards totaling $441,399 provided to subrecipients in 2022. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend establishing and maintaining written policies and procedures to ensure subaward agreements conform to the requirements outlined in 2 CFR §200.332. Views of Responsible Officials: Management agrees that subrecipient agreements in place in 2022 did not fully comply with 2 CFR §200.332. Updates were made to the policies and procedures as well to ensure subaward files contain the requisite components. Management has additionally implemented a Grant Master File Checklist to ensure compliance with terms and conditions required in subaward agreements.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.332 details requirements for pass-through entities in regard to subrecipient monitoring and management. Per 2 CFR §200.332, Requirements for Pass-Through Entities: “All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes: (1) Federal award identification. i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient’s unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of federal award date in §200.1 of this part) of award to the recipient by the federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity, including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings Number and Title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the federal awarding agency, including identification of any required financial and performance reports; (4) i. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient, which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. ii. The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with §200.405(d). (5) A requirement that the subrecipient permits the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward.” Condition: National CASA/GAL’s subrecipient agreements do not contain a level of specificity to fully comply with federal subrecipient regulations. During our testing of subrecipient monitoring, we selected 20 subrecipient awards within Court Appointed Special Advocates and 17 subrecipient awards within the Juvenile Mentoring Program. For all awards tested, National CASA/GAL’s subaward agreements did not comply with 2 CFR §200.332, Requirements for Pass-Through Entities, as they do not contain a specific scope of work or project description. Cause: National CASA/GAL did not have the proper policies and procedures in place to ensure subaward agreements complied to relevant federal regulation, and that all required elements are located in subaward agreements, and not in the application or by reference to other documents. Effect or Potential Effect: Without adequate controls in place to ensure conformity with subaward requirements, grantees may not ensure compliance with any award special conditions or revised budgets agreed upon at contract implementation. Questioned Costs: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. For the Court Appointed Special Advocates Program, the population consisted of 100 subawards made totaling to $1,471,827 provided to subrecipients in 2022. The sample consisted of 20 subawards totaling $410,352 provided to subrecipients in 2022. For the Juvenile Mentoring Program, the population consisted of 83 subawards totaling to $2,339,039 provided to subrecipients in 2022. The sample consisted of 17 subawards totaling $441,399 provided to subrecipients in 2022. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend establishing and maintaining written policies and procedures to ensure subaward agreements conform to the requirements outlined in 2 CFR §200.332. Views of Responsible Officials: Management agrees that subrecipient agreements in place in 2022 did not fully comply with 2 CFR §200.332. Updates were made to the policies and procedures as well to ensure subaward files contain the requisite components. Management has additionally implemented a Grant Master File Checklist to ensure compliance with terms and conditions required in subaward agreements.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.332 details requirements for pass-through entities in regard to subrecipient monitoring and management. Per 2 CFR §200.332, Requirements for Pass-Through Entities: “All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes: (1) Federal award identification. i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient’s unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of federal award date in §200.1 of this part) of award to the recipient by the federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity, including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings Number and Title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the federal awarding agency, including identification of any required financial and performance reports; (4) i. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient, which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. ii. The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with §200.405(d). (5) A requirement that the subrecipient permits the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward.” Condition: National CASA/GAL’s subrecipient agreements do not contain a level of specificity to fully comply with federal subrecipient regulations. During our testing of subrecipient monitoring, we selected 20 subrecipient awards within Court Appointed Special Advocates and 17 subrecipient awards within the Juvenile Mentoring Program. For all awards tested, National CASA/GAL’s subaward agreements did not comply with 2 CFR §200.332, Requirements for Pass-Through Entities, as they do not contain a specific scope of work or project description. Cause: National CASA/GAL did not have the proper policies and procedures in place to ensure subaward agreements complied to relevant federal regulation, and that all required elements are located in subaward agreements, and not in the application or by reference to other documents. Effect or Potential Effect: Without adequate controls in place to ensure conformity with subaward requirements, grantees may not ensure compliance with any award special conditions or revised budgets agreed upon at contract implementation. Questioned Costs: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. For the Court Appointed Special Advocates Program, the population consisted of 100 subawards made totaling to $1,471,827 provided to subrecipients in 2022. The sample consisted of 20 subawards totaling $410,352 provided to subrecipients in 2022. For the Juvenile Mentoring Program, the population consisted of 83 subawards totaling to $2,339,039 provided to subrecipients in 2022. The sample consisted of 17 subawards totaling $441,399 provided to subrecipients in 2022. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend establishing and maintaining written policies and procedures to ensure subaward agreements conform to the requirements outlined in 2 CFR §200.332. Views of Responsible Officials: Management agrees that subrecipient agreements in place in 2022 did not fully comply with 2 CFR §200.332. Updates were made to the policies and procedures as well to ensure subaward files contain the requisite components. Management has additionally implemented a Grant Master File Checklist to ensure compliance with terms and conditions required in subaward agreements.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756 Program: Court Appointed Special Advocates Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with §200.317 through §200.327. Condition: During our testing of Court Appointed Special Advocates of eight procurement transactions that exceeded the micro-purchase threshold (National CASA/GAL threshold is $10,000) totaling $374,153 in expenditures charged to the program in 2022, and one procurement transaction that exceeded the simplified acquisition threshold (National CASA/GAL threshold is $250,000) for $2,581,125, we noted that National CASA/GAL did not maintain documentation to support the vendor selection processes and compliance with its policies and procedures for one out of nine transactions tested. For two others, National CASA/GAL had previously contracted with the vendors and performed the required procurement analysis in a prior fiscal year, but did not document that the nature of the addendums did not warrant a new procurement process. National CASA/GAL provided its rationale for each of the procurements as part of the audit sample and testing process. In addition, evidence of verification of the review of suspension and debarment before entering into a contract with the vendor was not maintained for one out of nine vendors selected. Cause: National CASA/GAL personnel did not adhere to internal documented policies and procedures for ensuring complete documentation of the history of the procurement for contracts procured with the intention to utilize federal funding. Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with federal regulations and National CASA/GAL’s policy. Known Questioned Costs: $79,204 Likely Questioned Costs: $301,657 Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. The total population of procurements exceeding the micro-purchase threshold was 26 procurements and equal to $1,153,011 in expenditures incurred in 2022, from which a sample of eight procurements was tested. The total population of procurements exceeding the simplified acquisition purchase threshold was two procurements and equal to $2,853,125 in expenditures incurred in 2022, from which a sample of one procurement was tested. The total expenditures during 2022 subject to procurement testing were $4,006,136 for Court Appointed Special Advocates. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with National CASA/GAL’s procurement policy and federal regulations in §200.318. Views of Responsible Officials: Management concurs with the finding that personnel did not consistently adhere to internal documented procurement policies and procedures. Management has updated the policies and procedures over procurement to ensure compliance with federal regulations.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756 Program: Court Appointed Special Advocates Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with §200.317 through §200.327. Condition: During our testing of Court Appointed Special Advocates of eight procurement transactions that exceeded the micro-purchase threshold (National CASA/GAL threshold is $10,000) totaling $374,153 in expenditures charged to the program in 2022, and one procurement transaction that exceeded the simplified acquisition threshold (National CASA/GAL threshold is $250,000) for $2,581,125, we noted that National CASA/GAL did not maintain documentation to support the vendor selection processes and compliance with its policies and procedures for one out of nine transactions tested. For two others, National CASA/GAL had previously contracted with the vendors and performed the required procurement analysis in a prior fiscal year, but did not document that the nature of the addendums did not warrant a new procurement process. National CASA/GAL provided its rationale for each of the procurements as part of the audit sample and testing process. In addition, evidence of verification of the review of suspension and debarment before entering into a contract with the vendor was not maintained for one out of nine vendors selected. Cause: National CASA/GAL personnel did not adhere to internal documented policies and procedures for ensuring complete documentation of the history of the procurement for contracts procured with the intention to utilize federal funding. Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with federal regulations and National CASA/GAL’s policy. Known Questioned Costs: $79,204 Likely Questioned Costs: $301,657 Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. The total population of procurements exceeding the micro-purchase threshold was 26 procurements and equal to $1,153,011 in expenditures incurred in 2022, from which a sample of eight procurements was tested. The total population of procurements exceeding the simplified acquisition purchase threshold was two procurements and equal to $2,853,125 in expenditures incurred in 2022, from which a sample of one procurement was tested. The total expenditures during 2022 subject to procurement testing were $4,006,136 for Court Appointed Special Advocates. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with National CASA/GAL’s procurement policy and federal regulations in §200.318. Views of Responsible Officials: Management concurs with the finding that personnel did not consistently adhere to internal documented procurement policies and procedures. Management has updated the policies and procedures over procurement to ensure compliance with federal regulations.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period. Condition: National CASA/GAL did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022. Cause: National CASA/GAL did not submit to the FAC within the required timeframe as the Department of Justice’s site visit and findings remediation was in progress through April 2024. Management elected to defer completion of the audit until the site visit was complete to ensure the audit package would be complete and accurate. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This was a condition noted per review of National CASA/GAL’s compliance with the specified requirements. The submission was due September 30, 2023. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL closely monitor and comply with the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials: Management concurs that the reporting package was not submitted to the Federal Audit Clearinghouse within the deadline. Management determined as a site visit by the Office of Juvenile Justice and Delinquency Prevention (OJJDP)/Office of the Chief Financial Officer (OCFO) and subsequent resolution of findings was in process, a delay in the report was necessary to ensure statements were complete and accurate. Management asserts compliance with the deadline is expected in future periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period. Condition: National CASA/GAL did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022. Cause: National CASA/GAL did not submit to the FAC within the required timeframe as the Department of Justice’s site visit and findings remediation was in progress through April 2024. Management elected to defer completion of the audit until the site visit was complete to ensure the audit package would be complete and accurate. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This was a condition noted per review of National CASA/GAL’s compliance with the specified requirements. The submission was due September 30, 2023. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL closely monitor and comply with the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials: Management concurs that the reporting package was not submitted to the Federal Audit Clearinghouse within the deadline. Management determined as a site visit by the Office of Juvenile Justice and Delinquency Prevention (OJJDP)/Office of the Chief Financial Officer (OCFO) and subsequent resolution of findings was in process, a delay in the report was necessary to ensure statements were complete and accurate. Management asserts compliance with the deadline is expected in future periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period. Condition: National CASA/GAL did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022. Cause: National CASA/GAL did not submit to the FAC within the required timeframe as the Department of Justice’s site visit and findings remediation was in progress through April 2024. Management elected to defer completion of the audit until the site visit was complete to ensure the audit package would be complete and accurate. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This was a condition noted per review of National CASA/GAL’s compliance with the specified requirements. The submission was due September 30, 2023. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL closely monitor and comply with the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials: Management concurs that the reporting package was not submitted to the Federal Audit Clearinghouse within the deadline. Management determined as a site visit by the Office of Juvenile Justice and Delinquency Prevention (OJJDP)/Office of the Chief Financial Officer (OCFO) and subsequent resolution of findings was in process, a delay in the report was necessary to ensure statements were complete and accurate. Management asserts compliance with the deadline is expected in future periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period. Condition: National CASA/GAL did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022. Cause: National CASA/GAL did not submit to the FAC within the required timeframe as the Department of Justice’s site visit and findings remediation was in progress through April 2024. Management elected to defer completion of the audit until the site visit was complete to ensure the audit package would be complete and accurate. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This was a condition noted per review of National CASA/GAL’s compliance with the specified requirements. The submission was due September 30, 2023. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL closely monitor and comply with the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials: Management concurs that the reporting package was not submitted to the Federal Audit Clearinghouse within the deadline. Management determined as a site visit by the Office of Juvenile Justice and Delinquency Prevention (OJJDP)/Office of the Chief Financial Officer (OCFO) and subsequent resolution of findings was in process, a delay in the report was necessary to ensure statements were complete and accurate. Management asserts compliance with the deadline is expected in future periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the federal awarding agency. Unless the federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions. Condition: National CASA/GAL allocated expenditures to the grant during and after the funding period. During our testing of costs, we noted the below: For Court Appointed Special Advocates: • Three of 136 transactions were either fully or partially incurred after the grant period. • 22 of 136 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For Juvenile Mentoring Program: • 27 of 97 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs through the journal entry process. Effect or Potential Effect: Without consistent application of the controls in place to ensure costs are allowable and reimbursable, and properly recognized based on the date of incurrence, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. For the Court Appointed Special Advocates Program, 16 transactions totaling to $85,362 in costs incurred at the end of the period of performance were tested from a population of 43 transactions totaling to $150,874. Three transactions with costs incurred outside the period of performance were identified totaling $4,917. Additionally, 120 transactions (60 payroll and 60 non-payroll) were tested from populations of expenditures incurred throughout 2022. Of these, 22 non-payroll transactions, totaling to $15,405, were identified, which lacked documentation of review and approval of the allocation of costs made through journal entries. One non-payroll transaction of $95 was identified lacking relevant supporting documentation. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed. Views of Responsible Officials: Management concurs with the finding that costs were incurred outside the appropriate funding period. Management will produce and maintain documentation supporting the review and approval of the funding period associated with costs incurred and their proper inclusion in the applicable period. Management will update policies and procedures to periodically review subrecipient details to ensure compliance with funding periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the federal awarding agency. Unless the federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions. Condition: National CASA/GAL allocated expenditures to the grant during and after the funding period. During our testing of costs, we noted the below: For Court Appointed Special Advocates: • Three of 136 transactions were either fully or partially incurred after the grant period. • 22 of 136 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For Juvenile Mentoring Program: • 27 of 97 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs through the journal entry process. Effect or Potential Effect: Without consistent application of the controls in place to ensure costs are allowable and reimbursable, and properly recognized based on the date of incurrence, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. For the Court Appointed Special Advocates Program, 16 transactions totaling to $85,362 in costs incurred at the end of the period of performance were tested from a population of 43 transactions totaling to $150,874. Three transactions with costs incurred outside the period of performance were identified totaling $4,917. Additionally, 120 transactions (60 payroll and 60 non-payroll) were tested from populations of expenditures incurred throughout 2022. Of these, 22 non-payroll transactions, totaling to $15,405, were identified, which lacked documentation of review and approval of the allocation of costs made through journal entries. One non-payroll transaction of $95 was identified lacking relevant supporting documentation. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed. Views of Responsible Officials: Management concurs with the finding that costs were incurred outside the appropriate funding period. Management will produce and maintain documentation supporting the review and approval of the funding period associated with costs incurred and their proper inclusion in the applicable period. Management will update policies and procedures to periodically review subrecipient details to ensure compliance with funding periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the federal awarding agency. Unless the federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions. Condition: National CASA/GAL allocated expenditures to the grant during and after the funding period. During our testing of costs, we noted the below: For Court Appointed Special Advocates: • Three of 136 transactions were either fully or partially incurred after the grant period. • 22 of 136 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For Juvenile Mentoring Program: • 27 of 97 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs through the journal entry process. Effect or Potential Effect: Without consistent application of the controls in place to ensure costs are allowable and reimbursable, and properly recognized based on the date of incurrence, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. For the Court Appointed Special Advocates Program, 16 transactions totaling to $85,362 in costs incurred at the end of the period of performance were tested from a population of 43 transactions totaling to $150,874. Three transactions with costs incurred outside the period of performance were identified totaling $4,917. Additionally, 120 transactions (60 payroll and 60 non-payroll) were tested from populations of expenditures incurred throughout 2022. Of these, 22 non-payroll transactions, totaling to $15,405, were identified, which lacked documentation of review and approval of the allocation of costs made through journal entries. One non-payroll transaction of $95 was identified lacking relevant supporting documentation. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed. Views of Responsible Officials: Management concurs with the finding that costs were incurred outside the appropriate funding period. Management will produce and maintain documentation supporting the review and approval of the funding period associated with costs incurred and their proper inclusion in the applicable period. Management will update policies and procedures to periodically review subrecipient details to ensure compliance with funding periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the federal awarding agency. Unless the federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions. Condition: National CASA/GAL allocated expenditures to the grant during and after the funding period. During our testing of costs, we noted the below: For Court Appointed Special Advocates: • Three of 136 transactions were either fully or partially incurred after the grant period. • 22 of 136 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For Juvenile Mentoring Program: • 27 of 97 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs through the journal entry process. Effect or Potential Effect: Without consistent application of the controls in place to ensure costs are allowable and reimbursable, and properly recognized based on the date of incurrence, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. For the Court Appointed Special Advocates Program, 16 transactions totaling to $85,362 in costs incurred at the end of the period of performance were tested from a population of 43 transactions totaling to $150,874. Three transactions with costs incurred outside the period of performance were identified totaling $4,917. Additionally, 120 transactions (60 payroll and 60 non-payroll) were tested from populations of expenditures incurred throughout 2022. Of these, 22 non-payroll transactions, totaling to $15,405, were identified, which lacked documentation of review and approval of the allocation of costs made through journal entries. One non-payroll transaction of $95 was identified lacking relevant supporting documentation. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed. Views of Responsible Officials: Management concurs with the finding that costs were incurred outside the appropriate funding period. Management will produce and maintain documentation supporting the review and approval of the funding period associated with costs incurred and their proper inclusion in the applicable period. Management will update policies and procedures to periodically review subrecipient details to ensure compliance with funding periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-federal entity is responsible for complying with all requirements of the federal award. For all federal awards, this includes the provisions of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “FFATA,” that are codified in 2 CFR Part 170, which includes requirements on executive compensation, and also requirements implementing the Act for the non-federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management, and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, National CASA/GAL is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: During our testing of reporting, we selected 12 subrecipient awards within Court Appointed Special Advocates and 16 subrecipient awards within the Juvenile Mentoring Program that were subject to FFATA. Within the Court Appointed Special Advocates, 10 out of 12 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For all samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Within the Juvenile Mentoring Program, 14 out of 16 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For seven samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Cause: National CASA/GAL did not follow the documented policies and procedures to ensure compliance with the FFATA filing requirements. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This is a condition identified based upon our review of National CASA/GAL’s compliance with specified requirements. For the Court Appointed Special Advocates Program, nine out of 12 awards subject to FFATA selected for testing were submitted within one month of the required submission date. One out of 12 awards was submitted within three months of the required submission date. For the Juvenile Mentoring Program, nine out of 16 awards subject to FFATA selected for testing were submitted within one month of the required submission date. Five out of 16 awards were submitted within one month of the required submission date. The sample was selected based on a non-statistical basis. The prevalence of these is detailed in the condition section above. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that reports are submitted timely with proper control procedures in place to ensure compliance with 2 CFR Section 200.303. Views of Responsible Officials: Management concurs with this finding. Management will add additional procedures to verify the appropriateness of submitted subrecipient information within their FFATA reporting packet. Management will additionally ensure FFATA reports are submitted within the required timeline.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-federal entity is responsible for complying with all requirements of the federal award. For all federal awards, this includes the provisions of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “FFATA,” that are codified in 2 CFR Part 170, which includes requirements on executive compensation, and also requirements implementing the Act for the non-federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management, and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, National CASA/GAL is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: During our testing of reporting, we selected 12 subrecipient awards within Court Appointed Special Advocates and 16 subrecipient awards within the Juvenile Mentoring Program that were subject to FFATA. Within the Court Appointed Special Advocates, 10 out of 12 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For all samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Within the Juvenile Mentoring Program, 14 out of 16 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For seven samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Cause: National CASA/GAL did not follow the documented policies and procedures to ensure compliance with the FFATA filing requirements. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This is a condition identified based upon our review of National CASA/GAL’s compliance with specified requirements. For the Court Appointed Special Advocates Program, nine out of 12 awards subject to FFATA selected for testing were submitted within one month of the required submission date. One out of 12 awards was submitted within three months of the required submission date. For the Juvenile Mentoring Program, nine out of 16 awards subject to FFATA selected for testing were submitted within one month of the required submission date. Five out of 16 awards were submitted within one month of the required submission date. The sample was selected based on a non-statistical basis. The prevalence of these is detailed in the condition section above. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that reports are submitted timely with proper control procedures in place to ensure compliance with 2 CFR Section 200.303. Views of Responsible Officials: Management concurs with this finding. Management will add additional procedures to verify the appropriateness of submitted subrecipient information within their FFATA reporting packet. Management will additionally ensure FFATA reports are submitted within the required timeline.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-federal entity is responsible for complying with all requirements of the federal award. For all federal awards, this includes the provisions of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “FFATA,” that are codified in 2 CFR Part 170, which includes requirements on executive compensation, and also requirements implementing the Act for the non-federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management, and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, National CASA/GAL is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: During our testing of reporting, we selected 12 subrecipient awards within Court Appointed Special Advocates and 16 subrecipient awards within the Juvenile Mentoring Program that were subject to FFATA. Within the Court Appointed Special Advocates, 10 out of 12 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For all samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Within the Juvenile Mentoring Program, 14 out of 16 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For seven samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Cause: National CASA/GAL did not follow the documented policies and procedures to ensure compliance with the FFATA filing requirements. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This is a condition identified based upon our review of National CASA/GAL’s compliance with specified requirements. For the Court Appointed Special Advocates Program, nine out of 12 awards subject to FFATA selected for testing were submitted within one month of the required submission date. One out of 12 awards was submitted within three months of the required submission date. For the Juvenile Mentoring Program, nine out of 16 awards subject to FFATA selected for testing were submitted within one month of the required submission date. Five out of 16 awards were submitted within one month of the required submission date. The sample was selected based on a non-statistical basis. The prevalence of these is detailed in the condition section above. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that reports are submitted timely with proper control procedures in place to ensure compliance with 2 CFR Section 200.303. Views of Responsible Officials: Management concurs with this finding. Management will add additional procedures to verify the appropriateness of submitted subrecipient information within their FFATA reporting packet. Management will additionally ensure FFATA reports are submitted within the required timeline.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-federal entity is responsible for complying with all requirements of the federal award. For all federal awards, this includes the provisions of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “FFATA,” that are codified in 2 CFR Part 170, which includes requirements on executive compensation, and also requirements implementing the Act for the non-federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management, and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, National CASA/GAL is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: During our testing of reporting, we selected 12 subrecipient awards within Court Appointed Special Advocates and 16 subrecipient awards within the Juvenile Mentoring Program that were subject to FFATA. Within the Court Appointed Special Advocates, 10 out of 12 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For all samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Within the Juvenile Mentoring Program, 14 out of 16 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For seven samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Cause: National CASA/GAL did not follow the documented policies and procedures to ensure compliance with the FFATA filing requirements. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This is a condition identified based upon our review of National CASA/GAL’s compliance with specified requirements. For the Court Appointed Special Advocates Program, nine out of 12 awards subject to FFATA selected for testing were submitted within one month of the required submission date. One out of 12 awards was submitted within three months of the required submission date. For the Juvenile Mentoring Program, nine out of 16 awards subject to FFATA selected for testing were submitted within one month of the required submission date. Five out of 16 awards were submitted within one month of the required submission date. The sample was selected based on a non-statistical basis. The prevalence of these is detailed in the condition section above. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that reports are submitted timely with proper control procedures in place to ensure compliance with 2 CFR Section 200.303. Views of Responsible Officials: Management concurs with this finding. Management will add additional procedures to verify the appropriateness of submitted subrecipient information within their FFATA reporting packet. Management will additionally ensure FFATA reports are submitted within the required timeline.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition: For six out of seven performance reports selected for testing (three in the Court Appointed Special Advocates, three in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. For three out of the 14 SF-425s selected for testing (one in the Court Appointed Special Advocates program, two in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. Cause: While National CASA/GAL has a procedure in place that requires the program manager to review performance reports and SF-425s prior to submission, the procedure was not formalized as part of National CASA/GAL’s policies, and thus, due to turnover, proper documentation to support the review was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. National CASA/GAL does not have the documentation required regarding review/approval of the performance reports and SF-425s. Questioned Costs: None. Context: There were three performance reports submitted for the Court Appointed Special Advocates and four performance reports submitted for the Juvenile Mentoring Program; all seven performance reports were tested. There were six SF-425 reports submitted for the Court Appointed Special Advocates and eight SF-425 reports submitted for the Juvenile Mentoring Program; all 14 reports were tested. This is a condition identified per review of National CASA/GAL’s compliance with specified requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL implement controls to ensure proper documentation of review and approval of reports. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval was not maintained. Management modified their policies and procedures during the 2022 audit to ensure documentation of review and approval of reports is prepared and maintained for future reports.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition: For six out of seven performance reports selected for testing (three in the Court Appointed Special Advocates, three in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. For three out of the 14 SF-425s selected for testing (one in the Court Appointed Special Advocates program, two in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. Cause: While National CASA/GAL has a procedure in place that requires the program manager to review performance reports and SF-425s prior to submission, the procedure was not formalized as part of National CASA/GAL’s policies, and thus, due to turnover, proper documentation to support the review was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. National CASA/GAL does not have the documentation required regarding review/approval of the performance reports and SF-425s. Questioned Costs: None. Context: There were three performance reports submitted for the Court Appointed Special Advocates and four performance reports submitted for the Juvenile Mentoring Program; all seven performance reports were tested. There were six SF-425 reports submitted for the Court Appointed Special Advocates and eight SF-425 reports submitted for the Juvenile Mentoring Program; all 14 reports were tested. This is a condition identified per review of National CASA/GAL’s compliance with specified requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL implement controls to ensure proper documentation of review and approval of reports. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval was not maintained. Management modified their policies and procedures during the 2022 audit to ensure documentation of review and approval of reports is prepared and maintained for future reports.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition: For six out of seven performance reports selected for testing (three in the Court Appointed Special Advocates, three in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. For three out of the 14 SF-425s selected for testing (one in the Court Appointed Special Advocates program, two in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. Cause: While National CASA/GAL has a procedure in place that requires the program manager to review performance reports and SF-425s prior to submission, the procedure was not formalized as part of National CASA/GAL’s policies, and thus, due to turnover, proper documentation to support the review was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. National CASA/GAL does not have the documentation required regarding review/approval of the performance reports and SF-425s. Questioned Costs: None. Context: There were three performance reports submitted for the Court Appointed Special Advocates and four performance reports submitted for the Juvenile Mentoring Program; all seven performance reports were tested. There were six SF-425 reports submitted for the Court Appointed Special Advocates and eight SF-425 reports submitted for the Juvenile Mentoring Program; all 14 reports were tested. This is a condition identified per review of National CASA/GAL’s compliance with specified requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL implement controls to ensure proper documentation of review and approval of reports. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval was not maintained. Management modified their policies and procedures during the 2022 audit to ensure documentation of review and approval of reports is prepared and maintained for future reports.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition: For six out of seven performance reports selected for testing (three in the Court Appointed Special Advocates, three in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. For three out of the 14 SF-425s selected for testing (one in the Court Appointed Special Advocates program, two in the Juvenile Mentoring Program), appropriate documentation was not available to evidence review of the report prior to submission. Cause: While National CASA/GAL has a procedure in place that requires the program manager to review performance reports and SF-425s prior to submission, the procedure was not formalized as part of National CASA/GAL’s policies, and thus, due to turnover, proper documentation to support the review was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. National CASA/GAL does not have the documentation required regarding review/approval of the performance reports and SF-425s. Questioned Costs: None. Context: There were three performance reports submitted for the Court Appointed Special Advocates and four performance reports submitted for the Juvenile Mentoring Program; all seven performance reports were tested. There were six SF-425 reports submitted for the Court Appointed Special Advocates and eight SF-425 reports submitted for the Juvenile Mentoring Program; all 14 reports were tested. This is a condition identified per review of National CASA/GAL’s compliance with specified requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL implement controls to ensure proper documentation of review and approval of reports. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval was not maintained. Management modified their policies and procedures during the 2022 audit to ensure documentation of review and approval of reports is prepared and maintained for future reports.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Per 2 CFR §200.430, Compensation – Personal Services:   “Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.” Condition: For both programs, National CASA/GAL did not include the retention of reviewed payroll allocation workbooks (journal entry support) in its procedures. No transactions were selected for testing related to the review of these workbooks as the control was determined to not be functioning prior to testing. Additionally, we noted that National CASA/GAL allocated year-end payroll accrual expenditures to the Juvenile Mentoring Program based on budget allocation rates. There was no procedure in place to determine if a true-up was necessary from allocated costs. 37 transactions were tested, of which three were charged based on budgets and were not trued-up. Cause: National CASA/GAL did not have policies and procedures in place requiring the retention of the review and approval of timesheet allocations (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure allocations are adequately reviewed and approved, and document this review and approval, National CASA/GAL could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement National CASA/GAL is entitled to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. There were 61 total timesheets tested for controls across both programs (51 within Court Appointed Special Advocates and ten within the Juvenile Mentoring Program). 97 total payroll transactions were tested across both programs (60 for Court Appointed Special Advocates and 37 for the Juvenile Mentoring Program) for compliance. Payroll costs for the Court Appointed Special Advocates in 2022 were $3,734,509. Payroll costs for the Juvenile Mentoring Program in 2022 were $160,643. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL consistently document the review and approval of the payroll allocations (journal entries), including any budget true-ups that are required for estimates at year end. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval of journal entries was not retained and that a true-up of estimates was not specified in procedures. Management revised the control process in 2023 to include detailed review and approval of allocation workbooks within the general ledger. Management additionally has updated their policies and procedures to evaluate year-end payroll accruals and the considerations for any necessary true-ups.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Per 2 CFR §200.430, Compensation – Personal Services:   “Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.” Condition: For both programs, National CASA/GAL did not include the retention of reviewed payroll allocation workbooks (journal entry support) in its procedures. No transactions were selected for testing related to the review of these workbooks as the control was determined to not be functioning prior to testing. Additionally, we noted that National CASA/GAL allocated year-end payroll accrual expenditures to the Juvenile Mentoring Program based on budget allocation rates. There was no procedure in place to determine if a true-up was necessary from allocated costs. 37 transactions were tested, of which three were charged based on budgets and were not trued-up. Cause: National CASA/GAL did not have policies and procedures in place requiring the retention of the review and approval of timesheet allocations (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure allocations are adequately reviewed and approved, and document this review and approval, National CASA/GAL could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement National CASA/GAL is entitled to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. There were 61 total timesheets tested for controls across both programs (51 within Court Appointed Special Advocates and ten within the Juvenile Mentoring Program). 97 total payroll transactions were tested across both programs (60 for Court Appointed Special Advocates and 37 for the Juvenile Mentoring Program) for compliance. Payroll costs for the Court Appointed Special Advocates in 2022 were $3,734,509. Payroll costs for the Juvenile Mentoring Program in 2022 were $160,643. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL consistently document the review and approval of the payroll allocations (journal entries), including any budget true-ups that are required for estimates at year end. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval of journal entries was not retained and that a true-up of estimates was not specified in procedures. Management revised the control process in 2023 to include detailed review and approval of allocation workbooks within the general ledger. Management additionally has updated their policies and procedures to evaluate year-end payroll accruals and the considerations for any necessary true-ups.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Per 2 CFR §200.430, Compensation – Personal Services:   “Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.” Condition: For both programs, National CASA/GAL did not include the retention of reviewed payroll allocation workbooks (journal entry support) in its procedures. No transactions were selected for testing related to the review of these workbooks as the control was determined to not be functioning prior to testing. Additionally, we noted that National CASA/GAL allocated year-end payroll accrual expenditures to the Juvenile Mentoring Program based on budget allocation rates. There was no procedure in place to determine if a true-up was necessary from allocated costs. 37 transactions were tested, of which three were charged based on budgets and were not trued-up. Cause: National CASA/GAL did not have policies and procedures in place requiring the retention of the review and approval of timesheet allocations (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure allocations are adequately reviewed and approved, and document this review and approval, National CASA/GAL could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement National CASA/GAL is entitled to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. There were 61 total timesheets tested for controls across both programs (51 within Court Appointed Special Advocates and ten within the Juvenile Mentoring Program). 97 total payroll transactions were tested across both programs (60 for Court Appointed Special Advocates and 37 for the Juvenile Mentoring Program) for compliance. Payroll costs for the Court Appointed Special Advocates in 2022 were $3,734,509. Payroll costs for the Juvenile Mentoring Program in 2022 were $160,643. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL consistently document the review and approval of the payroll allocations (journal entries), including any budget true-ups that are required for estimates at year end. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval of journal entries was not retained and that a true-up of estimates was not specified in procedures. Management revised the control process in 2023 to include detailed review and approval of allocation workbooks within the general ledger. Management additionally has updated their policies and procedures to evaluate year-end payroll accruals and the considerations for any necessary true-ups.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Per 2 CFR §200.430, Compensation – Personal Services:   “Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non-federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-federal entity; and (vi) [Reserved] (vii) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-federal entity’s written policies) are identified and entered into the records in a timely manner. Short-term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The non-federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to a federal award based on budget estimates. All necessary adjustment must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.” Condition: For both programs, National CASA/GAL did not include the retention of reviewed payroll allocation workbooks (journal entry support) in its procedures. No transactions were selected for testing related to the review of these workbooks as the control was determined to not be functioning prior to testing. Additionally, we noted that National CASA/GAL allocated year-end payroll accrual expenditures to the Juvenile Mentoring Program based on budget allocation rates. There was no procedure in place to determine if a true-up was necessary from allocated costs. 37 transactions were tested, of which three were charged based on budgets and were not trued-up. Cause: National CASA/GAL did not have policies and procedures in place requiring the retention of the review and approval of timesheet allocations (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure allocations are adequately reviewed and approved, and document this review and approval, National CASA/GAL could incorrectly charge expenditures to the federal program, or not request appropriate reimbursement National CASA/GAL is entitled to under the terms of the grant. Questioned Costs: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. There were 61 total timesheets tested for controls across both programs (51 within Court Appointed Special Advocates and ten within the Juvenile Mentoring Program). 97 total payroll transactions were tested across both programs (60 for Court Appointed Special Advocates and 37 for the Juvenile Mentoring Program) for compliance. Payroll costs for the Court Appointed Special Advocates in 2022 were $3,734,509. Payroll costs for the Juvenile Mentoring Program in 2022 were $160,643. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL consistently document the review and approval of the payroll allocations (journal entries), including any budget true-ups that are required for estimates at year end. Views of Responsible Officials: Management agrees with the finding that documentation of review and approval of journal entries was not retained and that a true-up of estimates was not specified in procedures. Management revised the control process in 2023 to include detailed review and approval of allocation workbooks within the general ledger. Management additionally has updated their policies and procedures to evaluate year-end payroll accruals and the considerations for any necessary true-ups.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.403 states that for costs to be allowable under federal awards, they must be adequately documented and there must be sufficient documentation. “Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: a) Be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. See also §200.306(b). g) Be adequately documented. See also §200.300 through §200.309. h) Cost must be incurred during the approved budget period. The federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).” Condition: National CASA/GAL allocated expenditures to programs during 2022 based on a direct allocation methodology. This allocation is done manually, and the support was inconsistently maintained. During our testing of costs (excluding salaries, see finding 2022-003), we noted in accordance with §200.403(g) that: For Court Appointed Special Advocates: • One of 60 transactions was partially charged in the incorrect fiscal period. • One of 60 transactions underlying supporting documentation was not retained. • 19 of 60 transactions had inconsistent allocation methods (based on an estimated metric such as estimated time on program or square feet space utilized) applied to costs. • 21 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For the Juvenile Mentoring Program: • One of 60 transactions lacked documentation of all required reviews and approvals. • One of 60 transactions the incorrect allocation rate was utilized. • One of 60 transactions underlying supporting documentation was not retained. • 27 of 60 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs (journal entries). Effect or Potential Effect: Without adequate controls in place to ensure costs are allowable and reimbursable, including controls over review of allocation methodologies, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: Below reporting threshold. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. Nonpayroll costs for the Court Appointed Special Advocates in 2022 were $6,500,295. The sample tested consisted of 60 transactions totaling $165,919. Nonpayroll costs for the Juvenile Mentoring Program in 2022 were $2,401,373. The sample tested consisted of 60 transactions totaling $151,177. Questioned costs consist of amounts lacking underlying support or amounts in excess of supported allocations. For Court Appointed Special Advocates, four transactions resulted in questioned costs of $3,139. For the Juvenile Mentoring Program, two transactions resulted in questioned costs of $456. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that policies and procedures be updated to ensure underlying support, as well as support for allocations is appropriately maintained as required by §200.403. Views of Responsible Officials: Management concurs with the finding that procedures should specify that documentation of review and approval of both the costs charged and the allocation method of costs charged to federal grants be maintained. Management put policies in place to capture the documentation and maintenance of documentation indicating supervisor review and approval.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.332 details requirements for pass-through entities in regard to subrecipient monitoring and management. Per 2 CFR §200.332, Requirements for Pass-Through Entities: “All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes: (1) Federal award identification. i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient’s unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of federal award date in §200.1 of this part) of award to the recipient by the federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity, including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings Number and Title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the federal awarding agency, including identification of any required financial and performance reports; (4) i. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient, which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. ii. The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with §200.405(d). (5) A requirement that the subrecipient permits the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward.” Condition: National CASA/GAL’s subrecipient agreements do not contain a level of specificity to fully comply with federal subrecipient regulations. During our testing of subrecipient monitoring, we selected 20 subrecipient awards within Court Appointed Special Advocates and 17 subrecipient awards within the Juvenile Mentoring Program. For all awards tested, National CASA/GAL’s subaward agreements did not comply with 2 CFR §200.332, Requirements for Pass-Through Entities, as they do not contain a specific scope of work or project description. Cause: National CASA/GAL did not have the proper policies and procedures in place to ensure subaward agreements complied to relevant federal regulation, and that all required elements are located in subaward agreements, and not in the application or by reference to other documents. Effect or Potential Effect: Without adequate controls in place to ensure conformity with subaward requirements, grantees may not ensure compliance with any award special conditions or revised budgets agreed upon at contract implementation. Questioned Costs: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. For the Court Appointed Special Advocates Program, the population consisted of 100 subawards made totaling to $1,471,827 provided to subrecipients in 2022. The sample consisted of 20 subawards totaling $410,352 provided to subrecipients in 2022. For the Juvenile Mentoring Program, the population consisted of 83 subawards totaling to $2,339,039 provided to subrecipients in 2022. The sample consisted of 17 subawards totaling $441,399 provided to subrecipients in 2022. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend establishing and maintaining written policies and procedures to ensure subaward agreements conform to the requirements outlined in 2 CFR §200.332. Views of Responsible Officials: Management agrees that subrecipient agreements in place in 2022 did not fully comply with 2 CFR §200.332. Updates were made to the policies and procedures as well to ensure subaward files contain the requisite components. Management has additionally implemented a Grant Master File Checklist to ensure compliance with terms and conditions required in subaward agreements.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.332 details requirements for pass-through entities in regard to subrecipient monitoring and management. Per 2 CFR §200.332, Requirements for Pass-Through Entities: “All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes: (1) Federal award identification. i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient’s unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of federal award date in §200.1 of this part) of award to the recipient by the federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity, including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings Number and Title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the federal awarding agency, including identification of any required financial and performance reports; (4) i. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient, which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. ii. The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with §200.405(d). (5) A requirement that the subrecipient permits the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward.” Condition: National CASA/GAL’s subrecipient agreements do not contain a level of specificity to fully comply with federal subrecipient regulations. During our testing of subrecipient monitoring, we selected 20 subrecipient awards within Court Appointed Special Advocates and 17 subrecipient awards within the Juvenile Mentoring Program. For all awards tested, National CASA/GAL’s subaward agreements did not comply with 2 CFR §200.332, Requirements for Pass-Through Entities, as they do not contain a specific scope of work or project description. Cause: National CASA/GAL did not have the proper policies and procedures in place to ensure subaward agreements complied to relevant federal regulation, and that all required elements are located in subaward agreements, and not in the application or by reference to other documents. Effect or Potential Effect: Without adequate controls in place to ensure conformity with subaward requirements, grantees may not ensure compliance with any award special conditions or revised budgets agreed upon at contract implementation. Questioned Costs: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. For the Court Appointed Special Advocates Program, the population consisted of 100 subawards made totaling to $1,471,827 provided to subrecipients in 2022. The sample consisted of 20 subawards totaling $410,352 provided to subrecipients in 2022. For the Juvenile Mentoring Program, the population consisted of 83 subawards totaling to $2,339,039 provided to subrecipients in 2022. The sample consisted of 17 subawards totaling $441,399 provided to subrecipients in 2022. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend establishing and maintaining written policies and procedures to ensure subaward agreements conform to the requirements outlined in 2 CFR §200.332. Views of Responsible Officials: Management agrees that subrecipient agreements in place in 2022 did not fully comply with 2 CFR §200.332. Updates were made to the policies and procedures as well to ensure subaward files contain the requisite components. Management has additionally implemented a Grant Master File Checklist to ensure compliance with terms and conditions required in subaward agreements.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.332 details requirements for pass-through entities in regard to subrecipient monitoring and management. Per 2 CFR §200.332, Requirements for Pass-Through Entities: “All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes: (1) Federal award identification. i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient’s unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of federal award date in §200.1 of this part) of award to the recipient by the federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity, including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings Number and Title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the federal awarding agency, including identification of any required financial and performance reports; (4) i. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient, which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. ii. The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with §200.405(d). (5) A requirement that the subrecipient permits the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward.” Condition: National CASA/GAL’s subrecipient agreements do not contain a level of specificity to fully comply with federal subrecipient regulations. During our testing of subrecipient monitoring, we selected 20 subrecipient awards within Court Appointed Special Advocates and 17 subrecipient awards within the Juvenile Mentoring Program. For all awards tested, National CASA/GAL’s subaward agreements did not comply with 2 CFR §200.332, Requirements for Pass-Through Entities, as they do not contain a specific scope of work or project description. Cause: National CASA/GAL did not have the proper policies and procedures in place to ensure subaward agreements complied to relevant federal regulation, and that all required elements are located in subaward agreements, and not in the application or by reference to other documents. Effect or Potential Effect: Without adequate controls in place to ensure conformity with subaward requirements, grantees may not ensure compliance with any award special conditions or revised budgets agreed upon at contract implementation. Questioned Costs: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. For the Court Appointed Special Advocates Program, the population consisted of 100 subawards made totaling to $1,471,827 provided to subrecipients in 2022. The sample consisted of 20 subawards totaling $410,352 provided to subrecipients in 2022. For the Juvenile Mentoring Program, the population consisted of 83 subawards totaling to $2,339,039 provided to subrecipients in 2022. The sample consisted of 17 subawards totaling $441,399 provided to subrecipients in 2022. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend establishing and maintaining written policies and procedures to ensure subaward agreements conform to the requirements outlined in 2 CFR §200.332. Views of Responsible Officials: Management agrees that subrecipient agreements in place in 2022 did not fully comply with 2 CFR §200.332. Updates were made to the policies and procedures as well to ensure subaward files contain the requisite components. Management has additionally implemented a Grant Master File Checklist to ensure compliance with terms and conditions required in subaward agreements.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.332 details requirements for pass-through entities in regard to subrecipient monitoring and management. Per 2 CFR §200.332, Requirements for Pass-Through Entities: “All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Required information includes: (1) Federal award identification. i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient’s unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of federal award date in §200.1 of this part) of award to the recipient by the federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity, including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings Number and Title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the federal awarding agency, including identification of any required financial and performance reports; (4) i. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient, which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. ii. The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with §200.405(d). (5) A requirement that the subrecipient permits the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward.” Condition: National CASA/GAL’s subrecipient agreements do not contain a level of specificity to fully comply with federal subrecipient regulations. During our testing of subrecipient monitoring, we selected 20 subrecipient awards within Court Appointed Special Advocates and 17 subrecipient awards within the Juvenile Mentoring Program. For all awards tested, National CASA/GAL’s subaward agreements did not comply with 2 CFR §200.332, Requirements for Pass-Through Entities, as they do not contain a specific scope of work or project description. Cause: National CASA/GAL did not have the proper policies and procedures in place to ensure subaward agreements complied to relevant federal regulation, and that all required elements are located in subaward agreements, and not in the application or by reference to other documents. Effect or Potential Effect: Without adequate controls in place to ensure conformity with subaward requirements, grantees may not ensure compliance with any award special conditions or revised budgets agreed upon at contract implementation. Questioned Costs: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. For the Court Appointed Special Advocates Program, the population consisted of 100 subawards made totaling to $1,471,827 provided to subrecipients in 2022. The sample consisted of 20 subawards totaling $410,352 provided to subrecipients in 2022. For the Juvenile Mentoring Program, the population consisted of 83 subawards totaling to $2,339,039 provided to subrecipients in 2022. The sample consisted of 17 subawards totaling $441,399 provided to subrecipients in 2022. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend establishing and maintaining written policies and procedures to ensure subaward agreements conform to the requirements outlined in 2 CFR §200.332. Views of Responsible Officials: Management agrees that subrecipient agreements in place in 2022 did not fully comply with 2 CFR §200.332. Updates were made to the policies and procedures as well to ensure subaward files contain the requisite components. Management has additionally implemented a Grant Master File Checklist to ensure compliance with terms and conditions required in subaward agreements.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756 Program: Court Appointed Special Advocates Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with §200.317 through §200.327. Condition: During our testing of Court Appointed Special Advocates of eight procurement transactions that exceeded the micro-purchase threshold (National CASA/GAL threshold is $10,000) totaling $374,153 in expenditures charged to the program in 2022, and one procurement transaction that exceeded the simplified acquisition threshold (National CASA/GAL threshold is $250,000) for $2,581,125, we noted that National CASA/GAL did not maintain documentation to support the vendor selection processes and compliance with its policies and procedures for one out of nine transactions tested. For two others, National CASA/GAL had previously contracted with the vendors and performed the required procurement analysis in a prior fiscal year, but did not document that the nature of the addendums did not warrant a new procurement process. National CASA/GAL provided its rationale for each of the procurements as part of the audit sample and testing process. In addition, evidence of verification of the review of suspension and debarment before entering into a contract with the vendor was not maintained for one out of nine vendors selected. Cause: National CASA/GAL personnel did not adhere to internal documented policies and procedures for ensuring complete documentation of the history of the procurement for contracts procured with the intention to utilize federal funding. Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with federal regulations and National CASA/GAL’s policy. Known Questioned Costs: $79,204 Likely Questioned Costs: $301,657 Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. The total population of procurements exceeding the micro-purchase threshold was 26 procurements and equal to $1,153,011 in expenditures incurred in 2022, from which a sample of eight procurements was tested. The total population of procurements exceeding the simplified acquisition purchase threshold was two procurements and equal to $2,853,125 in expenditures incurred in 2022, from which a sample of one procurement was tested. The total expenditures during 2022 subject to procurement testing were $4,006,136 for Court Appointed Special Advocates. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with National CASA/GAL’s procurement policy and federal regulations in §200.318. Views of Responsible Officials: Management concurs with the finding that personnel did not consistently adhere to internal documented procurement policies and procedures. Management has updated the policies and procedures over procurement to ensure compliance with federal regulations.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756 Program: Court Appointed Special Advocates Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA Criteria: In accordance with §200.318, the non-federal entity must use its own documented procurement procedures which reflect applicable laws and regulations, provided that the procurements conform to applicable federal law and the standards identified. Additionally, the non federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. All procurement transactions must be conducted in in accordance with §200.317 through §200.327. Condition: During our testing of Court Appointed Special Advocates of eight procurement transactions that exceeded the micro-purchase threshold (National CASA/GAL threshold is $10,000) totaling $374,153 in expenditures charged to the program in 2022, and one procurement transaction that exceeded the simplified acquisition threshold (National CASA/GAL threshold is $250,000) for $2,581,125, we noted that National CASA/GAL did not maintain documentation to support the vendor selection processes and compliance with its policies and procedures for one out of nine transactions tested. For two others, National CASA/GAL had previously contracted with the vendors and performed the required procurement analysis in a prior fiscal year, but did not document that the nature of the addendums did not warrant a new procurement process. National CASA/GAL provided its rationale for each of the procurements as part of the audit sample and testing process. In addition, evidence of verification of the review of suspension and debarment before entering into a contract with the vendor was not maintained for one out of nine vendors selected. Cause: National CASA/GAL personnel did not adhere to internal documented policies and procedures for ensuring complete documentation of the history of the procurement for contracts procured with the intention to utilize federal funding. Effect or Potential Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements is noncompliance with federal regulations and National CASA/GAL’s policy. Known Questioned Costs: $79,204 Likely Questioned Costs: $301,657 Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements using a non-statistically valid sample. The total population of procurements exceeding the micro-purchase threshold was 26 procurements and equal to $1,153,011 in expenditures incurred in 2022, from which a sample of eight procurements was tested. The total population of procurements exceeding the simplified acquisition purchase threshold was two procurements and equal to $2,853,125 in expenditures incurred in 2022, from which a sample of one procurement was tested. The total expenditures during 2022 subject to procurement testing were $4,006,136 for Court Appointed Special Advocates. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with National CASA/GAL’s procurement policy and federal regulations in §200.318. Views of Responsible Officials: Management concurs with the finding that personnel did not consistently adhere to internal documented procurement policies and procedures. Management has updated the policies and procedures over procurement to ensure compliance with federal regulations.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period. Condition: National CASA/GAL did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022. Cause: National CASA/GAL did not submit to the FAC within the required timeframe as the Department of Justice’s site visit and findings remediation was in progress through April 2024. Management elected to defer completion of the audit until the site visit was complete to ensure the audit package would be complete and accurate. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This was a condition noted per review of National CASA/GAL’s compliance with the specified requirements. The submission was due September 30, 2023. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL closely monitor and comply with the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials: Management concurs that the reporting package was not submitted to the Federal Audit Clearinghouse within the deadline. Management determined as a site visit by the Office of Juvenile Justice and Delinquency Prevention (OJJDP)/Office of the Chief Financial Officer (OCFO) and subsequent resolution of findings was in process, a delay in the report was necessary to ensure statements were complete and accurate. Management asserts compliance with the deadline is expected in future periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period. Condition: National CASA/GAL did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022. Cause: National CASA/GAL did not submit to the FAC within the required timeframe as the Department of Justice’s site visit and findings remediation was in progress through April 2024. Management elected to defer completion of the audit until the site visit was complete to ensure the audit package would be complete and accurate. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This was a condition noted per review of National CASA/GAL’s compliance with the specified requirements. The submission was due September 30, 2023. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL closely monitor and comply with the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials: Management concurs that the reporting package was not submitted to the Federal Audit Clearinghouse within the deadline. Management determined as a site visit by the Office of Juvenile Justice and Delinquency Prevention (OJJDP)/Office of the Chief Financial Officer (OCFO) and subsequent resolution of findings was in process, a delay in the report was necessary to ensure statements were complete and accurate. Management asserts compliance with the deadline is expected in future periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period. Condition: National CASA/GAL did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022. Cause: National CASA/GAL did not submit to the FAC within the required timeframe as the Department of Justice’s site visit and findings remediation was in progress through April 2024. Management elected to defer completion of the audit until the site visit was complete to ensure the audit package would be complete and accurate. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This was a condition noted per review of National CASA/GAL’s compliance with the specified requirements. The submission was due September 30, 2023. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL closely monitor and comply with the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials: Management concurs that the reporting package was not submitted to the Federal Audit Clearinghouse within the deadline. Management determined as a site visit by the Office of Juvenile Justice and Delinquency Prevention (OJJDP)/Office of the Chief Financial Officer (OCFO) and subsequent resolution of findings was in process, a delay in the report was necessary to ensure statements were complete and accurate. Management asserts compliance with the deadline is expected in future periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR §200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period. Condition: National CASA/GAL did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2022. Cause: National CASA/GAL did not submit to the FAC within the required timeframe as the Department of Justice’s site visit and findings remediation was in progress through April 2024. Management elected to defer completion of the audit until the site visit was complete to ensure the audit package would be complete and accurate. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This was a condition noted per review of National CASA/GAL’s compliance with the specified requirements. The submission was due September 30, 2023. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that National CASA/GAL closely monitor and comply with the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Views of Responsible Officials: Management concurs that the reporting package was not submitted to the Federal Audit Clearinghouse within the deadline. Management determined as a site visit by the Office of Juvenile Justice and Delinquency Prevention (OJJDP)/Office of the Chief Financial Officer (OCFO) and subsequent resolution of findings was in process, a delay in the report was necessary to ensure statements were complete and accurate. Management asserts compliance with the deadline is expected in future periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the federal awarding agency. Unless the federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions. Condition: National CASA/GAL allocated expenditures to the grant during and after the funding period. During our testing of costs, we noted the below: For Court Appointed Special Advocates: • Three of 136 transactions were either fully or partially incurred after the grant period. • 22 of 136 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For Juvenile Mentoring Program: • 27 of 97 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs through the journal entry process. Effect or Potential Effect: Without consistent application of the controls in place to ensure costs are allowable and reimbursable, and properly recognized based on the date of incurrence, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. For the Court Appointed Special Advocates Program, 16 transactions totaling to $85,362 in costs incurred at the end of the period of performance were tested from a population of 43 transactions totaling to $150,874. Three transactions with costs incurred outside the period of performance were identified totaling $4,917. Additionally, 120 transactions (60 payroll and 60 non-payroll) were tested from populations of expenditures incurred throughout 2022. Of these, 22 non-payroll transactions, totaling to $15,405, were identified, which lacked documentation of review and approval of the allocation of costs made through journal entries. One non-payroll transaction of $95 was identified lacking relevant supporting documentation. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed. Views of Responsible Officials: Management concurs with the finding that costs were incurred outside the appropriate funding period. Management will produce and maintain documentation supporting the review and approval of the funding period associated with costs incurred and their proper inclusion in the applicable period. Management will update policies and procedures to periodically review subrecipient details to ensure compliance with funding periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the federal awarding agency. Unless the federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions. Condition: National CASA/GAL allocated expenditures to the grant during and after the funding period. During our testing of costs, we noted the below: For Court Appointed Special Advocates: • Three of 136 transactions were either fully or partially incurred after the grant period. • 22 of 136 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For Juvenile Mentoring Program: • 27 of 97 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs through the journal entry process. Effect or Potential Effect: Without consistent application of the controls in place to ensure costs are allowable and reimbursable, and properly recognized based on the date of incurrence, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. For the Court Appointed Special Advocates Program, 16 transactions totaling to $85,362 in costs incurred at the end of the period of performance were tested from a population of 43 transactions totaling to $150,874. Three transactions with costs incurred outside the period of performance were identified totaling $4,917. Additionally, 120 transactions (60 payroll and 60 non-payroll) were tested from populations of expenditures incurred throughout 2022. Of these, 22 non-payroll transactions, totaling to $15,405, were identified, which lacked documentation of review and approval of the allocation of costs made through journal entries. One non-payroll transaction of $95 was identified lacking relevant supporting documentation. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed. Views of Responsible Officials: Management concurs with the finding that costs were incurred outside the appropriate funding period. Management will produce and maintain documentation supporting the review and approval of the funding period associated with costs incurred and their proper inclusion in the applicable period. Management will update policies and procedures to periodically review subrecipient details to ensure compliance with funding periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the federal awarding agency. Unless the federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions. Condition: National CASA/GAL allocated expenditures to the grant during and after the funding period. During our testing of costs, we noted the below: For Court Appointed Special Advocates: • Three of 136 transactions were either fully or partially incurred after the grant period. • 22 of 136 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For Juvenile Mentoring Program: • 27 of 97 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs through the journal entry process. Effect or Potential Effect: Without consistent application of the controls in place to ensure costs are allowable and reimbursable, and properly recognized based on the date of incurrence, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. For the Court Appointed Special Advocates Program, 16 transactions totaling to $85,362 in costs incurred at the end of the period of performance were tested from a population of 43 transactions totaling to $150,874. Three transactions with costs incurred outside the period of performance were identified totaling $4,917. Additionally, 120 transactions (60 payroll and 60 non-payroll) were tested from populations of expenditures incurred throughout 2022. Of these, 22 non-payroll transactions, totaling to $15,405, were identified, which lacked documentation of review and approval of the allocation of costs made through journal entries. One non-payroll transaction of $95 was identified lacking relevant supporting documentation. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed. Views of Responsible Officials: Management concurs with the finding that costs were incurred outside the appropriate funding period. Management will produce and maintain documentation supporting the review and approval of the funding period associated with costs incurred and their proper inclusion in the applicable period. Management will update policies and procedures to periodically review subrecipient details to ensure compliance with funding periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: Where a funding period is specified, a recipient may charge to the grant only allowable costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the federal awarding agency. Unless the federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions. Condition: National CASA/GAL allocated expenditures to the grant during and after the funding period. During our testing of costs, we noted the below: For Court Appointed Special Advocates: • Three of 136 transactions were either fully or partially incurred after the grant period. • 22 of 136 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. For Juvenile Mentoring Program: • 27 of 97 transactions lacked documentation of review and approval of the allocation of costs made through journal entries. Cause: National CASA/GAL did not have procedures in place to document, and maintain the documentation of, the review and approval of the allocation methodology and the allocation of costs through the journal entry process. Effect or Potential Effect: Without consistent application of the controls in place to ensure costs are allowable and reimbursable, and properly recognized based on the date of incurrence, National CASA/GAL could incorrectly charge expenditures to the federal programs. Questioned Costs Court Appointed Special Advocates: Below reporting threshold. Questioned Costs Juvenile Mentoring Program: None. Context: This is a condition identified per review of National CASA/GAL’s compliance with specified requirements not using a statistically valid sample. For the Court Appointed Special Advocates Program, 16 transactions totaling to $85,362 in costs incurred at the end of the period of performance were tested from a population of 43 transactions totaling to $150,874. Three transactions with costs incurred outside the period of performance were identified totaling $4,917. Additionally, 120 transactions (60 payroll and 60 non-payroll) were tested from populations of expenditures incurred throughout 2022. Of these, 22 non-payroll transactions, totaling to $15,405, were identified, which lacked documentation of review and approval of the allocation of costs made through journal entries. One non-payroll transaction of $95 was identified lacking relevant supporting documentation. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that only costs incurred during the appropriate funding period be charged, and that this be appropriately documented and reviewed. Views of Responsible Officials: Management concurs with the finding that costs were incurred outside the appropriate funding period. Management will produce and maintain documentation supporting the review and approval of the funding period associated with costs incurred and their proper inclusion in the applicable period. Management will update policies and procedures to periodically review subrecipient details to ensure compliance with funding periods.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-federal entity is responsible for complying with all requirements of the federal award. For all federal awards, this includes the provisions of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “FFATA,” that are codified in 2 CFR Part 170, which includes requirements on executive compensation, and also requirements implementing the Act for the non-federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management, and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, National CASA/GAL is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: During our testing of reporting, we selected 12 subrecipient awards within Court Appointed Special Advocates and 16 subrecipient awards within the Juvenile Mentoring Program that were subject to FFATA. Within the Court Appointed Special Advocates, 10 out of 12 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For all samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Within the Juvenile Mentoring Program, 14 out of 16 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For seven samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Cause: National CASA/GAL did not follow the documented policies and procedures to ensure compliance with the FFATA filing requirements. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This is a condition identified based upon our review of National CASA/GAL’s compliance with specified requirements. For the Court Appointed Special Advocates Program, nine out of 12 awards subject to FFATA selected for testing were submitted within one month of the required submission date. One out of 12 awards was submitted within three months of the required submission date. For the Juvenile Mentoring Program, nine out of 16 awards subject to FFATA selected for testing were submitted within one month of the required submission date. Five out of 16 awards were submitted within one month of the required submission date. The sample was selected based on a non-statistical basis. The prevalence of these is detailed in the condition section above. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that reports are submitted timely with proper control procedures in place to ensure compliance with 2 CFR Section 200.303. Views of Responsible Officials: Management concurs with this finding. Management will add additional procedures to verify the appropriateness of submitted subrecipient information within their FFATA reporting packet. Management will additionally ensure FFATA reports are submitted within the required timeline.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-federal entity is responsible for complying with all requirements of the federal award. For all federal awards, this includes the provisions of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “FFATA,” that are codified in 2 CFR Part 170, which includes requirements on executive compensation, and also requirements implementing the Act for the non-federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management, and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, National CASA/GAL is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: During our testing of reporting, we selected 12 subrecipient awards within Court Appointed Special Advocates and 16 subrecipient awards within the Juvenile Mentoring Program that were subject to FFATA. Within the Court Appointed Special Advocates, 10 out of 12 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For all samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Within the Juvenile Mentoring Program, 14 out of 16 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For seven samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Cause: National CASA/GAL did not follow the documented policies and procedures to ensure compliance with the FFATA filing requirements. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This is a condition identified based upon our review of National CASA/GAL’s compliance with specified requirements. For the Court Appointed Special Advocates Program, nine out of 12 awards subject to FFATA selected for testing were submitted within one month of the required submission date. One out of 12 awards was submitted within three months of the required submission date. For the Juvenile Mentoring Program, nine out of 16 awards subject to FFATA selected for testing were submitted within one month of the required submission date. Five out of 16 awards were submitted within one month of the required submission date. The sample was selected based on a non-statistical basis. The prevalence of these is detailed in the condition section above. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that reports are submitted timely with proper control procedures in place to ensure compliance with 2 CFR Section 200.303. Views of Responsible Officials: Management concurs with this finding. Management will add additional procedures to verify the appropriateness of submitted subrecipient information within their FFATA reporting packet. Management will additionally ensure FFATA reports are submitted within the required timeline.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-federal entity is responsible for complying with all requirements of the federal award. For all federal awards, this includes the provisions of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “FFATA,” that are codified in 2 CFR Part 170, which includes requirements on executive compensation, and also requirements implementing the Act for the non-federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management, and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, National CASA/GAL is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: During our testing of reporting, we selected 12 subrecipient awards within Court Appointed Special Advocates and 16 subrecipient awards within the Juvenile Mentoring Program that were subject to FFATA. Within the Court Appointed Special Advocates, 10 out of 12 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For all samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Within the Juvenile Mentoring Program, 14 out of 16 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For seven samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Cause: National CASA/GAL did not follow the documented policies and procedures to ensure compliance with the FFATA filing requirements. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This is a condition identified based upon our review of National CASA/GAL’s compliance with specified requirements. For the Court Appointed Special Advocates Program, nine out of 12 awards subject to FFATA selected for testing were submitted within one month of the required submission date. One out of 12 awards was submitted within three months of the required submission date. For the Juvenile Mentoring Program, nine out of 16 awards subject to FFATA selected for testing were submitted within one month of the required submission date. Five out of 16 awards were submitted within one month of the required submission date. The sample was selected based on a non-statistical basis. The prevalence of these is detailed in the condition section above. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that reports are submitted timely with proper control procedures in place to ensure compliance with 2 CFR Section 200.303. Views of Responsible Officials: Management concurs with this finding. Management will add additional procedures to verify the appropriateness of submitted subrecipient information within their FFATA reporting packet. Management will additionally ensure FFATA reports are submitted within the required timeline.

Federal Agency: Department of Justice Federal Assistance Listing Numbers: 16.756, 16.726 Programs: Court Appointed Special Advocates, Juvenile Mentoring Program Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028 Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-federal entity is responsible for complying with all requirements of the federal award. For all federal awards, this includes the provisions of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “FFATA,” that are codified in 2 CFR Part 170, which includes requirements on executive compensation, and also requirements implementing the Act for the non-federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management, and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, National CASA/GAL is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: During our testing of reporting, we selected 12 subrecipient awards within Court Appointed Special Advocates and 16 subrecipient awards within the Juvenile Mentoring Program that were subject to FFATA. Within the Court Appointed Special Advocates, 10 out of 12 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For all samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Within the Juvenile Mentoring Program, 14 out of 16 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For seven samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions. Cause: National CASA/GAL did not follow the documented policies and procedures to ensure compliance with the FFATA filing requirements. Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies. Questioned Costs: None. Context: This is a condition identified based upon our review of National CASA/GAL’s compliance with specified requirements. For the Court Appointed Special Advocates Program, nine out of 12 awards subject to FFATA selected for testing were submitted within one month of the required submission date. One out of 12 awards was submitted within three months of the required submission date. For the Juvenile Mentoring Program, nine out of 16 awards subject to FFATA selected for testing were submitted within one month of the required submission date. Five out of 16 awards were submitted within one month of the required submission date. The sample was selected based on a non-statistical basis. The prevalence of these is detailed in the condition section above. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that reports are submitted timely with proper control procedures in place to ensure compliance with 2 CFR Section 200.303. Views of Responsible Officials: Management concurs with this finding. Management will add additional procedures to verify the appropriateness of submitted subrecipient information within their FFATA reporting packet. Management will additionally ensure FFATA reports are submitted within the required timeline.