Finding 2022-001: Material weakness in internal controls over compliance for earmarking and material
noncompliance for earmarking in the U.S. Refugee Admissions Program:
Criteria or Specific Requirements:
The underlying awards identify an earmarking requirement requiring thresholds of direct assistance to be
provided on behalf of each eligible arriving refugee. Award number SPRMCO21CA3005 and
SPRMCO22CA0025 states that at least $1,225 will be used to cover payments made to or on behalf of a
refugee for cash disbursements or material goods, as needed, to meet the program's requirements. No
less than $1,025 of this $1,225 must be spent for or on behalf of each refugee during that refugee's
reception and replacement (R&P) and Afghan placement and assistance (APA) program service delivery
period. Up to $200 of this $1,225 may be pooled into a flexible fund to spend on behalf of other
vulnerable refugees assigned to the same affiliate/sub-office who have unmet needs during their R&P
period (within 90 days of the refugee’s arrival date). Award number 323-23-00 states at least $1,275 is to
be used to cover payments made to or on behalf of refugees for cash disbursements or for material
goods, as needed, to meet the program's requirements. No less than $1,075 of this $1,275 must be
spent for or on behalf of each refugee during that refugee reception and replacement (R&P) service
delivery period. Up to $200 of this $1,275 may be pooled into a flexible fund to spend on behalf of other
vulnerable refugees assigned to the same affiliate/sub-office with unmet needs during their R&P period
(within 90 days of the refugee’s arrival date).
Conditions:
During the testing, 11 Out of 24 sample tests did not meet the minimum spending requirement within 90
days of the refugee's arrival date.
Cause:
Internal controls were not in place to ensure earmarking requirements were met.
Effect:
The Organization may not have met earmarking requirements outlined in the underlying award
agreements nor have controls to monitor that earmarking requirements were met effectively.
Questioned costs:
None.
Auditor's Recommendation:
We recommend that the Organization implement a process to identify the value of direct assistance
provided to each eligible refugee as recorded within the financial records. Further, we recommend that
internal controls over compliance be implemented to monitor direct aid distribution and meet the
earmarking requirements included within the grant terms.
Finding 2022-002: Eligibility (Material weakness in Compliance, Internal Control, and Service Provision
within the APA Program):
Criteria or Specific Requirements:
According to the CFDA #19.510 guidelines, only refugees enrolled in the APA/R&P program are eligible
for funding, and lawful permanent residents do not qualify. Additionally, accurate and complete
documentation is required to support eligibility determinations and ensure program compliance. Proper
record-keeping is essential for transparency, accountability, and program integrity.
Conditions:
During our testwork over eligibility for the APA/R&P program, we noted the following exceptions:
1. Ineligible refugees received funding in 7 out of 25 samples tested (28%). These refugees were not
enrolled in the APA/R&P program, yet they were provided with APA/R&P program funding.
2. A lawful permanent resident received funding in 1 out of 25 samples tested (4%). The Organization
incorrectly provided APA/R&P program funding to this individual.
Additionally, the review process identified discrepancies in case notes, incomplete financial logs, and
inaccurately completed cultural orientation forms.
Cause:
The Organization did not adequately verify refugee enrollment status and did not properly exclude lawful
permanent residents from receiving APA/R&P program funding.
Effect:
The Organization provided APA/R&P program funding to ineligible refugees and lawful permanent
residents due to inadequate verification and inconsistent documentation practices.
Questioned costs:
None.
Recommendation:
The Organization should enhance its eligibility verification process to ensure that only enrolled refugees
receive funding. Implementing regular training for staff and updating guidelines will help maintain
accurate and complete documentation, ensuring compliance and maximizing the effectiveness of the
APA/R&P program.
Finding 2022-003: Internal Controls and Compliance over Reporting (Significant Deficiency)
Criteria or Specific Requirements:
The HIAS agreements require the Sub-Grantee of the Afghan Placement & Assistance Program (APA)
(19.510) to submit monthly APA arrival and expenditure reports by the 15th of the following month.
Also, in accordance with Uniform Guidance 2 CFR 200.512(a), recipients must submit a data collection
form that states whether the audit was completed in accordance with this part and provides information
about the auditee, its federal programs, and the results of the audit submitted within the earlier of 30 days
after the receipt of the audit report or nine months after the end of the audit period.
Conditions:
The Organization did not submit the quarterly reports within the specified time frame in accordance with
the HIAS agreements.
Additionally, the Organization did not comply with the required submission date of the data collection
form and reporting package to the FAC for the fiscal year ending June 30, 2022.
Cause:
Lack of sufficient internal controls and procedures over the reporting process to ensure timely and
accurate reporting.
Effect:
The Organization was not in compliance with the reporting requirements, federal regulations, and
guidelines, and it could be exposed to a reduction or elimination of funds by the federal awarding
agencies.
Questioned costs:
None.
Auditor's Recommendation:
We recommend that the Organization evaluate its policies and procedures regarding report submission
to ensure the timely submission of all compliance reports. In addition, the Organization should maintain
documentation to support the appropriate and timely submission of the single audit (SF-SAC form).
Finding 2022-001: Material weakness in internal controls over compliance for earmarking and material
noncompliance for earmarking in the U.S. Refugee Admissions Program:
Criteria or Specific Requirements:
The underlying awards identify an earmarking requirement requiring thresholds of direct assistance to be
provided on behalf of each eligible arriving refugee. Award number SPRMCO21CA3005 and
SPRMCO22CA0025 states that at least $1,225 will be used to cover payments made to or on behalf of a
refugee for cash disbursements or material goods, as needed, to meet the program's requirements. No
less than $1,025 of this $1,225 must be spent for or on behalf of each refugee during that refugee's
reception and replacement (R&P) and Afghan placement and assistance (APA) program service delivery
period. Up to $200 of this $1,225 may be pooled into a flexible fund to spend on behalf of other
vulnerable refugees assigned to the same affiliate/sub-office who have unmet needs during their R&P
period (within 90 days of the refugee’s arrival date). Award number 323-23-00 states at least $1,275 is to
be used to cover payments made to or on behalf of refugees for cash disbursements or for material
goods, as needed, to meet the program's requirements. No less than $1,075 of this $1,275 must be
spent for or on behalf of each refugee during that refugee reception and replacement (R&P) service
delivery period. Up to $200 of this $1,275 may be pooled into a flexible fund to spend on behalf of other
vulnerable refugees assigned to the same affiliate/sub-office with unmet needs during their R&P period
(within 90 days of the refugee’s arrival date).
Conditions:
During the testing, 11 Out of 24 sample tests did not meet the minimum spending requirement within 90
days of the refugee's arrival date.
Cause:
Internal controls were not in place to ensure earmarking requirements were met.
Effect:
The Organization may not have met earmarking requirements outlined in the underlying award
agreements nor have controls to monitor that earmarking requirements were met effectively.
Questioned costs:
None.
Auditor's Recommendation:
We recommend that the Organization implement a process to identify the value of direct assistance
provided to each eligible refugee as recorded within the financial records. Further, we recommend that
internal controls over compliance be implemented to monitor direct aid distribution and meet the
earmarking requirements included within the grant terms.
Finding 2022-002: Eligibility (Material weakness in Compliance, Internal Control, and Service Provision
within the APA Program):
Criteria or Specific Requirements:
According to the CFDA #19.510 guidelines, only refugees enrolled in the APA/R&P program are eligible
for funding, and lawful permanent residents do not qualify. Additionally, accurate and complete
documentation is required to support eligibility determinations and ensure program compliance. Proper
record-keeping is essential for transparency, accountability, and program integrity.
Conditions:
During our testwork over eligibility for the APA/R&P program, we noted the following exceptions:
1. Ineligible refugees received funding in 7 out of 25 samples tested (28%). These refugees were not
enrolled in the APA/R&P program, yet they were provided with APA/R&P program funding.
2. A lawful permanent resident received funding in 1 out of 25 samples tested (4%). The Organization
incorrectly provided APA/R&P program funding to this individual.
Additionally, the review process identified discrepancies in case notes, incomplete financial logs, and
inaccurately completed cultural orientation forms.
Cause:
The Organization did not adequately verify refugee enrollment status and did not properly exclude lawful
permanent residents from receiving APA/R&P program funding.
Effect:
The Organization provided APA/R&P program funding to ineligible refugees and lawful permanent
residents due to inadequate verification and inconsistent documentation practices.
Questioned costs:
None.
Recommendation:
The Organization should enhance its eligibility verification process to ensure that only enrolled refugees
receive funding. Implementing regular training for staff and updating guidelines will help maintain
accurate and complete documentation, ensuring compliance and maximizing the effectiveness of the
APA/R&P program.
Finding 2022-003: Internal Controls and Compliance over Reporting (Significant Deficiency)
Criteria or Specific Requirements:
The HIAS agreements require the Sub-Grantee of the Afghan Placement & Assistance Program (APA)
(19.510) to submit monthly APA arrival and expenditure reports by the 15th of the following month.
Also, in accordance with Uniform Guidance 2 CFR 200.512(a), recipients must submit a data collection
form that states whether the audit was completed in accordance with this part and provides information
about the auditee, its federal programs, and the results of the audit submitted within the earlier of 30 days
after the receipt of the audit report or nine months after the end of the audit period.
Conditions:
The Organization did not submit the quarterly reports within the specified time frame in accordance with
the HIAS agreements.
Additionally, the Organization did not comply with the required submission date of the data collection
form and reporting package to the FAC for the fiscal year ending June 30, 2022.
Cause:
Lack of sufficient internal controls and procedures over the reporting process to ensure timely and
accurate reporting.
Effect:
The Organization was not in compliance with the reporting requirements, federal regulations, and
guidelines, and it could be exposed to a reduction or elimination of funds by the federal awarding
agencies.
Questioned costs:
None.
Auditor's Recommendation:
We recommend that the Organization evaluate its policies and procedures regarding report submission
to ensure the timely submission of all compliance reports. In addition, the Organization should maintain
documentation to support the appropriate and timely submission of the single audit (SF-SAC form).