FAC Explorer

Audit 323222

FY End
2023-12-31
Total Expended
$21.70M
Findings
40
Programs
17
Organization: Search for Common Ground (DC)
Year: 2023 Accepted: 2024-09-30
Auditor: Bdo USA LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
500905 2023-002 Significant Deficiency - C
500906 2023-002 Significant Deficiency - C
500907 2023-002 Significant Deficiency - C
500908 2023-002 Significant Deficiency - C
500909 2023-002 Significant Deficiency - C
500910 2023-002 Significant Deficiency - C
500911 2023-002 Significant Deficiency - C
500912 2023-002 Significant Deficiency - C
500913 2023-002 Significant Deficiency - C
500914 2023-002 Significant Deficiency - C
500915 2023-002 Significant Deficiency - C
500916 2023-002 Significant Deficiency - C
500917 2023-002 Significant Deficiency - C
500918 2023-003 Significant Deficiency Yes I
500919 2023-003 Significant Deficiency Yes I
500920 2023-003 Significant Deficiency Yes I
500921 2023-003 Significant Deficiency Yes I
500922 2023-003 Significant Deficiency Yes I
500923 2023-003 Significant Deficiency Yes I
500924 2023-003 Significant Deficiency Yes I
1077347 2023-002 Significant Deficiency - C
1077348 2023-002 Significant Deficiency - C
1077349 2023-002 Significant Deficiency - C
1077350 2023-002 Significant Deficiency - C
1077351 2023-002 Significant Deficiency - C
1077352 2023-002 Significant Deficiency - C
1077353 2023-002 Significant Deficiency - C
1077354 2023-002 Significant Deficiency - C
1077355 2023-002 Significant Deficiency - C
1077356 2023-002 Significant Deficiency - C
1077357 2023-002 Significant Deficiency - C
1077358 2023-002 Significant Deficiency - C
1077359 2023-002 Significant Deficiency - C
1077360 2023-003 Significant Deficiency Yes I
1077361 2023-003 Significant Deficiency Yes I
1077362 2023-003 Significant Deficiency Yes I
1077363 2023-003 Significant Deficiency Yes I
1077364 2023-003 Significant Deficiency Yes I
1077365 2023-003 Significant Deficiency Yes I
1077366 2023-003 Significant Deficiency Yes I

Programs

ALN Program Spent Major Findings
19.801 Office of Global Women's Issues $2.04M - 0
97.132 Financial Assistance for Targeted Violence and Terrorism Prevention $621,603 Yes 2
19.517 Overseas Refugee Assistance Programs for Africa $350,094 Yes 1
19.345 International Programs to Support Democracy, Human Rights and Labor $246,889 - 0
19.040 Public Diplomacy Programs $231,135 - 0
19.501 Public Diplomacy Programs for Afghanistan and Pakistan $225,072 - 0
19.415 Professional and Cultural Exchange Programs - Citizen Exchanges $172,805 - 0
19.700 General Department of State Assistance $132,993 - 0
19.706 Partnership for Regional East Africa Counterterrorism $122,904 - 0
98.001 Usaid Foreign Assistance for Programs Overseas $61,900 Yes 0
93.308 National Institute on Minority Health and Health Disparities (nimhd) Extramural Loan Repayment Program $53,574 - 0
19.225 Africa Regional Democracy Fund $2,309 - 0
19.979 Regional Peace and Security $-649 - 0
19.121 Conflict and Stabilization Operations $-7,932 - 0
19.021 Investing in People in the Middle East and North Africa $-17,521 - 0
19.701 Global Counterterrorism Programs $-24,469 - 0
19.016 Iraq Assistance Program $-77,578 - 0

Contacts

Name Title Type
HB7NVH9YCEH1 Wasim Khan Auditee
2027947014 Matt Cromwell Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. Pass-through entity identifying numbers are presented where available. The reimbursement of indirect costs reflected in the accompanying consolidated financial statements as federal grants revenue is subject to final approval by federal grantors and could be adjusted upon the results of these reviews. Management believes that the results of any such adjustment will not be material to the Organization’s consolidated financial position or change in net assets. All of the Organization’s federal awards were in the form of cash assistance for the year ended December 31, 2023. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (Schedule) includes the federal award activity of Search for Common Ground and Subsidiaries (the “Organization”) under programs of the federal government for the year ended December 31, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Organization, it is not intended to and does not present the consolidated financial position, changes in net assets or cash flows of the Organization.
Title: Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. Pass-through entity identifying numbers are presented where available. The reimbursement of indirect costs reflected in the accompanying consolidated financial statements as federal grants revenue is subject to final approval by federal grantors and could be adjusted upon the results of these reviews. Management believes that the results of any such adjustment will not be material to the Organization’s consolidated financial position or change in net assets. All of the Organization’s federal awards were in the form of cash assistance for the year ended December 31, 2023. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. Pass-through entity identifying numbers are presented where available. The reimbursement of indirect costs reflected in the accompanying consolidated financial statements as federal grants revenue is subject to final approval by federal grantors and could be adjusted upon the results of these reviews. Management believes that the results of any such adjustment will not be material to the Organization’s consolidated financial position or change in net assets. All of the Organization’s federal awards were in the form of cash assistance for the year ended December 31, 2023.
Title: Indirect Cost Rate Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. Pass-through entity identifying numbers are presented where available. The reimbursement of indirect costs reflected in the accompanying consolidated financial statements as federal grants revenue is subject to final approval by federal grantors and could be adjusted upon the results of these reviews. Management believes that the results of any such adjustment will not be material to the Organization’s consolidated financial position or change in net assets. All of the Organization’s federal awards were in the form of cash assistance for the year ended December 31, 2023. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The Organization has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance.

Finding Details

Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-002
2023-002 Internal Control over Compliance and Compliance with Cash Management Information on the Federal Program(s): United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023 FHI 360 PO22001322 March 15, 2022 through February 29, 2024 Education Development Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026 Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025 Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023 Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024 Freedom House 7200-AA-21-LA-00004 September 1, 2023 through December 31, 2023 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023   United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024 World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023 Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS). Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest. Questioned Costs: None. Context: The nature of these findings is detailed in the condition section above. Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year. Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required. Repeat Finding: This finding is not a repeat finding from prior year. Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances. Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-003
2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Pass-through Award(s): Pass-through Entity Pass-through Award Number Award Period Freedom House AID-OAA-A-16-00044 October 1, 2016 through June 30, 2023 Freedom House 720-68520-LA-00002 September 15, 2020 through September 14, 2024 Freedom House 720-482-21-LA-00001 October 11 2021 through December 31, 2023 Freedom House 7200-AA-21-LA-00004 November 1, 2022 through January 15, 2024 Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023 National Democratic Institute 21-20547-SUD.0-1900 October 15, 2020 through August 31, 2024 United States Department of Homeland Security Assistance Listing Number: 97.132 Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention Award Number: Direct Award Number Award Period EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023 Criteria or Specific Requirement: In accordance with §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that 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 a manner providing full and open competition consistent in accordance with §200.319 and must be performed using the appropriate procurement method as outlined in §200.320. In accordance with §200.320(c), Noncompetitive Procurement, there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of procurement compliance requirement, we tested a total of twenty-five procurement transactions for assistance listing number 98.001. We identified the following matters: • For five procurement transactions, the Organization did not maintain any support they verified the vendor was not suspended or debarred prior to entering into the covered transaction. • For two procurements tested, the Organization procured goods from a vendor without full and open competition. During our testing of subrecipient monitoring compliance requirement, we tested a total of two subrecipient agreements for assistance listing number 97.132. In both instances the Organization performed the suspension and debarment check after entering into the covered transaction. The Organization did however perform the check prior to making any payments to either subrecipient. Cause: In the instances identified, the Organization was unable to provide complete documentation of the history of the procurement, and for ensuring proper suspension and debarment validations were performed. Effect: Failure to perform procurement procedures in accordance with a written policy that complies with Procurement Procedures as outlined in the Uniform Administrative Requirements could result in the procurement being disallowed. Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the U.S. government. Questioned Costs: Total known questioned costs are $44,539. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Repeat Finding: This finding is a repeat finding from prior year. This was reported as finding 2022-004 in the 2022 schedule of findings and questioned costs. Recommendation: We recommend management reinforce the procurement policy that complies with the Procurement Procedures as outlined in the Uniform Administrative Requirements. We recommend that all staff are provided additional training on this policy to help ensure compliance going forward. Views of Responsible Officials: The Organization’s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.