Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: In review of budget to actual expenditure amounts for the year under audit, the auditor noted two line items that
exceeded the allowed budget amount for the year. While a budget amendment was completed for these line
items, one line still exceeded the allowable budget amount.
Criteria: Annual budgets are approved by the grantor agency and amendments must be submitted for approval to alter
the original budget if needed. Cause: For two line items, the original budget as approved was exceeded. Additionally, for one of those two line items,
even though an amendment was submitted, the budget was still exceeded. It appears that monitoring is not
sufficient to prevent budget overages from occurring, nor to detect them timely to rectify the grantor.
Effect: enCircle violated their grant terms by exceeding their approved budget.
Questioned Cost Amount: $886.24
Recommendation: Management should implement procedures that allow for proper reviews of budget to actual information for
grants to verify amounts expended and amounts remaining for expenditure monthly. Additionally, grant
management personnel and financial personnel need to work on better communication regarding financial status
of grants. Views of Responsible Officials and Planned Corrective Action: During the monthly billing process, enCircle will now only bill up until the approved budget even if there are
allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget
amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly
billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed
expenditures.
enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel
remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the
meeting cycle to create sufficient communication including other means (Teams chats, etc…)
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: During our testing of 25 disbursements for the program, we noted one disbursement for which an invoice or
receipt from a third party vendor could not be provided. The only support provided was the excel allocation to
various areas. We also noted 2 instances where children in foster care received more than the $150 clothing
allowance, including the purchase of $200 gift cards in addition to other items in both instances. In the final issue
in our sample of 25, we noted toys included with a clothing purchase. Toys should not be included in clothing
allowances per grant guidelines. Our testing noted three instances where gift cards were not well tracked to
ensure they were properly given to foster families and subsequently used for clothing.
Criteria: All disbursements should be properly supported by adequate documentation, made within program established
guidelines. Cause: Documented allowance for clothing was not followed in 2 instances tested. Support was not maintained for one
disbursement tested. Unallowed items were purchased in one disbursement tested.
Effect: Disbursements that weren’t allowable under the program were made in several instances because amounts
exceeded allowed thresholds or for an unallowed item. Additionally, an unsupported item could not be verified
for allowability due to lack of details as to what was purchased.
Questioned Cost Amount: $2,777.78 from the sample tested and projected to be approximately $94,000 of the total expenditures.
Perspective Information: 5 of 25 items selected for testing
Recommendation: We recommend that stronger reviews and oversight is put in place to make sure that allowances for clothing are
followed for all children in foster care. Additionally, if the program is going to continue use of gift cards as a means
of providing funds for clothing purchases, then receipts for the use of those funds should be received to verify
they were spent appropriately and controls over unspent gift cards must be put in place.
Views of Responsible Officials and Planned Corrective Action: enCircle has communicated to grant management personnel the requirements regarding clothing allowances,
especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely
identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card
purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or
the cash value remaining).
enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of
transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.