Audit 352321

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency. Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-002. Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days. Questioned costs: None Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: Amounts received in advance were not consistently spent within the 30 days per the requirement. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency. Questioned costs: None Context: Indirect Allocations In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on. Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff. Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.

Federal Agency: Department of Justice Federal Program Name: Services for Victims of Human Trafficking Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003, 15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT, 15POVC-21-GG-03694-HT, and 2020-HT-OVC-614 Award Period: October 1, 2020 through September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. Condition: During our testing it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Questioned costs: None Context: In a sample of 1, it was noted that the Organization did not retain support to demonstrate that suspension and debarment was reviewed. Cause: The Organization was in its startup phases and the Uniform Grant Requirements had not been tested previously. Support for suspension and debarment review was retained for some vendors, but not all of them. Effect or potential effect: The contractor tested was not suspended or debarred however, the deficiency in internal controls provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the Organization retain support of suspension and debarment checks for each vendor to support the written policy is implemented and the Uniform Grant Requirements are being followed. Views of responsible officials: We agreed with the above comment.