FAC Explorer

Audit 356152

FY End
2024-09-30
Total Expended
$723.46M
Findings
78
Programs
82
Organization: International Rescue Committee, Inc. (NY)
Year: 2024 Accepted: 2025-05-13
Auditor: Kpmg LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
560216 2024-001 Significant Deficiency - L
560217 2024-002 Significant Deficiency - B
560218 2024-002 Significant Deficiency - B
560219 2024-002 Significant Deficiency - B
560220 2024-002 Significant Deficiency - B
560221 2024-002 Significant Deficiency - B
560222 2024-002 Significant Deficiency - B
560223 2024-002 Significant Deficiency - B
560224 2024-002 Significant Deficiency - B
560225 2024-002 Significant Deficiency - B
560226 2024-002 Significant Deficiency - B
560227 2024-002 Significant Deficiency - B
560228 2024-002 Significant Deficiency - B
560229 2024-002 Significant Deficiency - B
560230 2024-002 Significant Deficiency - B
560231 2024-002 Significant Deficiency - B
560232 2024-002 Significant Deficiency - B
560233 2024-002 Significant Deficiency - B
560234 2024-002 Significant Deficiency - B
560235 2024-002 Significant Deficiency - B
560236 2024-002 Significant Deficiency - B
560237 2024-002 Significant Deficiency - B
560238 2024-002 Significant Deficiency - B
560239 2024-002 Significant Deficiency - B
560240 2024-002 Significant Deficiency - B
560241 2024-002 Significant Deficiency - B
560242 2024-002 Significant Deficiency - B
560243 2024-002 Significant Deficiency - B
560244 2024-002 Significant Deficiency - B
560245 2024-002 Significant Deficiency - B
560246 2024-002 Significant Deficiency - B
560247 2024-002 Significant Deficiency - B
560248 2024-002 Significant Deficiency - B
560249 2024-002 Significant Deficiency - B
560250 2024-002 Significant Deficiency - B
560251 2024-002 Significant Deficiency - B
560252 2024-002 Significant Deficiency - B
560253 2024-002 Significant Deficiency - B
560254 2024-001 Significant Deficiency - L
1136658 2024-001 Significant Deficiency - L
1136659 2024-002 Significant Deficiency - B
1136660 2024-002 Significant Deficiency - B
1136661 2024-002 Significant Deficiency - B
1136662 2024-002 Significant Deficiency - B
1136663 2024-002 Significant Deficiency - B
1136664 2024-002 Significant Deficiency - B
1136665 2024-002 Significant Deficiency - B
1136666 2024-002 Significant Deficiency - B
1136667 2024-002 Significant Deficiency - B
1136668 2024-002 Significant Deficiency - B
1136669 2024-002 Significant Deficiency - B
1136670 2024-002 Significant Deficiency - B
1136671 2024-002 Significant Deficiency - B
1136672 2024-002 Significant Deficiency - B
1136673 2024-002 Significant Deficiency - B
1136674 2024-002 Significant Deficiency - B
1136675 2024-002 Significant Deficiency - B
1136676 2024-002 Significant Deficiency - B
1136677 2024-002 Significant Deficiency - B
1136678 2024-002 Significant Deficiency - B
1136679 2024-002 Significant Deficiency - B
1136680 2024-002 Significant Deficiency - B
1136681 2024-002 Significant Deficiency - B
1136682 2024-002 Significant Deficiency - B
1136683 2024-002 Significant Deficiency - B
1136684 2024-002 Significant Deficiency - B
1136685 2024-002 Significant Deficiency - B
1136686 2024-002 Significant Deficiency - B
1136687 2024-002 Significant Deficiency - B
1136688 2024-002 Significant Deficiency - B
1136689 2024-002 Significant Deficiency - B
1136690 2024-002 Significant Deficiency - B
1136691 2024-002 Significant Deficiency - B
1136692 2024-002 Significant Deficiency - B
1136693 2024-002 Significant Deficiency - B
1136694 2024-002 Significant Deficiency - B
1136695 2024-002 Significant Deficiency - B
1136696 2024-001 Significant Deficiency - L

Programs

ALN Program Spent Major Findings
93.567 Refugee and Entrant Assistance Voluntary Agency Programs $20.37M - 0
93.067 Global Aids $8.05M Yes 0
97.141 Shelter and Services Program $2.95M - 0
19.518 Overseas Refugee Assistance Programs for Western Hemisphere $1.48M - 0
59.077 Community Navigator Pilot Program $1.36M - 0
10.234 American Rescue Plan Technical Assistance Investment Program $816,568 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $805,467 Yes 1
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $572,959 - 0
93.604 Assistance for Torture Victims $561,541 - 0
19.108 Bureau of South and Central Asian Affairs $519,255 - 0
19.223 South Sudan and Sudan Assistance Program $304,786 - 0
19.345 International Programs to Support Democracy, Human Rights and Labor $290,982 - 0
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $290,706 Yes 0
19.522 Overseas Refugee Assistance Programs for Strategic Global Priorities $276,851 - 0
59.050 Prime Technical Assistance $253,252 - 0
94.021 Americorps Volunteer Generation Fund 94.021 $230,393 - 0
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $208,051 - 0
16.582 Crime Victim Assistance/discretionary Grants $198,518 - 0
98.001 Usaid Foreign Assistance for Programs Overseas $195,052 Yes 0
19.519 Overseas Refugee Assistance Program for Middle East and North Africa Program $176,987 - 0
97.102 Case Management Pilot Program $172,982 - 0
19.523 Overseas Refugee Assistance Program for South Asia $167,813 - 0
10.902 Soil and Water Conservation $162,613 - 0
10.935 Urban Agriculture and Innovative Production $158,111 - 0
98.U03 Catalyze Capital Investment Platform $150,829 - 0
10.175 Farmers Market and Local Food Promotion Program $149,337 - 0
16.575 Crime Victim Assistance $139,533 - 0
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $136,337 - 0
82.002 Educational Exchange_university Lecturers (professors) and Research Scholars $133,755 - 0
84.287 Twenty-First Century Community Learning Centers $125,879 - 0
10.225 Community Food Projects $121,718 - 0
97.010 Citizenship Education and Training $110,350 - 0
84.002 Adult Education - Basic Grants to States $109,159 - 0
10.255 Research Innovation and Development Grants in Economic (ridge) $100,130 - 0
84.424 Student Support and Academic Enrichment Program $98,672 - 0
10.522 Food and Agriculture Service Learning Program $87,618 - 0
19.517 Overseas Refugee Assistance Programs for Africa $86,951 Yes 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $85,653 - 0
17.259 Wioa Youth Activities $72,402 - 0
93.495 Community Health Workers for Public Health Response and Resilient $70,264 - 0
93.676 Unaccompanied Children Program $64,539 Yes 0
93.327 Demonstration Grants for Domestic Victims of Human Trafficking $61,265 - 0
59.037 Small Business Development Centers $60,000 - 0
19.511 Overseas Refugee Assistance Programs for East Asia $58,511 - 0
10.182 Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments $53,141 - 0
10.170 Specialty Crop Block Grant Program - Farm Bill $51,928 - 0
21.023 Emergency Rental Assistance Program $43,499 - 0
93.569 Community Services Block Grant $42,500 - 0
10.551 Supplemental Nutrition Assistance Program $38,978 - 0
32.011 Affordable Connectivity Outreach Grant Program $38,616 - 0
10.215 Sustainable Agriculture Research and Education $37,239 - 0
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $28,766 - 0
19.510 U.s. Refugee Admissions Program $28,624 - 0
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $27,055 - 0
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $25,155 - 0
93.583 Refugee and Entrant Assistance Wilson/fish Program $24,468 - 0
93.598 Services to Victims of A Severe Form of Trafficking $19,981 - 0
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $19,586 - 0
84.425 Education Stabilization Fund $19,163 - 0
21.034 State Small Business Credit Initiative Competitive Technical Assistance Program $16,825 - 0
98.U01 Latin America and Caribbean Learning and Rapid Response Task Order (laclearn) $16,027 - 0
17.289 Community Project Funding/congressionally Directed Spending $15,000 - 0
93.283 Centers for Disease Control and Prevention Investigations and Technical Assistance $15,000 - 0
19.019 International Programs to Combat Human Trafficking $14,948 - 0
10.443 Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers $14,085 - 0
16.320 Services for Trafficking Victims $13,130 Yes 0
10.675 Urban and Community Forestry Program $11,412 - 0
93.575 Child Care and Development Block Grant $10,131 - 0
98.U02 Improving Learning Outcomes for Asia Mechanism (iloa) $8,650 - 0
93.493 Congressional Directives $5,899 - 0
97.024 Emergency Food and Shelter National Board Program $5,250 - 0
17.258 Wioa Adult Program $4,923 - 0
93.558 Temporary Assistance for Needy Families $4,281 - 0
10.331 Gus Schumacher Nutrition Incentive Program $4,124 - 0
10.575 Farm to School Grant Program $3,645 - 0
10.311 Beginning Farmer and Rancher Development Program $3,469 - 0
94.006 Americorps State and National 94.006 $571 - 0
93.584 Refugee and Entrant Assistance Targeted Assistance Grants $239 - 0
93.576 Refugee and Entrant Assistance Discretionary Grants $-43 - 0
14.218 Community Development Block Grants/entitlement Grants $-44 - 0
98.U04 2020-Catalyst-Ga016 Safe to Learn and Thrive Together $-3,424 - 0
93.556 Marylee Allen Promoting Safe and Stable Families Program $-155,057 - 0

Contacts

Name Title Type
VYJKCDDX9G95 Rick Estridge Auditee
4438900915 Shelly Masi Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: The accompanying schedule of expenditures of federal awards presents the federal awards activity (including indirect cost recovery amounts) of International Rescue Committee, Inc. and its subsidiaries (IRC) for the year ended September 30, 2024. This schedule includes federal awards passed through states and other agencies and is prepared on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of IRC’s consolidated financial statements. De Minimis Rate Used: N Rate Explanation: In connection with its ongoing relationship with USAID and the regulatory provisions for its negotiated indirect cost rate agreement, IRC has been involved in finalizing provisional rates each year. Provisional rates provided by the government are charged to the grants and adjusted in the period after the final rate is determined. IRC applies its indirect cost rate negotiated with USAID (NICRA) to its Federally-funded activities. The accompanying schedule of expenditures of federal awards presents the federal awards activity (including indirect cost recovery amounts) of International Rescue Committee, Inc. and its subsidiaries (IRC) for the year ended September 30, 2024. This schedule includes federal awards passed through states and other agencies and is prepared on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of IRC’s consolidated financial statements.
Title: Reconciliation to Consolidated Financial Statements Accounting Policies: The accompanying schedule of expenditures of federal awards presents the federal awards activity (including indirect cost recovery amounts) of International Rescue Committee, Inc. and its subsidiaries (IRC) for the year ended September 30, 2024. This schedule includes federal awards passed through states and other agencies and is prepared on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of IRC’s consolidated financial statements. De Minimis Rate Used: N Rate Explanation: In connection with its ongoing relationship with USAID and the regulatory provisions for its negotiated indirect cost rate agreement, IRC has been involved in finalizing provisional rates each year. Provisional rates provided by the government are charged to the grants and adjusted in the period after the final rate is determined. IRC applies its indirect cost rate negotiated with USAID (NICRA) to its Federally-funded activities. The reconciliation of IRC’s consolidated financial statements and the schedule of expenditures of federal awards is as follows (in thousands): Grant and contract income: U.S. federal and local government agencies $ 744,806 Less: Nonfederal awards included above (21,346) Total expenditures of federal awards $ 723,460
Title: Pass-through Activity Accounting Policies: The accompanying schedule of expenditures of federal awards presents the federal awards activity (including indirect cost recovery amounts) of International Rescue Committee, Inc. and its subsidiaries (IRC) for the year ended September 30, 2024. This schedule includes federal awards passed through states and other agencies and is prepared on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of IRC’s consolidated financial statements. De Minimis Rate Used: N Rate Explanation: In connection with its ongoing relationship with USAID and the regulatory provisions for its negotiated indirect cost rate agreement, IRC has been involved in finalizing provisional rates each year. Provisional rates provided by the government are charged to the grants and adjusted in the period after the final rate is determined. IRC applies its indirect cost rate negotiated with USAID (NICRA) to its Federally-funded activities. IRC is the subrecipient of federal funds, which are reported as pass-through funds on the schedule of expenditures of federal awards as the expense is incurred.
Title: Indirect Cost Rate Accounting Policies: The accompanying schedule of expenditures of federal awards presents the federal awards activity (including indirect cost recovery amounts) of International Rescue Committee, Inc. and its subsidiaries (IRC) for the year ended September 30, 2024. This schedule includes federal awards passed through states and other agencies and is prepared on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of IRC’s consolidated financial statements. De Minimis Rate Used: N Rate Explanation: In connection with its ongoing relationship with USAID and the regulatory provisions for its negotiated indirect cost rate agreement, IRC has been involved in finalizing provisional rates each year. Provisional rates provided by the government are charged to the grants and adjusted in the period after the final rate is determined. IRC applies its indirect cost rate negotiated with USAID (NICRA) to its Federally-funded activities. In connection with its ongoing relationship with USAID and the regulatory provisions for its negotiated indirect cost rate agreement, IRC has been involved in finalizing provisional rates each year. Provisional rates provided by the government are charged to the grants and adjusted in the period after the final rate is determined. IRC applies its indirect cost rate negotiated with USAID (NICRA) to its Federally-funded activities.

Finding Details

Finding 2024-001
U.S. Department of State: Bureau of Population and Refugees and Migration: Oversees Refugee Assistance Programs for Africa: Advancing access to integrated life-saving assistance and protection services to promote selfreliance and resilience for refugees and host communities in Uganda (ALN 19.517, award number SPRMCO23CA0106) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives (ALN 98.001, award number 720BHA22GR00304) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non-federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For ALN 19.517, there were 3 new or amended subawardee agreements entered into during fiscal year 2024. We selected all three of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for all three agreements was not submitted timely. All of the agreements were entered into on October 1, 2023 and the information was submitted in January 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested - 3 Subaward not reported - 0 Report not timely - 3 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $957,943 Subaward not reported - $0 Report not timely - $957,943 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2024. We selected four for test work and noted that while all the key data elements were accurately submitted, the information for two of these agreements was not submitted timely. These two agreements were entered into on January 1, 2024 and March 1, 2024 and the information was not submitted until November of 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for certain subawards on a timely basis. We noted the following exceptions: Transactions Tested - 4 Subaward not reported - 0 Report not timely - 2 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $1,349,750 Subaward not reported - $0 Report not timely - $112,617 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 Cause: Responsible staff encountered challenges accessing SAM.gov due to credential errors, which resulted in delays in submitting or updating subrecipient details in a timely manner. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized. Views of Responsible Officials: Management agrees with this finding and will take the necessary actions to ensure its FFATA reporting is more timely.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-001
U.S. Department of State: Bureau of Population and Refugees and Migration: Oversees Refugee Assistance Programs for Africa: Advancing access to integrated life-saving assistance and protection services to promote selfreliance and resilience for refugees and host communities in Uganda (ALN 19.517, award number SPRMCO23CA0106) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives (ALN 98.001, award number 720BHA22GR00304) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non-federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For ALN 19.517, there were 3 new or amended subawardee agreements entered into during fiscal year 2024. We selected all three of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for all three agreements was not submitted timely. All of the agreements were entered into on October 1, 2023 and the information was submitted in January 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested - 3 Subaward not reported - 0 Report not timely - 3 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $957,943 Subaward not reported - $0 Report not timely - $957,943 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2024. We selected four for test work and noted that while all the key data elements were accurately submitted, the information for two of these agreements was not submitted timely. These two agreements were entered into on January 1, 2024 and March 1, 2024 and the information was not submitted until November of 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for certain subawards on a timely basis. We noted the following exceptions: Transactions Tested - 4 Subaward not reported - 0 Report not timely - 2 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $1,349,750 Subaward not reported - $0 Report not timely - $112,617 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 Cause: Responsible staff encountered challenges accessing SAM.gov due to credential errors, which resulted in delays in submitting or updating subrecipient details in a timely manner. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized. Views of Responsible Officials: Management agrees with this finding and will take the necessary actions to ensure its FFATA reporting is more timely.
Finding 2024-001
U.S. Department of State: Bureau of Population and Refugees and Migration: Oversees Refugee Assistance Programs for Africa: Advancing access to integrated life-saving assistance and protection services to promote selfreliance and resilience for refugees and host communities in Uganda (ALN 19.517, award number SPRMCO23CA0106) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives (ALN 98.001, award number 720BHA22GR00304) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non-federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For ALN 19.517, there were 3 new or amended subawardee agreements entered into during fiscal year 2024. We selected all three of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for all three agreements was not submitted timely. All of the agreements were entered into on October 1, 2023 and the information was submitted in January 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested - 3 Subaward not reported - 0 Report not timely - 3 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $957,943 Subaward not reported - $0 Report not timely - $957,943 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2024. We selected four for test work and noted that while all the key data elements were accurately submitted, the information for two of these agreements was not submitted timely. These two agreements were entered into on January 1, 2024 and March 1, 2024 and the information was not submitted until November of 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for certain subawards on a timely basis. We noted the following exceptions: Transactions Tested - 4 Subaward not reported - 0 Report not timely - 2 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $1,349,750 Subaward not reported - $0 Report not timely - $112,617 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 Cause: Responsible staff encountered challenges accessing SAM.gov due to credential errors, which resulted in delays in submitting or updating subrecipient details in a timely manner. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized. Views of Responsible Officials: Management agrees with this finding and will take the necessary actions to ensure its FFATA reporting is more timely.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-002
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Finding 2024-001
U.S. Department of State: Bureau of Population and Refugees and Migration: Oversees Refugee Assistance Programs for Africa: Advancing access to integrated life-saving assistance and protection services to promote selfreliance and resilience for refugees and host communities in Uganda (ALN 19.517, award number SPRMCO23CA0106) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives (ALN 98.001, award number 720BHA22GR00304) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non-federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For ALN 19.517, there were 3 new or amended subawardee agreements entered into during fiscal year 2024. We selected all three of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for all three agreements was not submitted timely. All of the agreements were entered into on October 1, 2023 and the information was submitted in January 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested - 3 Subaward not reported - 0 Report not timely - 3 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $957,943 Subaward not reported - $0 Report not timely - $957,943 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2024. We selected four for test work and noted that while all the key data elements were accurately submitted, the information for two of these agreements was not submitted timely. These two agreements were entered into on January 1, 2024 and March 1, 2024 and the information was not submitted until November of 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for certain subawards on a timely basis. We noted the following exceptions: Transactions Tested - 4 Subaward not reported - 0 Report not timely - 2 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $1,349,750 Subaward not reported - $0 Report not timely - $112,617 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 Cause: Responsible staff encountered challenges accessing SAM.gov due to credential errors, which resulted in delays in submitting or updating subrecipient details in a timely manner. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized. Views of Responsible Officials: Management agrees with this finding and will take the necessary actions to ensure its FFATA reporting is more timely.