Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.
Finding 2024-004 Suspension and Debarment (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program
Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not
qualified for a Federal award states that non-Federal entities are subject to the non-procurement
debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance
programs or activities. The non-Federal entity must verify that the person with whom you intend to do
business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification
from that person; (c) adding a clause or condition to the covered transaction with that person.
Condition: During our audit, we noted contractual relationships under the Federal awards for which
documentation of SAM Exclusion checks were unavailable for our inspection.
Cause: Administrative oversight.
Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity
that is suspended, debarred or otherwise included on the US Federal sanction list.
Questioned Costs: $102,541
Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under
major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening
documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in
nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings
are run on all contractual relationships that are charged to the Federal awards, and that documentation
of such screenings are maintained in the vendor files.
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.