2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
Finding No.2023-002: Maintain Supporting Documentation for Federal Report Submissions
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entity: California Rural Legal Assistance Foundation
Federal Award Number: Not available in the contract
Federal Award Year: October 1, 2022 – October 31, 2024
Compliance Requirement: Reporting
Criteria or Specific Requirements:
Section 6 of the Memorandum of Understanding between California Rural Legal Assistance Foundation (CRLAF) and the Council on American-Islamic Relations, San Francisco Bay Area Office (CAIR-SFBA), outlines the subrecipient's reporting requirements for demographic data.
a. The subgrantee shall regularly update a reporting database, the “ALSP Reporting Database”, shared with CRLAF and California Department of Social Services (CDSS), that quantitatively describes the services provided under this project. The subgrantee shall collect and report in this database the following information, without disclosing personally identifiable information or other confidential information:
• Number of individuals provided legal assistance
• For immigration legal services: case type
• For non-legal services: service type
• Case outcomes, as feasibly possible
• General demographic information, reported anonymously, about individuals served: age, language, nationality, and county of residence
b. The deadline to update the reporting database with information from individuals served in each month of the grant term shall be the 5th day of the following month.
Condition:
During our testing of 10 reporting samples, we identified two instances wherein CAIR-CA did not retain confirmation or proof of submission (e.g., email receipts, submission confirmations from the federal portal) for demographic data reports submitted under the contract between CRLAF and Council on American-Islamic Relations, CAIR-SFBA.
Additionally, we were informed that demographic data updates are entered directly into the Afghan Legal Services Project (ALSP) Reporting Database. As a result, no copies of submitted reports were generated or retained for review.
Cause:
CAIR-CA has not established a formal process requiring the retention of submitted reports and confirmations of submission as part of its grant reporting procedures.
Effect:
The absence of documentation may affect CAIR-CA’s ability to demonstrate compliance with the applicable federal requirements.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA implement a standardized process of retaining copies of documentation of report submissions. This process should include saving submission confirmations for all required federal reports, such as email receipts, portal confirmations, or screenshots, as evidence of timely and accurate submission.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and has already begun strengthening its reporting procedures to include the retention of submission confirmations as part of its grant documentation.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: October 31, 2025.
Finding No.2023-003: Improve Controls Over Expense Reporting and Payroll Charges
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entity: 1. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
2. California Department of Social Services (CDSS)
Federal Award Number:
1. Not available in the contract
2. ACS22-05-CAIR-A1
Federal Award Year:
1. February 1, 2023 – March 31, 2024
2. November 1, 2022 – March 31, 2025
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirements:
In accordance with 2 CFR 200.403 and 200.405, costs charged to a federal award must be necessary, reasonable, and allocable.
In addition, 2 CFR 200.430 Compensation-personal services, provides that compensation for personal services must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Condition:
During our testing of 21 non-payroll expenses, we identified one instance wherein translation services amounting to $795, provided by a staff member, were charged under professional fees, even though the individual's salary was recorded and billed under salary expenses.
Additionally, in our testing of 25 payroll expenses, we identified one instance of overbilling in the amount $622. This occurred because the payroll charge was based on budgeted Full Time Equivalents (FTEs) rather than the actual time worked.
Cause:
CAIR-CA's current internal controls for reviewing billings under the federal program were not sufficient to consistently prevent or detect duplicate or inaccurate charges.
Furthermore, CAIR-CA lacked adequate internal controls to ensure that payroll allocations were based on actual time worked on the federal program.
Effect:
These control deficiencies resulted in the overbilling of federal funds.
Questioned Cost: $1,417
Recommendation:
To ensure compliance with the Uniform Guidance, we recommend that CAIR-CA strengthen its internal controls over expense reporting by implementing enhanced review procedures to verify the allowability of costs charged to federal awards.
Additionally, CAIR-CA should establish formal procedures to ensure that payroll charges to federal programs are based on actual time and effort records. Management should conduct regular reviews and make necessary adjustments to payroll allocations to accurately reflect the work performed on federally funded activities.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and has already initiated enhancements to its review process to ensure that expense reports are consistently reviewed and approved by both supervisors and finance personnel prior to being charged to federal awards. These steps are designed to further strengthen internal controls and support compliance with federal requirements.
In addition, Finance staff are formalizing procedures to reconcile payroll charges on a regular basis to ensure compliance with federal requirements and to confirm that all charges to federal programs are supported by actual time and effort records.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: October 31, 2025
Finding No.2023-003: Improve Controls Over Expense Reporting and Payroll Charges
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entity: 1. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
2. California Department of Social Services (CDSS)
Federal Award Number:
1. Not available in the contract
2. ACS22-05-CAIR-A1
Federal Award Year:
1. February 1, 2023 – March 31, 2024
2. November 1, 2022 – March 31, 2025
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirements:
In accordance with 2 CFR 200.403 and 200.405, costs charged to a federal award must be necessary, reasonable, and allocable.
In addition, 2 CFR 200.430 Compensation-personal services, provides that compensation for personal services must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Condition:
During our testing of 21 non-payroll expenses, we identified one instance wherein translation services amounting to $795, provided by a staff member, were charged under professional fees, even though the individual's salary was recorded and billed under salary expenses.
Additionally, in our testing of 25 payroll expenses, we identified one instance of overbilling in the amount $622. This occurred because the payroll charge was based on budgeted Full Time Equivalents (FTEs) rather than the actual time worked.
Cause:
CAIR-CA's current internal controls for reviewing billings under the federal program were not sufficient to consistently prevent or detect duplicate or inaccurate charges.
Furthermore, CAIR-CA lacked adequate internal controls to ensure that payroll allocations were based on actual time worked on the federal program.
Effect:
These control deficiencies resulted in the overbilling of federal funds.
Questioned Cost: $1,417
Recommendation:
To ensure compliance with the Uniform Guidance, we recommend that CAIR-CA strengthen its internal controls over expense reporting by implementing enhanced review procedures to verify the allowability of costs charged to federal awards.
Additionally, CAIR-CA should establish formal procedures to ensure that payroll charges to federal programs are based on actual time and effort records. Management should conduct regular reviews and make necessary adjustments to payroll allocations to accurately reflect the work performed on federally funded activities.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and has already initiated enhancements to its review process to ensure that expense reports are consistently reviewed and approved by both supervisors and finance personnel prior to being charged to federal awards. These steps are designed to further strengthen internal controls and support compliance with federal requirements.
In addition, Finance staff are formalizing procedures to reconcile payroll charges on a regular basis to ensure compliance with federal requirements and to confirm that all charges to federal programs are supported by actual time and effort records.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: October 31, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
2023-001 Implement System-Based Tracking of Federal Expenditures
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entities:
1. California Department of Social Services
2. University of California, San Diego
3. California Rural Legal Assistance Foundation
4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
Federal Award Numbers: ALSP22-0002-A1, PUR00533092, ALSP22-0001, and ACS22-05-CAIR-A1
Federal Award Year: 8/1/2022 to 3/31/2025
Compliance Requirement: Activities Allowed or Unallowed
Criteria:
Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements.
2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger).
In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended.
Condition:
During our review of the SEFA, we noted that CAIR-CA currently utilizes workbooks outside of its accounting software to track federal expenditures. The external workbooks do not reconcile directly with the general ledger (GL) requiring management to prepare a separate reconciliation to support the SEFA amounts.
Cause:
This year marks CAIR-CA’s first Single Audit. As such, processes and internal controls over federal award tracking are still under development. The current system is not yet fully integrated to allow for automated or system-based tracking of federal expenditures by grant.
Effect:
Relying on manual workbooks to track federal expenditures can be inefficient and may result in inaccurate or incomplete reporting of federal expenditures.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA enhance its accounting processes to enable the tracking of federal expenditures directly within its accounting software. This can be accomplished by implementing
GL tracking codes or tags specifically designated for federal expenditures. Transitioning to a system based tracking approach will support consistency between the general ledger and the SEFA, simplify the process of generating financial reports, and improve the tracking of federal expenditures.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: November 20, 2025
Finding No.2023-002: Maintain Supporting Documentation for Federal Report Submissions
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entity: California Rural Legal Assistance Foundation
Federal Award Number: Not available in the contract
Federal Award Year: October 1, 2022 – October 31, 2024
Compliance Requirement: Reporting
Criteria or Specific Requirements:
Section 6 of the Memorandum of Understanding between California Rural Legal Assistance Foundation (CRLAF) and the Council on American-Islamic Relations, San Francisco Bay Area Office (CAIR-SFBA), outlines the subrecipient's reporting requirements for demographic data.
a. The subgrantee shall regularly update a reporting database, the “ALSP Reporting Database”, shared with CRLAF and California Department of Social Services (CDSS), that quantitatively describes the services provided under this project. The subgrantee shall collect and report in this database the following information, without disclosing personally identifiable information or other confidential information:
• Number of individuals provided legal assistance
• For immigration legal services: case type
• For non-legal services: service type
• Case outcomes, as feasibly possible
• General demographic information, reported anonymously, about individuals served: age, language, nationality, and county of residence
b. The deadline to update the reporting database with information from individuals served in each month of the grant term shall be the 5th day of the following month.
Condition:
During our testing of 10 reporting samples, we identified two instances wherein CAIR-CA did not retain confirmation or proof of submission (e.g., email receipts, submission confirmations from the federal portal) for demographic data reports submitted under the contract between CRLAF and Council on American-Islamic Relations, CAIR-SFBA.
Additionally, we were informed that demographic data updates are entered directly into the Afghan Legal Services Project (ALSP) Reporting Database. As a result, no copies of submitted reports were generated or retained for review.
Cause:
CAIR-CA has not established a formal process requiring the retention of submitted reports and confirmations of submission as part of its grant reporting procedures.
Effect:
The absence of documentation may affect CAIR-CA’s ability to demonstrate compliance with the applicable federal requirements.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA implement a standardized process of retaining copies of documentation of report submissions. This process should include saving submission confirmations for all required federal reports, such as email receipts, portal confirmations, or screenshots, as evidence of timely and accurate submission.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and has already begun strengthening its reporting procedures to include the retention of submission confirmations as part of its grant documentation.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: October 31, 2025.
Finding No.2023-003: Improve Controls Over Expense Reporting and Payroll Charges
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entity: 1. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
2. California Department of Social Services (CDSS)
Federal Award Number:
1. Not available in the contract
2. ACS22-05-CAIR-A1
Federal Award Year:
1. February 1, 2023 – March 31, 2024
2. November 1, 2022 – March 31, 2025
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirements:
In accordance with 2 CFR 200.403 and 200.405, costs charged to a federal award must be necessary, reasonable, and allocable.
In addition, 2 CFR 200.430 Compensation-personal services, provides that compensation for personal services must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Condition:
During our testing of 21 non-payroll expenses, we identified one instance wherein translation services amounting to $795, provided by a staff member, were charged under professional fees, even though the individual's salary was recorded and billed under salary expenses.
Additionally, in our testing of 25 payroll expenses, we identified one instance of overbilling in the amount $622. This occurred because the payroll charge was based on budgeted Full Time Equivalents (FTEs) rather than the actual time worked.
Cause:
CAIR-CA's current internal controls for reviewing billings under the federal program were not sufficient to consistently prevent or detect duplicate or inaccurate charges.
Furthermore, CAIR-CA lacked adequate internal controls to ensure that payroll allocations were based on actual time worked on the federal program.
Effect:
These control deficiencies resulted in the overbilling of federal funds.
Questioned Cost: $1,417
Recommendation:
To ensure compliance with the Uniform Guidance, we recommend that CAIR-CA strengthen its internal controls over expense reporting by implementing enhanced review procedures to verify the allowability of costs charged to federal awards.
Additionally, CAIR-CA should establish formal procedures to ensure that payroll charges to federal programs are based on actual time and effort records. Management should conduct regular reviews and make necessary adjustments to payroll allocations to accurately reflect the work performed on federally funded activities.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and has already initiated enhancements to its review process to ensure that expense reports are consistently reviewed and approved by both supervisors and finance personnel prior to being charged to federal awards. These steps are designed to further strengthen internal controls and support compliance with federal requirements.
In addition, Finance staff are formalizing procedures to reconcile payroll charges on a regular basis to ensure compliance with federal requirements and to confirm that all charges to federal programs are supported by actual time and effort records.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: October 31, 2025
Finding No.2023-003: Improve Controls Over Expense Reporting and Payroll Charges
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entity: 1. San Diego Refugee Communities Coalition/United Women of East Africa Support Team
2. California Department of Social Services (CDSS)
Federal Award Number:
1. Not available in the contract
2. ACS22-05-CAIR-A1
Federal Award Year:
1. February 1, 2023 – March 31, 2024
2. November 1, 2022 – March 31, 2025
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirements:
In accordance with 2 CFR 200.403 and 200.405, costs charged to a federal award must be necessary, reasonable, and allocable.
In addition, 2 CFR 200.430 Compensation-personal services, provides that compensation for personal services must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Condition:
During our testing of 21 non-payroll expenses, we identified one instance wherein translation services amounting to $795, provided by a staff member, were charged under professional fees, even though the individual's salary was recorded and billed under salary expenses.
Additionally, in our testing of 25 payroll expenses, we identified one instance of overbilling in the amount $622. This occurred because the payroll charge was based on budgeted Full Time Equivalents (FTEs) rather than the actual time worked.
Cause:
CAIR-CA's current internal controls for reviewing billings under the federal program were not sufficient to consistently prevent or detect duplicate or inaccurate charges.
Furthermore, CAIR-CA lacked adequate internal controls to ensure that payroll allocations were based on actual time worked on the federal program.
Effect:
These control deficiencies resulted in the overbilling of federal funds.
Questioned Cost: $1,417
Recommendation:
To ensure compliance with the Uniform Guidance, we recommend that CAIR-CA strengthen its internal controls over expense reporting by implementing enhanced review procedures to verify the allowability of costs charged to federal awards.
Additionally, CAIR-CA should establish formal procedures to ensure that payroll charges to federal programs are based on actual time and effort records. Management should conduct regular reviews and make necessary adjustments to payroll allocations to accurately reflect the work performed on federally funded activities.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and has already initiated enhancements to its review process to ensure that expense reports are consistently reviewed and approved by both supervisors and finance personnel prior to being charged to federal awards. These steps are designed to further strengthen internal controls and support compliance with federal requirements.
In addition, Finance staff are formalizing procedures to reconcile payroll charges on a regular basis to ensure compliance with federal requirements and to confirm that all charges to federal programs are supported by actual time and effort records.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: October 31, 2025