Finding 2024-003 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over activities allowed or unallowed and allowable costs/cost principles and significant deficiency in internal controls Criteria: According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Organization charged payroll expenditures to the grant which were not based on records maintained which reflected the work performed. Cause: Payroll is processed by an external third party, and the system was setup originally to base pay on time budgets rather than actual hours spent. In addition, there were errors in the payroll allocations to various programs Effect: The Organization charged expenditures to the grant which were unallowable. Likely Questioned Costs: $4,059 Repeat Finding: No Recommendations: We recommend the Organization review the payroll allocations in the payroll system to ensure they are supported by actual time spent on the program. In addition, the payroll calculations should be reviewed to ensure the amounts allocated to the various programs are correct. Views of Responsible Officials: The Organization uses a third-party vendor to process payroll. This system does not have the capability to allocate salaried employees based on time spent on the program recorded in the time keeping system. Because of this, the hours worked in each program need to be converted into percentages before payroll is submitted for processing. To ensure accuracy, the Organization will have a second reviewer confirm the manual entry conversion from hours worked to percentage of time worked for salaried employees for the remaining duration of time in a third-party payroll system. Effective January 2026, the Organization will implement a new payroll system that will be processed in-house. This system has improved functionality that will eliminate the need to make this conversion and the potential for errors.
Finding 2024-004 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to employee training and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, program employees must complete Crime Victims Compensation Training every 4 years. Condition: The Organization did not maintain proof that program employees completed the required training. Cause: The Organization’s policies and procedures did not require certificates of completion be maintained for training completed. Effect: If required training is not completed, program employees may lack the knowledge needed to operate the program. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure training is completed timely and certificates of completion are maintained. Views of Responsible Officials: Moving forward a new process of policy with record keeping guidance will be implemented to ensure the documentation is kept on file. For training courses that do not provide a completion certificate, staff will prepare a memo with self-attestation of completion for our records.
Finding 2024-005 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to Board Member training and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, at least one Board Member must complete at least 12 hours of training in the first year of service related to board rules and responsibilities, core victim services, confidentiality and civil rights. Condition: The Organization did not maintain proof that at least one board member had completed the required 12 hours of training. Cause: The Organization’s policies and procedures did not require certificates of completion be maintained for training completed. Effect: If required training is not completed, board members may lack the knowledge needed to oversee the program. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure training is completed timely and certificates of completion are maintained. Views of Responsible Officials: The delegates from the board did receive the training prior to entering the board but were unable to provide certification proof. Moving forward a new process of policy with record keeping guidance will be implemented to ensure the documentation is kept on file. For training courses that do not provide a completion certificate, Board members will prepare a memo with self-attestation of completion for our records.
Finding 2024-006 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to employment eligibility and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, the Organization must obtain a criminal history record check on any employee, potential employee or volunteer working with victims of crime. Condition: The Organization was unable to locate the criminal history verification form for an employee working within the program. Cause: The Organization was previously a part of Catholic Charities of Oregon. The employee in question was originally hired by Catholic Charities of Oregon and the Organization did not re-verify eligibility when it spun off from Catholic Charities of Oregon. Catholic Charities of Oregon and the Organization were both unable to provide documentation that a criminal history verification was completed. Effect: Employees who are not eligible to be employed by the program may be employed. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure documentation of criminal history verification is maintained for all employees. Views of Responsible Officials: The Organization has long term employees that joined the organization when it was a program of Catholic Charities. The Organization does not maintain these records for employees that began with Catholic Charities. In early FY2026, The Organization will complete background checks on long term employees to ensure we maintain the proper documentation.
Finding 2024-007 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over reporting and significant deficiency in internal controls related to reporting Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, the Organization is to submit various financial and performance reports on a quarterly, semi-annual or annual basis. The reports must be filed within 20 days or one month, depending on the type of report, or period end. Condition: The Organization did not submit any of the required reports timely. In addition, no evidence of review was noted on one quarterly report or any of the performance reports. Cause: Internal control processes and procedures were not in place to ensure required reports were filed timely. Effect: The Department of Justice relies on reports to monitor the activities of the Organization, and without these reports, the Department of Justice cannot provide sufficient oversight of grant activities. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure reports are filed timely. Views of Responsible Officials: The Director of Finance and Accounting Manager began implementing process and procedures to ensure all invoices are filed in a timely manner to funders in July 2024. The importance of understanding the requirements of the agreements has been stressed to the finance team. The team has also been instructed to save on SharePoint all communication with funders regarding changes of when invoices are to be filed when the instructions differ from the agreement. To ensure timely submission of the performance reports, the Organization will use Sales Force software to track all due dates. This system will send reminders and will record submission dates. To ensure review of all performance reports, procedures will be put in place outlining roles and responsibilities of report preparation by managers and review by Program Directors.
Finding 2024-003 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over activities allowed or unallowed and allowable costs/cost principles and significant deficiency in internal controls Criteria: According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Organization charged payroll expenditures to the grant which were not based on records maintained which reflected the work performed. Cause: Payroll is processed by an external third party, and the system was setup originally to base pay on time budgets rather than actual hours spent. In addition, there were errors in the payroll allocations to various programs Effect: The Organization charged expenditures to the grant which were unallowable. Likely Questioned Costs: $4,059 Repeat Finding: No Recommendations: We recommend the Organization review the payroll allocations in the payroll system to ensure they are supported by actual time spent on the program. In addition, the payroll calculations should be reviewed to ensure the amounts allocated to the various programs are correct. Views of Responsible Officials: The Organization uses a third-party vendor to process payroll. This system does not have the capability to allocate salaried employees based on time spent on the program recorded in the time keeping system. Because of this, the hours worked in each program need to be converted into percentages before payroll is submitted for processing. To ensure accuracy, the Organization will have a second reviewer confirm the manual entry conversion from hours worked to percentage of time worked for salaried employees for the remaining duration of time in a third-party payroll system. Effective January 2026, the Organization will implement a new payroll system that will be processed in-house. This system has improved functionality that will eliminate the need to make this conversion and the potential for errors.
Finding 2024-004 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to employee training and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, program employees must complete Crime Victims Compensation Training every 4 years. Condition: The Organization did not maintain proof that program employees completed the required training. Cause: The Organization’s policies and procedures did not require certificates of completion be maintained for training completed. Effect: If required training is not completed, program employees may lack the knowledge needed to operate the program. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure training is completed timely and certificates of completion are maintained. Views of Responsible Officials: Moving forward a new process of policy with record keeping guidance will be implemented to ensure the documentation is kept on file. For training courses that do not provide a completion certificate, staff will prepare a memo with self-attestation of completion for our records.
Finding 2024-005 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to Board Member training and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, at least one Board Member must complete at least 12 hours of training in the first year of service related to board rules and responsibilities, core victim services, confidentiality and civil rights. Condition: The Organization did not maintain proof that at least one board member had completed the required 12 hours of training. Cause: The Organization’s policies and procedures did not require certificates of completion be maintained for training completed. Effect: If required training is not completed, board members may lack the knowledge needed to oversee the program. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure training is completed timely and certificates of completion are maintained. Views of Responsible Officials: The delegates from the board did receive the training prior to entering the board but were unable to provide certification proof. Moving forward a new process of policy with record keeping guidance will be implemented to ensure the documentation is kept on file. For training courses that do not provide a completion certificate, Board members will prepare a memo with self-attestation of completion for our records.
Finding 2024-006 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to employment eligibility and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, the Organization must obtain a criminal history record check on any employee, potential employee or volunteer working with victims of crime. Condition: The Organization was unable to locate the criminal history verification form for an employee working within the program. Cause: The Organization was previously a part of Catholic Charities of Oregon. The employee in question was originally hired by Catholic Charities of Oregon and the Organization did not re-verify eligibility when it spun off from Catholic Charities of Oregon. Catholic Charities of Oregon and the Organization were both unable to provide documentation that a criminal history verification was completed. Effect: Employees who are not eligible to be employed by the program may be employed. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure documentation of criminal history verification is maintained for all employees. Views of Responsible Officials: The Organization has long term employees that joined the organization when it was a program of Catholic Charities. The Organization does not maintain these records for employees that began with Catholic Charities. In early FY2026, The Organization will complete background checks on long term employees to ensure we maintain the proper documentation.
Finding 2024-007 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over reporting and significant deficiency in internal controls related to reporting Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, the Organization is to submit various financial and performance reports on a quarterly, semi-annual or annual basis. The reports must be filed within 20 days or one month, depending on the type of report, or period end. Condition: The Organization did not submit any of the required reports timely. In addition, no evidence of review was noted on one quarterly report or any of the performance reports. Cause: Internal control processes and procedures were not in place to ensure required reports were filed timely. Effect: The Department of Justice relies on reports to monitor the activities of the Organization, and without these reports, the Department of Justice cannot provide sufficient oversight of grant activities. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure reports are filed timely. Views of Responsible Officials: The Director of Finance and Accounting Manager began implementing process and procedures to ensure all invoices are filed in a timely manner to funders in July 2024. The importance of understanding the requirements of the agreements has been stressed to the finance team. The team has also been instructed to save on SharePoint all communication with funders regarding changes of when invoices are to be filed when the instructions differ from the agreement. To ensure timely submission of the performance reports, the Organization will use Sales Force software to track all due dates. This system will send reminders and will record submission dates. To ensure review of all performance reports, procedures will be put in place outlining roles and responsibilities of report preparation by managers and review by Program Directors.
Finding 2024-003 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over activities allowed or unallowed and allowable costs/cost principles and significant deficiency in internal controls Criteria: According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Organization charged payroll expenditures to the grant which were not based on records maintained which reflected the work performed. Cause: Payroll is processed by an external third party, and the system was setup originally to base pay on time budgets rather than actual hours spent. In addition, there were errors in the payroll allocations to various programs Effect: The Organization charged expenditures to the grant which were unallowable. Likely Questioned Costs: $4,059 Repeat Finding: No Recommendations: We recommend the Organization review the payroll allocations in the payroll system to ensure they are supported by actual time spent on the program. In addition, the payroll calculations should be reviewed to ensure the amounts allocated to the various programs are correct. Views of Responsible Officials: The Organization uses a third-party vendor to process payroll. This system does not have the capability to allocate salaried employees based on time spent on the program recorded in the time keeping system. Because of this, the hours worked in each program need to be converted into percentages before payroll is submitted for processing. To ensure accuracy, the Organization will have a second reviewer confirm the manual entry conversion from hours worked to percentage of time worked for salaried employees for the remaining duration of time in a third-party payroll system. Effective January 2026, the Organization will implement a new payroll system that will be processed in-house. This system has improved functionality that will eliminate the need to make this conversion and the potential for errors.
Finding 2024-004 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to employee training and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, program employees must complete Crime Victims Compensation Training every 4 years. Condition: The Organization did not maintain proof that program employees completed the required training. Cause: The Organization’s policies and procedures did not require certificates of completion be maintained for training completed. Effect: If required training is not completed, program employees may lack the knowledge needed to operate the program. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure training is completed timely and certificates of completion are maintained. Views of Responsible Officials: Moving forward a new process of policy with record keeping guidance will be implemented to ensure the documentation is kept on file. For training courses that do not provide a completion certificate, staff will prepare a memo with self-attestation of completion for our records.
Finding 2024-005 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to Board Member training and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, at least one Board Member must complete at least 12 hours of training in the first year of service related to board rules and responsibilities, core victim services, confidentiality and civil rights. Condition: The Organization did not maintain proof that at least one board member had completed the required 12 hours of training. Cause: The Organization’s policies and procedures did not require certificates of completion be maintained for training completed. Effect: If required training is not completed, board members may lack the knowledge needed to oversee the program. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure training is completed timely and certificates of completion are maintained. Views of Responsible Officials: The delegates from the board did receive the training prior to entering the board but were unable to provide certification proof. Moving forward a new process of policy with record keeping guidance will be implemented to ensure the documentation is kept on file. For training courses that do not provide a completion certificate, Board members will prepare a memo with self-attestation of completion for our records.
Finding 2024-006 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to employment eligibility and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, the Organization must obtain a criminal history record check on any employee, potential employee or volunteer working with victims of crime. Condition: The Organization was unable to locate the criminal history verification form for an employee working within the program. Cause: The Organization was previously a part of Catholic Charities of Oregon. The employee in question was originally hired by Catholic Charities of Oregon and the Organization did not re-verify eligibility when it spun off from Catholic Charities of Oregon. Catholic Charities of Oregon and the Organization were both unable to provide documentation that a criminal history verification was completed. Effect: Employees who are not eligible to be employed by the program may be employed. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure documentation of criminal history verification is maintained for all employees. Views of Responsible Officials: The Organization has long term employees that joined the organization when it was a program of Catholic Charities. The Organization does not maintain these records for employees that began with Catholic Charities. In early FY2026, The Organization will complete background checks on long term employees to ensure we maintain the proper documentation.
Finding 2024-007 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over reporting and significant deficiency in internal controls related to reporting Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, the Organization is to submit various financial and performance reports on a quarterly, semi-annual or annual basis. The reports must be filed within 20 days or one month, depending on the type of report, or period end. Condition: The Organization did not submit any of the required reports timely. In addition, no evidence of review was noted on one quarterly report or any of the performance reports. Cause: Internal control processes and procedures were not in place to ensure required reports were filed timely. Effect: The Department of Justice relies on reports to monitor the activities of the Organization, and without these reports, the Department of Justice cannot provide sufficient oversight of grant activities. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure reports are filed timely. Views of Responsible Officials: The Director of Finance and Accounting Manager began implementing process and procedures to ensure all invoices are filed in a timely manner to funders in July 2024. The importance of understanding the requirements of the agreements has been stressed to the finance team. The team has also been instructed to save on SharePoint all communication with funders regarding changes of when invoices are to be filed when the instructions differ from the agreement. To ensure timely submission of the performance reports, the Organization will use Sales Force software to track all due dates. This system will send reminders and will record submission dates. To ensure review of all performance reports, procedures will be put in place outlining roles and responsibilities of report preparation by managers and review by Program Directors.
Finding 2024-008 Identification of the Federal Program: 93.568 – Low-Income Home Energy Assistance Program Compliance finding over reporting and significant deficiency in internal controls related to reporting Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and Multnomah County, the Organization is to submit monthly expenditure reports by the 20th calendar day of the month following the month in which the expenditures were incurred. In addition, the Organization is to submit semi-annual internal financial statements within 30 days of December 31st and June 30th. Condition: The Organization did not submit 7 of the required 12 monthly financial reports or semi-annual internal financial statements timely to Multnomah County. Cause: Internal control processes and procedures were not in place to ensure required reports were filed timely. Effect: Multnomah County relies on monthly reports to monitor the activities of the Organization, and without these reports, Multnomah County cannot provide sufficient oversight of grant activities. Questioned Costs: None Repeat Finding: Yes Recommendations: We recommend the Organization develop internal control processes and procedures to ensure reports are filed timely. Views of Responsible Officials: The Organization began implementing processes and procedures to ensure all invoices are filed in a timely manner to funders in July 2024. The importance of understanding the requirements of the agreements has been stressed to the finance team. The team has also been instructed to save on SharePoint all communication with funders regarding changes of when reports are to be filed when the instructions differ from the agreement. The Organization has been behind on financial statements and previously was not able to submit the semi-annual financial statements. As of June 30, 2025, the first semi-annual financial statements were submitted.