Audit 368884

Finding 2024-001 Significant deficiency in internal controls over compliance and instances of noncompliance related to period of performance. Federal Agency: United States Department of Health and Human Services Program Title: Unaccompanied Children Program Pass-Through Entities: Global Refugee (fka Lutheran Immigration and Refugee Services) Assistance Listing Number: 93.676 Award Identification: All awards Criteria Per the standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance), Subpart D ‐ Post Federal Award Requirements, Section 200.309, only allowable costs incurred during the period of performance may be charged to the federal awards. Condition/Context During our audit, out of a sample of 25 transactions tested for period of performance, we identified three selections where the cost was incurred either before or after the respective award’s the period of performance. All three charges that were outside of the period of performance related to charges for goods and services that were entered into the incorrect period due to timing of receipt of the invoice and/or data entry error. Cause The Organization’s controls did not operate effectively to prevent or detect expenditures that were incurred outside of the federal award’s period of performance. Effect or Potential Effect The Organization charged to federal awards costs incurred outside the period of performance. Questioned Costs Award 90ZU0555-02-01: $1,829 Award 90ZU0521-02: 150 Total Questioned Costs: $1,979 Recommendation We recommend the Organization strengthen its internal control processes and procedures to ensure there are adequate controls in place to identify and record charges in the correct period to prevent charges to federal awards that did not occur within the award’s period of performance. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan. Repeat Finding Not a repeat finding.

Finding 2024-002 Significant deficiency in internal controls over compliance and instance of noncompliance related to eligibility. Federal Agency: United States Department of State Program Titles: Refugee Admissions Program Pass-Through Entity: Global Refugee (fka Lutheran Immigration and Refugee Services) Assistance Listing Number: 19.510 Award Identification: All awards Criteria Compliance requirements contained in Title 2 U.S. Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.303, require that a nonfederal entity establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Federal award referenced requires that eligible participants be Afghan arrivals as defined in the award. Condition/Context During the year ended December 31, 2024, out of a sample of 25 eligible participants, two selections who were provided direct payments under the award were not Afghan arrivals as defined in the award and were therefore not eligible. Cause The Organization’s internal controls over eligibility did not operate effectively to ensure that only eligible participants benefited from the award. Effect or Potential Effect Ineligible participants benefited from the award. Questioned Costs Payments on behalf of ineligible beneficiaries identified under award SPRMCO23CA0364 totaled $3,263. Recommendation We recommend the Organization implement internal controls to ensure that only eligible participants benefit from federal awards. Views of Responsible Individuals Management agrees with the finding and has provided the accompanying corrective action plan. Repeat Finding Not a repeat finding.