Audit 378522

Administration for Children and Families Federal Financial Assistance Listing #93.566, 2302SDRCMA, 10/01/2022 – 9/30/2024 Federal Financial Assistance Listing #93.566, 2402SDRCMA, 10/01/2023 – 9/30/2026 Refugee and Entrant Assistance – State Administered Programs Eligibility Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Two instances were identified where the participant was underpaid based upon eligibility for one month (2 participant files). Cause: The participant in each case obtained employment and no monthly redetermination form was completed to ensure the participant no longer was eligible to receive the monthly cash assistance. Additionally, the Organization experienced an increase in refugee arrivals at the beginning of the fiscal year creating an increase in the workload of staff members. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility that the Organization would provide services to ineligible participants and the Organization would not detect ineligibility in a timely manner. Questioned Costs: None reported. The grant was under allocated. Context/Sampling: A nonstatistical sample of 60 participant case files out of more than 250 participant case files were selected for testing which included $149,528 of participant payments out of $668,330. Repeat Finding from Prior Year: Yes, prior year finding 2024‐003 Recommendation: We recommend management review the Organization’s policies, procedures and controls over eligibility with applicable program employees to ensure compliance with the federal program. View of Responsible Officials: Management is in agreement.

Passed through Lutheran Immigration and Refugee Service dba Global Refuge Federal Financial Assistance Listing #19.510, 323‐24‐00, 10/01/2023 – 9/30/2024 Federal Financial Assistance Listing #19.510, 323‐25‐00, 10/01/2024 – 9/30/2025 U.S. Refugee Admissions Program Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: In the sample of expenditures selected for testing, two instances were identified where the approval over the expense occurred after the check was written. Cause: The Organization underwent a transitional phase from paper‐based documentation to a digital workflow using Salesforce. This system change likely contributed to deviations in the established processes and internal controls, including the sequence of expense approvals. Effect: Lack of compliance with designed internal controls over disbursements allows for payment of expenses that were not approved prior to checks being written. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 payroll and nonpayroll disbursements out of more than 250 payroll and nonpayroll disbursements were selected for testing which included $31,198 out of $756,944. Repeat Finding from Prior Year: No Recommendation: We recommend management review the Organization’s policies, procedures and controls over expenses with applicable program employees to ensure approval of expenses occurs prior to checks being written and payments being made. View of Responsible Officials: Management is in agreement.

Passed through Lutheran Immigration and Refugee Service dba Global Refuge Federal Financial Assistance Listing #19.510, 323‐24‐00, 10/01/2023 – 9/30/2024 Federal Financial Assistance Listing #19.510, 323‐25‐00, 10/01/2024 – 9/30/2025 U.S. Refugee Admissions Program Special Tests and Provisions Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We noted the following matters during testing which affected 2 participant files: a) One instance was identified where documentation for both the initial home visit and the 30‐day followup home visit was missing from the participant file. No case activity or other documentation was able to be provided to indicate that these visits were conducted in accordance with the federal program. b) One instance was identified where an expense was paid and reimbursed under the grant without evidence of a formal request, invoice support, review, or approval. Cause: The Organization experienced an increase in refugee arrivals at the beginning of the fiscal year creating an increase in the workload of staff members along with employee turnover occurring toward the end of the fiscal year. Additionally, the Organization underwent a transitional phase from paper‐based documentation to a digital workflow using Salesforce. This system change likely contributed to deviations in established processes and internal controls. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility that the Organization would not be in compliance with the federal award was it relates to case file management. Questioned Costs: $39 Context/Sampling: A nonstatistical sample of 18 participant files out of 117 total participant files were selected for testing. Repeat Finding from Prior Year: No Recommendation: We recommend that management review the Organization’s policies, procedures and controls over case file management with applicable program employees to ensure compliance with the federal program. View of Responsible Officials: Management is in agreement.