Finding No. 2024-001 Implement System-Based Tracking of Federal Expenditures Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance State/Replacement Designee 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 5. Public Health Institute (PHI) Federal Award Numbers: ALSP22-0002-A1, ALSP23-0001, PUR00533092, ACS22-05-CAIR, 06568-AR76924 Federal Award Year: August 1, 2022 to June 30, 2026 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 utilizes workbooks outside of its accounting software to track federal expenditures. The workbooks do not reconcile directly with the general ledger (GL), so management performs a separate reconciliation to support the SEFA amounts. This approach was similarly observed in the prior year's audit. Cause: The prior year audit was completed in August 2025, after the close of the fiscal year 2024. As a result, management was still in the process of implementing a system-based tracking during the year 2024. CAIR-CA’s processes for tracking federal awards are continuing to develop, as this is only the second year under Single Audit. Effect: Using manual workbooks requires additional manual effort and may make reconciliation between SEFA and GL more time-consuming, and may result in inaccurate or incomplete reporting. Questioned Cost: None Recommendation: We recommend that CAIR-CA continue enhancing its accounting processes to track federal expenditures directly within its accounting software. This could include GL tracking codes or other similar identifiers for federal programs. System based tracking would simplify SEFA preparation, improve consistency with the general ledger, and strengthen monitoring of federal expenditures. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already updated the accounting system to incorporate grant-specific tracking codes to further align with federal reporting standards. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. 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 Implementation date: November 20, 2025
Finding No.2024-002: Maintain Supporting Documentation for Required Federal Reports Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance State/Replacement Designee 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: November 1, 2022 – March 31, 2025 Compliance Requirement: Reporting Criteria or Specific Requirements: The Compliance Supplement requires that Quarterly Expenditure Reports be submitted for this program. Additionally, 2 CFR 200.334 requires non-federal entities to retain financial records, supporting documentation, and all other pertinent records to substantiate federal award reporting. Condition: During our testing of 24 reporting samples, we identified two (2) instances wherein Quarterly Expenditure Reports related to the grant of Council on American Islamic Relations, San Francisco Bay Area Office (CAIR-SFBA), including the evidence of submission (e.g. confirmation emails or system-generated receipts), were not available for review. Cause: Management indicated that the reports and supporting documentation could not be located. Additionally, the staff previously responsible for preparing and submitting these reports is no longer with the Organization. Effect: The absence of documented evidence may affect CAIR-CA’s ability to demonstrate compliance with the applicable federal requirements. Questioned Cost: None Recommendation: We recommend that CAIR-CA finalize and consistently implement a formal process for retaining submitted grant reports and supporting documentation. This process should include keeping submission confirmations, such as email receipts, portal confirmations, or screenshots, as well as retaining copies of the submitted reports, to provide clear evidence of timely and accurate submission for all required reports. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already implemented reporting procedures to include the retention of submission confirmations as part of its grant documentation. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: October 31, 2025
Finding No.2024-003: Noncompliance with Annual Financial Statements Audit and Single Audit Submission Requirements Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance State/Replacement Designee 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 5. Public Health Institute (PHI) 6. License to Freedom Federal Award Numbers: ALSP22-0002-A1, ALSP23-0001, PUR00533092, ACS22-05-CAIR, 06568-AR76924 Federal Award Year: August 1, 2022 to June 30, 2026 Compliance Requirement: Reporting Criteria: California Nonprofit Integrity Act of 2004 requires nonprofit organizations to obtain an annual independent audit and must make the audited financial statements available to the California Attorney General no later than 9 months after the close of the fiscal year. Title 2 CFR § 200.512(a)(1) requires non-federal entities to submit the single audit reporting package, including the Data Collection Form (SF‑SAC) and the auditor’s reports, to the Federal Audit Clearinghouse (FAC) within the earlier of (i) 30 calendar days after receipt of the auditor’s reports, or (ii) nine (9) months after the end of the audit period. Condition: The single audit reporting package for the year ended December 31, 2023, was submitted by CAIR-CA in August 2025. CAIR-CA also failed to complete its financial and single audit for the year ended December 31, 2024 within the required nine month deadline under 2 CFR 200.512. As of September 30, 2025, no single audit report has been issued or filed, resulting in noncompliance with federal audit requirements. Cause: The year ended December 31, 2023, represented CAIR-CA’s first year undergoing a single audit, with 2024 being its second. During this initial implementation period, management was in the process of aligning its internal processes with applicable federal reporting requirements, including FAC submission protocols and deadlines. As part of this transition, formalized procedures to support timely submission were established and refined. Effect: Delays in submitting the single audit reporting package result in noncompliance with federal requirements and may increase scrutiny from federal agencies or affect the timing of future funding. Questioned Cost: None Recommendation: We recommend that management continue to enhance its processes related to single audit compliance and formalize policies and procedures to support timely submission. This should include establishing clear timelines, assigning responsibility for monitoring key deadlines, and implementing a process to track submission status to the FAC. These steps will help promote timely and accurate submissions in the future reporting periods. Views of Responsible Officials and Corrective Action Plan: Management has developed and implemented corrective actions to address this finding. As of January 1, 2026, formal procedures for FAC submission have been established, including defined roles, internal deadlines, and review protocols. A compliance tracking system has been implemented to monitor key reporting deadlines, and staff have received training on federal requirements. Management will continue to monitor adherence to these procedures to ensure timely submission in future reporting periods. Implementation date: January 1, 2026