Finding #2023-005 – Material Weakness and Other Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Passed through U. S. Committee for Refugee and Immigrants, 93.567, Refugee and Entrant Assistance – Matching Grant Program, Contract period and grant #: 10/01/21...
Finding #2023-005 – Material Weakness and Other Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Passed through U. S. Committee for Refugee and Immigrants, 93.567, Refugee and Entrant Assistance – Matching Grant Program, Contract period and grant #: 10/01/21 – 09/30/23 2202VARVMG. Criteria: Matching, Level of Effort and Earmarking 45 CFR 75 306 stipulates that matching funds must meet the following criteria: 1) verifiable from organization’s records, 2) not included as contributions for any other federal award, 3) are necessary and reasonable for accomplishment of project or program objectives, 4) are allowable under Uniform Guidance Subpart E, 5) are not paid by the federal government under another federal award except where federal statute allows, and 6) are included in approved budget when required by HHS award agency. Additionally, donated goods and services should be valued at fair value, must be documented, and to the extent feasible supported by the same methods used internally by the organization. Condition and context: During our testing of 15 transactions reported as matching grant costs, we identified the following exceptions: 1. For 1 transaction, the basis for the valuation was not documented and there was no documentation of the distribution to clients within the match grant program. 2. For 1 transaction, the YMCA received a discount from the vendor so they did not incur any costs. This transaction does not meet the definition of an in-kind contribution and should not be recorded as an in-kind match. 3. For 2 transactions, federal commodities were used for match that were received from another federal program. Recommendation: Provide additional training and emphasize adherence to established policies and procedures to ensure maintenance of documentation for valuation, distribution and documentation of matching grant funds. Planned corrective action: Finance and programmatic staff assigned to programs with matching requirements will communicate and review activity monthly to ensure eligibility and adherence with program requirements. Increased documentation of valuation and allocation of items included in match reporting will be maintained. Responsible officer: Jennifer Garcia, Chief Financial Officer and Jeff Watkins, Chief International Initiatives Officer. Estimated completion date: April 2024.