Finding 1156543 (2024-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
$1
Year
2024
Accepted
2025-09-30
Audit: 368884
Organization: Samaritas and Subsidiaries (MI)
Auditor: Clark Nuber P S

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance, leading to ineligible participants receiving benefits under the Refugee Admissions Program.
  • Impacted Requirements: Compliance with Title 2 U.S. Code of Federal Regulations, which mandates effective internal controls to ensure only eligible participants receive federal awards.
  • Recommended Follow-Up: Implement stronger internal controls to verify eligibility of participants before disbursing federal funds.

Finding Text

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.

Corrective Action Plan

Contact Person(s): Bridgette Zappacosta Corrective Action Planned: Management concurs with the finding. The Organization will strengthen eligibility verification procedures to ensure that only participants meeting the specific award requirements are approved for benefits. This will include: revising intake and eligibility documentation protocols to require verification and supervisory sign-off that the individual meets the award’s eligibility definition and providing targeted staff training on eligibility requirements under the Refugee Admissions Program. Quarterly internal reviews of eligibility determinations will be conducted, with exceptions reported to management for corrective action. Anticipated Completion Date: December 31, 2025

Categories

Questioned Costs Eligibility Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 1156533 2024-001
    Material Weakness Repeat
  • 1156534 2024-001
    Material Weakness Repeat
  • 1156535 2024-001
    Material Weakness Repeat
  • 1156536 2024-001
    Material Weakness Repeat
  • 1156537 2024-001
    Material Weakness Repeat
  • 1156538 2024-001
    Material Weakness Repeat
  • 1156539 2024-001
    Material Weakness Repeat
  • 1156540 2024-002
    Material Weakness Repeat
  • 1156541 2024-002
    Material Weakness Repeat
  • 1156542 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.576 Refugee and Entrant Assistance Discretionary Grants $327,005
93.567 Refugee and Entrant Assistance Voluntary Agency Programs $311,435
10.569 Emergency Food Assistance Program (food Commodities) $154,635
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $140,937
19.510 U.s. Refugee Admissions Program $107,498
14.231 Emergency Solutions Grant Program $86,551
93.959 Block Grants for Prevention and Treatment of Substance Abuse $68,336
93.558 Temporary Assistance for Needy Families $62,685
10.568 Emergency Food Assistance Program (administrative Costs) $48,565
93.583 Refugee and Entrant Assistance Wilson/fish Program $48,180
14.267 Continuum of Care Program $37,570
93.676 Unaccompanied Children Program $14,967
97.024 Emergency Food and Shelter National Board Program $9,500
93.778 Medical Assistance Program $3,908
14.218 Community Development Block Grants/entitlement Grants $2,500
93.658 Foster Care Title IV-E $218
93.659 Adoption Assistance $152