Finding 1158212 (2024-003)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 370111
Organization: Jesuit Refugee Service/usa, INC (DC)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The Organization failed to submit required tax reports for foreign assistance funds, violating grant agreements.
  • Impacted Requirements: Annual tax reports must be submitted by February 15 for the prior fiscal year, affecting multiple countries.
  • Recommended Follow-Up: Establish a formal process to ensure timely submission of all required reports, addressing management turnover issues.

Finding Text

Finding 2024-003 – Tax disclosure submission Federal Agency: U.S. Department of State Program: Overseas Refugee Assistance Programs for Africa, Overseas Refugee Assistance Program for Middle East and North Africa Program, Overseas Refugee Assistance Programs for East Asia Assistance listing number: 19.517, 19.519, 19.511 Federal award identification number and year: • SPRMCO22CA0165 – 2022 • SPRMCO23CA0142 – 2023 • SPRMCO23CA0092 – 2023 • SPRMCO24CA0074 – 2024 • SPRMCO23CA0200 – 2023 • SPRMCO24CA0240 – 2024 • SPRMCO23CA0122 – 2023 Criteria: Per the grant agreements to the above awards section 19 Reporting Taxes on Foreign Assistance Funds. The Recipient is required to submit a report detailing foreign taxes assessed under this award during the prior U.S. Government fiscal year (October 1 through September 30). The report must be submitted to the Grants Officer on an annual basis by February 15. Condition: The Organization is required to comply with conditions listed in their grant agreements. Management had processes in place to submit each tax report on a timely basis; however these processes did not occur. Grant countries impacted: Cameroon, South Sudan, Uganda, Ethiopia, Iraq and Thailand. Cause: The cause is due to frequent turnover in key management positions, which disrupted the continuity of established submission procedures. Effect: The Organization failed to comply with the submission requirements for the tax reports in violation of the grant agreement. Context: Out of a population of 14 filings, seven were selected for testing. All seven did not meet the submission requirement. Questioned costs: There are no questioned costs noted. Recommendation: Management should implement a formalized process to ensure that submission requirements are met. Views of responsible officials: Management agrees with findings. See corrective action plan.

Corrective Action Plan

Finding Tax Disclosure Submission. Per the grant agreements to the above awards section 19 Reporting Taxes on Foreign Assistance Funds. The Recipient is required to submit a report detailing foreign taxes assessed under this award during the prior U.S. Government fiscal year (10/01 - 09/30). The report must be submitted to the Grants Officer on an annual basis by February 15. Management had processes in place to submit each tax report on a timely basis; however these processes did not occur. Grant countries impacted: Cameroon, South Sudan, Uganda, Ethiopia, Iraq, and Thailand. Corrective Action Plan Management concurs with the findings. Although internal procedures for timely submission of the foreign tax reports were previously in place, the organization experienced significant turnover in key management positions during the reporting period. This transition disrupted the continuity of compliance processes and led to failure to meet the tax disclosure reporting deadlines. To prevent recurrence of this compliance lapse, JRS/USA is taking the following corrective measures: 1. Formalized Tax Reporting SOP A formal Standard Operating Procedure (SOP) will be developed for the Foreign Tax Disclosure Reporting Process, outlining: a) Roles and responsibilities (JRS/USA and country offices) b) Required data sources c) Timeline for data collection and submission d) Review and approval workflows This SOP will be distributed to all relevant compliance, finance, and grant management staff. 2. Centralized Calendar and Tracker A centralized compliance calendar and submission tracker will be implemented, incorporating the February 15 foreign tax report deadline. Automated reminders will be sent to responsible staff beginning in January each year to initiate the reporting process well in advance. 3. Designated Focal Point A single point of contact at JRS/USA has been assigned as the Tax Disclosure Focal Point, responsible for: a) Coordinating data collection from field offices b) Ensuring timely submission to the Grants Officer c) Maintaining documentation of the submission and confirmation of receipt 4. Training and Onboarding Updates Compliance and finance staff, both at JRS/USA and in the field, will be trained on the tax disclosure requirements and the new SOP. This training will also be integrated into the onboarding process for new hires in relevant roles to reduce the risk of future disruptions due to staff turnover. 5. Quarterly Internal Compliance Check-ins Although the report is submitted annually, quarterly check-ins will be held by the JRS/USA Compliance Team to review upcoming deadlines, including the tax report, to ensure ongoing visibility and proactive planning. Timeline for Implementation All corrective actions have been implemented or will be fully in effect by October 30, 2025. Responsible Party Samira Ahmed, Senior Grants and Compliance Specialist, will be responsible for overseeing the tax disclosure process and ensuring timely and accurate submissions going forward.

Categories

Reporting

Other Findings in this Audit

  • 1158203 2024-002
    Material Weakness Repeat
  • 1158204 2024-003
    Material Weakness Repeat
  • 1158205 2024-002
    Material Weakness Repeat
  • 1158206 2024-003
    Material Weakness Repeat
  • 1158207 2024-003
    Material Weakness Repeat
  • 1158208 2024-003
    Material Weakness Repeat
  • 1158209 2024-002
    Material Weakness Repeat
  • 1158210 2024-003
    Material Weakness Repeat
  • 1158211 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
19.518 Overseas Refugee Assistance Programs for Western Hemisphere $1.13M
19.519 Overseas Refugee Assistance Program for Middle East and North Africa Program $853,689
19.517 Overseas Refugee Assistance Programs for Africa $655,724
19.511 Overseas Refugee Assistance Programs for East Asia $369,627
19.523 Overseas Refugee Assistance Program for South Asia $65,285
97.141 Shelter and Services Program $20,131