Finding 1162595 (2023-004)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2025-11-18

AI Summary

  • Core Issue: The Organization lacks proper documentation for program eligibility reviews, which is required by federal regulations.
  • Impacted Requirements: Compliance with 2 CFR § 200.300 is not met due to missing evidence of staff review and approval.
  • Recommended Follow-Up: Implement a policy to ensure all eligibility documents are reviewed and documented appropriately.

Finding Text

Finding 2023-004, Eligibility (Assistance Listing 93.567 and 93.576) Criteria: 2 CFR § 200.300 requires that the Federal Organization or pass-through entity must manage and administer the Federal award in a manner so as to ensure that Federal programs are implemented in full accordance with the U.S. Constitution, applicable Federal statutes and regulations. Condition and Context: The Organization’s maintains files for the documentation of program eligibility however those documents do not include evidence of review or approval by the Organization’s staff. In addition, 37 out of 60 samples didn’t include the signature of the interpreter which also served as case manager. There was no indication of who was handling the case unless the enrollment form was signed by the interpreter. Cause: Internal controls over the documentation of program eligibility were not operating effectively or designed properly. Effect: The review and approval performed on program eligibility was not documented. Identification as a repeat finding: No. Questioned costs: None. Recommendation: We recommend that the Organization institute a policy that provides for the documentation of the review of eligibility documents.

Corrective Action Plan

Finding 2023-004 Assistance Listings: 93.567 & 93.576 Issue: Eligibility documentation needed strengthening. Corrective Actions 1. Apricot Hard Stops – Mandatory ORR eligibility fields prevent enrollment without complete data. 2. Enhanced Case Notes – Case managers must document eligibility review and note interpreter use. 3. File Accountability – Physical files labeled with responsible case manager; cross-checked during audits. 4. Compliance Reviews – Compliance Coordinator conducts quarterly file audits. Responsible Official: Javid Siddiqi, Director of Immigration Services Implementation Date: Completed January 2025; quarterly monitoring ongoing.

Categories

Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1162588 2023-001
    Material Weakness Repeat
  • 1162589 2023-002
    Material Weakness Repeat
  • 1162590 2023-003
    Material Weakness Repeat
  • 1162591 2023-004
    Material Weakness Repeat
  • 1162592 2023-001
    Material Weakness Repeat
  • 1162593 2023-002
    Material Weakness Repeat
  • 1162594 2023-003
    Material Weakness Repeat
  • 1162596 2023-005
    Material Weakness Repeat
  • 1162597 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.567 REFUGEE AND ENTRANT ASSISTANCE VOLUNTARY AGENCY PROGRAMS $997,527
93.576 REFUGEE AND ENTRANT ASSISTANCE DISCRETIONARY GRANTS $872,576
19.510 U.S. REFUGEE ADMISSIONS PROGRAM $238,159
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $80,537
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $11,137