Finding 1167428 (2025-002)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2025-12-31

AI Summary

  • Core Issue: Internal controls over expense approvals are weak, allowing payments to be made without prior approval.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) is not met due to lapses in the approval process during a transition to a digital workflow.
  • Recommended Follow-Up: Management should review and reinforce policies to ensure all expenses are approved before payments are processed.

Finding Text

Passed through Lutheran Immigration and Refugee Service dba Global Refuge Federal Financial Assistance Listing #19.510, 323‐24‐00, 10/01/2023 – 9/30/2024 Federal Financial Assistance Listing #19.510, 323‐25‐00, 10/01/2024 – 9/30/2025 U.S. Refugee Admissions Program Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: In the sample of expenditures selected for testing, two instances were identified where the approval over the expense occurred after the check was written. Cause: The Organization underwent a transitional phase from paper‐based documentation to a digital workflow using Salesforce. This system change likely contributed to deviations in the established processes and internal controls, including the sequence of expense approvals. Effect: Lack of compliance with designed internal controls over disbursements allows for payment of expenses that were not approved prior to checks being written. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 payroll and nonpayroll disbursements out of more than 250 payroll and nonpayroll disbursements were selected for testing which included $31,198 out of $756,944. Repeat Finding from Prior Year: No Recommendation: We recommend management review the Organization’s policies, procedures and controls over expenses with applicable program employees to ensure approval of expenses occurs prior to checks being written and payments being made. View of Responsible Officials: Management is in agreement.

Corrective Action Plan

Federal Agency Name: Department of State Assistance Listing Number: 19.510 Program Name: U.S. Refugee Admissions Program Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Summary: Two instances were identified where the approval over the expense occurred after the check was written. Responsible Individuals: Nathan Beyer, Staci Jonson, Dana Boraas Corrective Action Plan: Procedures will be reviewed with staff to ensure staff are fully trained on the proper sequence of approval and release of checks. Where appropriate, procedures may be modified to ensure proper approval is obtained and documented, prior to checks being delivered to clients. Anticipated Completion Date: December 31, 2025

Categories

Allowable Costs / Cost Principles HUD Housing Programs Significant Deficiency

Other Findings in this Audit

  • 1167427 2025-001
    Material Weakness Repeat
  • 1167429 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $2.43M
19.510 U.S. REFUGEE ADMISSIONS PROGRAM $784,095
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $748,924
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $669,541
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $272,471
93.576 REFUGEE AND ENTRANT ASSISTANCE DISCRETIONARY GRANTS $242,438
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $206,121
93.567 REFUGEE AND ENTRANT ASSISTANCE VOLUNTARY AGENCY PROGRAMS $184,945
93.623 BASIC CENTER GRANT $163,676
14.169 HOUSING COUNSELING ASSISTANCE PROGRAM $144,378
16.832 Children of Incarcerated Parents Web Portal $138,458
93.583 REFUGEE AND ENTRANT ASSISTANCE WILSON/FISH PROGRAM $116,143
10.555 NATIONAL SCHOOL LUNCH PROGRAM $102,568
21.019 CORONAVIRUS RELIEF FUND $99,899
97.010 CITIZENSHIP EDUCATION AND TRAINING $87,657
16.021 JUSTICE SYSTEMS RESPONSE TO FAMILIES $83,229
10.553 SCHOOL BREAKFAST PROGRAM $56,585
16.540 JUVENILE JUSTICE AND DELINQUENCY PREVENTION $55,011
93.235 TITLE V STATE SEXUAL RISK AVOIDANCE EDUCATION (TITLE V STATE SRAE) PROGRAM $27,303
16.575 CRIME VICTIM ASSISTANCE $20,876
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $15,865
10.558 CHILD AND ADULT CARE FOOD PROGRAM $5,862
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $1,401
84.425 EDUCATION STABILIZATION FUND $77