Finding 1217672 (2025-008)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-06-16

AI Summary

  • Core Issue: Incomplete documentation and eligibility verification for refugee assistance programs, with significant gaps in client files.
  • Impacted Requirements: Compliance with federal eligibility guidelines for the U.S. Department of Health and Human Services programs.
  • Recommended Follow-Up: Enhance internal controls and procedures to ensure proper documentation and retention of eligibility determinations.

Finding Text

Finding #2025-008 – Eligibility – Material Weakness and Material Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, 93.566, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Passed through Texas Office for Refugees: 10/01/24 – 09/30/25, FFY2025-27946V-ASA RSS, 10/01/24 – 09/30/25, FFY2025-27946V-AUSAA-RSS, 10/01/24 – 09/30/25, FFY2025-27946V-CMA, 10/01/24 – 09/30/25, FFY2025-27946V-RSS, Passed through United States Conference of Catholic Bishops: 10/01/24 – 09/30/25, 25RSI13A, Passed through U. S. Committee for Refugees: 10/01/24 – 09/30/25, RHP-2025-YMCA-Houston TX-03, 93.567, Refugee and Entrant Assistance Voluntary Agency Programs, Passed through U. S. Committee for Refugees and Immigrants: 10/01/24 – 09/30/25, 2502VARVMG, 10/01/23 – 09/30/24, 2402VARVMG. Criteria: Eligibility – The YMCA is responsible for having internal control procedures for its client intake process to ensure that only eligible clients are served and documentation of their eligibility is maintained. Condition and context: The following exceptions were noted in the testing of eligibility and maintenance of documentation: Refugee and Entrant Assistance State/Replacement Designee Administered Programs – 25 out of 40 files tested for eligibility and maintenance of documentation were incomplete and lacked information to support the eligibility of the participants, and 5 out of 40 files could not be located. Refugee and Entrant Assistance Voluntary Agency Programs – 11 out of 40 files tested for eligibility and maintenance of documentation were incomplete and lacked information to support the eligibility of the participants. Effect: Failure to follow eligibility guidelines and maintain documentation of the determination of eligibility could result in ineligible participants being served. Recommendation: Strengthen policies and procedures to ensure the documentation and retention of eligibility determinations. Views of responsible officials: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Finding #2025-008 – Eligibility – Material Weakness and Material Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, 93.566, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Passed through Texas Office for Refugees: 10/01/24 – 09/30/25, FFY2025-27946V-ASA RSS, 10/01/24 – 09/30/25, FFY2025-27946V-AUSAA-RSS, 10/01/24 – 09/30/25, FFY2025-27946V-CMA, 10/01/24 – 09/30/25, FFY2025-27946V-RSS, Passed through United States Conference of Catholic Bishops: 10/01/24 – 09/30/25, 25RSI13A, Passed through U. S. Committee for Refugees: 10/01/24 – 09/30/25, RHP-2025-YMCA-Houston TX-03, 93.567, Refugee and Entrant Assistance Voluntary Agency Programs, Passed through U. S. Committee for Refugees and Immigrants: 10/01/24 – 09/30/25, 2502VARVMG, 10/01/23 – 09/30/24, 2402VARVMG. Condition and context: The following exceptions were noted in the testing of eligibility and maintenance of documentation: Refugee and Entrant Assistance State/Replacement Designee Administered Programs – 25 out of 40 files tested for eligibility and maintenance of documentation were incomplete and lacked information to support the eligibility of the participants, and 5 out of 40 files could not be located. Refugee and Entrant Assistance Voluntary Agency Programs – 11 out of 40 files tested for eligibility and maintenance of documentation were incomplete and lacked information to support the eligibility of the participants. Planned corrective action: Management acknowledges the deficiencies identified related to documentation and retention of eligibility determinations and notes that the programs associated with this finding are no longer active within the organization. The organization maintained procedures for determining client eligibility prior to the provision of services; however, in certain instances, supporting documentation was either incomplete or not available for review at the time of audit testing. Management conducted an extensive search for the requested files and determined that the missing or incomplete documentation was primarily attributable to operational disruption during a period of organizational transition, including staffing changes and the transfer or wind-down of the specific programs noted. While documentation was not consistently retained or retrievable in these instances, management does not believe this indicates that eligibility determinations were not performed. In response, management has reinforced documentation and retention procedures across current programs, including clearer expectations for file completeness and centralized retention practices to ensure documentation remains accessible regardless of staffing or program transitions. Management will continue to monitor compliance with these procedures to strengthen consistency in documentation and retention of eligibility determinations. Responsible officer: Lauren Rome, VP of Financial Operations/Interim CFO. Estimated completion date: May 15, 2026

Categories

Eligibility Material Weakness

Other Findings in this Audit

  • 1217660 2025-005
    Material Weakness Repeat
  • 1217661 2025-006
    Material Weakness Repeat
  • 1217662 2025-008
    Material Weakness Repeat
  • 1217663 2025-005
    Material Weakness Repeat
  • 1217664 2025-006
    Material Weakness Repeat
  • 1217665 2025-008
    Material Weakness Repeat
  • 1217666 2025-005
    Material Weakness Repeat
  • 1217667 2025-006
    Material Weakness Repeat
  • 1217668 2025-008
    Material Weakness Repeat
  • 1217669 2025-005
    Material Weakness Repeat
  • 1217670 2025-006
    Material Weakness Repeat
  • 1217671 2025-007
    Material Weakness Repeat
  • 1217673 2025-005
    Material Weakness Repeat
  • 1217674 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.676 UNACCOMPANIED ALIEN CHILDREN PROGRAM $4.34M
16.575 CRIME VICTIM ASSISTANCE $845,536
93.567 REFUGEE AND ENTRANT ASSISTANCE VOLUNTARY AGENCY PROGRAMS $673,532
16.320 SERVICES FOR TRAFFICKING VICTIMS $653,338
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $442,404
93.576 REFUGEE AND ENTRANT ASSISTANCE DISCRETIONARY GRANTS $370,306
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $307,255
19.510 U.S. REFUGEE ADMISSIONS PROGRAM $294,094
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $269,918
10.187 THE EMERGENCY FOOD ASSISTANCE PROGRAM (TEFAP) COMMODITY CREDIT CORPORATION ELIGIBLE RECIPIENT FUNDS $64,551
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $55,399
97.010 CITIZENSHIP EDUCATION AND TRAINING $39,775
10.558 CHILD AND ADULT CARE FOOD PROGRAM $32,163
10.555 NATIONAL SCHOOL LUNCH PROGRAM $11,161
10.182 PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $3,566
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $2,624