Finding 1217673 (2025-005)

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

AI Summary

  • Core Issue: There is a material weakness in internal controls over federal funds, leading to noncompliance with federal requirements.
  • Impacted Requirements: Compliance with 2 CFR Part 200, which mandates effective internal controls and proper documentation of costs for federal awards.
  • Recommended Follow-Up: Management acknowledges the issue and has a corrective action plan in place; ensure implementation and monitor progress.

Finding Text

Finding #2025-005 – Material Weakness and Other 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, 93.676, Unaccompanied Alien Children Program, Passed through U. S. Committee for Refugees and Immigrants: 01/01/25 – 12/31/25, 90ZU0630-02. Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 requires recipients and subrecipients of federal funds to establish, document, and maintain effective internal control over federal awards that provides reasonable assurance that the recipient is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, section 200.403 indicates that costs charged to federal awards must be necessary and reasonable for the performance of the program and be adequately documented. Condition and context: Same as finding #2025-001. Cause: Same as finding #2025-001. Effect: Same as finding #2025-001. Questioned costs: $1,275. Recommendation: Same as finding #2025-001. View of responsible officials: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Findings #2025-001 and #2025-005 – Material Weakness. 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, 93.676, Unaccompanied Alien Children Program, Passed through U. S. Committee for Refugees and Immigrants: 01/01/25 – 12/31/25, 90ZU0630-02. Condition and context: During the planning phase of the audit, management disclosed that amounts reported as employee withholdings on Form 941 had been intentionally manipulated by the former payroll director resulting over reporting withholdings to the Internal Revenue Service. Management did not have a formal reconciliation process in place to compare Form 941 to the payroll register and general ledger, nor was there a periodic reconciliation of the payroll register to the general ledger. The absence of these independent reconciliation controls allowed the misstatement to occur and not be detected in a timely manner. In our testing of 110 payroll transactions, we identified the following exceptions: Refugee and Entrant Assistance State/Replacement Designee Administered Programs (ALN 93.566) – 1 out of 40 payroll transactions tested utilized the incorrect pay rate. Unaccompanied Alien Children Program (ALN 93.676) – 1 out of 40 payroll transactions tested utilized the incorrect pay rate. Refugee and Entrant Assistance State/Replacement Designee Administered Programs (ALN 93.566) – 1 out of 40 payroll transactions tested was incorrectly charged to the program. Additionally, in testing the reconciliation of payroll expense recorded in the payroll register to the amount recorded in the general ledger system, an error of $349,000 was identified. The error was related to credit card charges erroneously being recorded to payroll expense. Recommendation: Policies and procedures should be designed and implemented to prepare a formal reconciliation of Form 941 to the payroll register and the general ledger and a reconciliation between the payroll register and the general ledger. Additionally, procedures should be strengthened over the review of pay rates utilized in the payroll system and the allocation of payroll to cost centers and government programs. Planned corrective action: Management acknowledges the deficiency identified in the execution and precision of payroll reconciliation processes. During the audit planning phase, management disclosed that a former payroll director intentionally manipulated employee withholding amounts reported on Form 941 in prior periods. While reconciliation procedures between the payroll register, general ledger, and Form 941 filings were in place, they were not performed with sufficient precision and consistency to detect the misstatement in a timely manner. Additionally, audit testing identified isolated instances of incorrect payrates and program allocations, as well as a misclassification of approximately $349,000 related to credit card return charges recorded to accrued payroll; management has confirmed this item represents a classification error and not an issue impacting payroll processing or employee compensation. In response, management has refined reconciliation procedures to require more detailed comparison across systems, established clearer expectations for investigation and resolution of variances, and enhanced documentation standards to evidence the level of review performed. Management has also strengthened oversight of payroll activity, including review of payrates and allocation of payroll costs to programs, and will continue to monitor these controls to ensure they are operating with an appropriate level of precision and consistency. In May 2026, an interim leadership structure was established in response to the departure of the Chief Financial Officer. During this interim period management is assessing departmental functions and organizational structure to better align responsibilities and further strengthen internal controls in the areas noted above. Responsible officer: Lauren Rome, VP of Financial Operations/Interim CFO. Estimated completion date: June 15, 2026.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness Internal Control / Segregation of Duties

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
  • 1217672 2025-008
    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