Finding 1226195 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-08-10
Audit: 408833
Organization: Opening Doors, Inc. (CA)

AI Summary

  • Core Issue: Lack of documented supervisory review and approval for eligibility determinations in the Refugee and Entrant Assistance program.
  • Impacted Requirements: Compliance with federal eligibility determination procedures, risking approval of ineligible individuals for services.
  • Recommended Follow-Up: Implement stronger controls by requiring Program Managers to document reviews and establish periodic monitoring to ensure compliance.

Finding Text

Federal Agency: U.S. Department of Health & Human Services Federal Program Name: Refugee and Entrant Assistance Voluntary Agency Programs Assistance Listing Number: 93.576 Federal Award Identification Number and Year: Various, see below Pass-Through Agency: Various, see below Pass-Through Number: Various, see below Award Period: Various, see below Compliance Requirement Affected: Eligibility Direct Agency Direct Award number Award Period Pass Through Entity (or) Pass Through Number U.S. Department of Health & Human Services (Direct) 90ZQ0011-01-0 9/30/24-9/29/28 U.S. Department of Health & Human Services Passed through Council on American-Islamic Relations, Greater Los Angeles ALSP23-0001 10/1/24-10/31/26 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Program eligibility determinations should be supported by completed intake documentation and evidenced by supervisory review and approval in accordance with the organization's established eligibility determination procedures. Condition: CLA noted the selected intake form/applications did not contain the Program Manager's signature or other evidence of review and approval. As a result, CLA was unable to verify that the eligibility determination was reviewed and approved in accordance with established procedures. Questioned Costs: None noted Context: A nonstatistical sample of 40 of over 250 clients served were selected for testing for the Refugee and Entrant Assistance Voluntary Agency Programs program. The condition noted above was identified during our procedures over ODI's Eligibility Federal compliance requirements. Effect: Without documented review and approval, there is an increased risk that individuals who do not meet program eligibility requirements could be approved for services, resulting in noncompliance with federal program requirements and potential questioned costs. Cause: Management did not consistently document supervisory review and approval of intake forms/applications or retain evidence demonstrating that the required review control was performed. Repeat Finding: The finding is not a repeat finding. Recommendation: CLA recommends management strengthen controls over eligibility determinations by requiring Program Managers to document and retain evidence of review and approval of all intake forms/applications before services are provided. Management should also implement periodic monitoring procedures to ensure review approvals are consistently documented and maintained for audit purposes. Management’s Views: See Separate Corrective Action Plan.

Corrective Action Plan

Auditor's Recommendation: Strengthen controls over eligibility determinations by requiring Program Managers to document and retain evidence of review and approval of all intake forms/applications before services are provided. Management should also implement periodic monitoring procedures to ensure review approvals are consistently documented and maintained for audit purposes. Management Response: ODI is diligent in understanding and implementing the steps necessary to review and collect the required documentation to determine client eligibility for programs. Due to the large number of clients serviced and the volume of documents collected and reviewed, many of the programs track eligibility via proprietary on line portals provided by the funders to capture and document the steps performed to determine eligibility. These portals automatically determine whether a client is eligible based on the information provided. The Program Managers see the client eligibility on the portal when they assign caseworkers to the clients, but there is no formal Program Manager signature provided or captured in the portal. Corrective Action: • Regarding the specific program 90ZQ(l}011-01-0 Support for Trauma-Affected Refugees (STAR} referenced in this finding, client eligibility is determined by requirements established by the Office of Refugee Resettlement (ORR} that apply to other programs administered by ODI. To address the auditor's recommendation regarding this program, ODI will set up a procedure to review and retain documentation for clients entering the STAR program or who were referred from other ORR programs showing they are eligible to receive the STAR services. •Regarding the specific program ALSP23-0001 Afghan Legal Services Project (ALSP}, ODI has serviced, and is still servicing, approximately 500 clients. Although ODI asserts that it has and retains the documentation to demonstrate client eligibility for this program, to address the auditor's recommendation, ODI will set up a procedure to track and document that the program manager will approve. Responsible Personnel: Mao Vang, Health & SOT Program Director; Alyssa Eckels, ILS Program Director Implementation Date: Immediate implementation

Categories

Questioned Costs Subrecipient Monitoring Eligibility Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1226194 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
19.510 U.S. REFUGEE ADMISSIONS PROGRAM $2.35M
14.267 CONTINUUM OF CARE PROGRAM $479,152
21.020 COMMUNITY DEVELOPMENT FINANCIAL INSTITUTIONS PROGRAM $102,029
93.569 COMMUNITY SERVICES BLOCK GRANT $74,329
93.576 REFUGEE AND ENTRANT ASSISTANCE DISCRETIONARY GRANTS $53,273
59.046 MICROLOAN PROGRAM $34,758