Finding Text
Finding No. 2025-006: Eligibility Documentation and Record Retention Controls Federal Program Name: Refugee and Entrant Assistance State/Replacement Designee Administered Programs; Refugee and Entrant Assistance Discretionary Grants Federal Assistance Listing Number: 93.566; 93.576 Type of Finding Significant Deficiency in Internal Control over Compliance; Other Matters Criteria Grant requirements require organizations to obtain, maintain, and retain documentation supporting participant eligibility and compliance with program requirements. Such documentation should be complete, properly executed, and readily available for review. Condition During our review of participant eligibility documentation, we noted exceptions related to the completion, retention, and availability of required participant documentation. Specifically, required service plans and self-sufficiency plans were not consistently completed, signed, retained, or available for review for certain participants. Management indicated that documentation requirements were not always clearly communicated during the implementation of certain programs and that requirements evolved over time as additional guidance was received from funding agencies. In addition, participant records were historically maintained in multiple formats and locations. IRIS also experienced operational challenges, including the transition from paper-based to electronic records, office transitions, program implementation changes, and flooding that damaged certain stored client files and rendered some records unrecoverable. Questions Costs None Context Of the 60 participants selected for testing, 23 of the selections were not in compliance due to lack of supporting documentation. Effect As a result, IRIS was unable to demonstrate compliance with certain participant eligibility documentation requirements for a limited number of participants selected for testing. Missing or incomplete documentation may result in audit exceptions, monitoring findings, and an inability to demonstrate participant eligibility. Cause IRIS did not maintain formalized procedures governing participant eligibility documentation, file review, record retention, and documentation monitoring across certain programs. Repeat Finding Yes. This finding was also reported in the prior year as Finding 2024-002. Recommendation We recommend that management establish and document formal procedures for obtaining, reviewing, retaining, and periodically monitoring participant eligibility documentation. Procedures should identify required documentation by program, assign responsibility for file review, establish record retention standards, and include safeguards to protect records from loss or damage. Management should also perform periodic reviews of participant files to verify that required documentation is complete, properly executed, and retained in accordance with program requirements. Management’s Response/Views of Responsible Officials See Auditee’s Corrective Action Plan.