Finding 1239639 (2024-006)

Material Weakness Repeat Finding
Requirement
ABCEHL
Questioned Costs
-
Year
2024
Accepted
2026-09-30

AI Summary

  • Core Issue: A material weakness in internal controls led to a disclaimer of opinion on compliance due to inaccessible data for five out of six compliance requirements.
  • Impacted Requirements: The inability to test compliance with key areas such as Allowable Costs, Cash Management, and Eligibility affects approximately 79% of the program's revenue.
  • Recommended Follow-Up: AIRS should work with ADES to restore ARRPODS access and consider maintaining independent records to avoid future data access issues.

Finding Text

Program Title: Refugee and Entrant Assistance State Administered Programs — Afghan Supplemental Services (Contract No. CTR061924) Federal Financial Assistance Listing Number: 93.566 Federal Award Year: 2024 Federal Agency: U.S. Department of Health and Human Services, passed through the Arizona Department of Economic Security Type of Finding: Material Weakness in Internal Control over Compliance / Scope Limitation resulting in Disclaimer of Opinion Criteria: Compliance requirements identified as direct and material to Contract No. CTR061924 under ALN 93.566 include Activities Allowed or Unallowed (A), Allowable Costs/Cost Principles (B), Cash Management (C), Eligibility (E), Period of Performance (H), and Reporting (L), per the 2025 OMB Compliance Supplement, Part 4, ALN 93.566. Condition: Of these six requirements, only the administrative-claim component of Allowable Costs (B) was substantively tested, using AIRS’s own accounting records. The remaining five requirements could not be tested because the evidence needed — ARRPODS-based unit/task activity records and client A-number eligibility data — was inaccessible. The Arizona Department of Economic Security (ADES) confirmed in writing (correspondence dated September 10, 2026) that this data is currently unavailable due to a stateside data conversion, a condition compounded by the inactive status of Contract No. CTR061924 for FY2024 and FY2025. Cause: This is an inherent scope limitation arising from circumstances beyond the control of both AIRS and the engagement team, rather than a restriction imposed by management, consistent with AU-C §705.13. AIRS does not maintain source documentation independent of ADES’s ARRPODS system sufficient to support billed units under CTR061924 in the event ARRPODS is unavailable. Effect: The engagement team was unable to obtain sufficient appropriate audit evidence regarding compliance with five of six direct-and-material requirements for a contract representing approximately 79% of the dollar volume and 64% of the invoices tested within ALN 93.566. Because AIRS invoices ADES across all four ALN 93.566 contracts on a combined, purpose-code basis, this evidence gap could not be isolated to a separable population of transactions and is pervasive to the program as a whole, resulting in a disclaimer of opinion on compliance for ALN 93.566. Because CTR061924 revenue is recognized on the same unit-earned basis for financial reporting purposes, the same evidence gap also contributed to the qualified opinion on the basic financial statements taken as a whole (see the Independent Auditor’s Report).Questioned Costs: Undeterminable due to the scope limitation. An estimated $600,000–$650,000 of ALN 93.566 revenue and the related receivable could not be substantiated (applying the approximate 79% sample proportion to total program revenue of approximately $800,000 on a pre-adjustment, cash basis). Following the GAAP accrual-basis correction described in Finding 2024-002, total ALN 93.566 program revenue increased to $1,122,212, as reflected in the Schedule of Expenditures of Federal Awards; the $600,000–$650,000 estimate reflects the pre-adjustment base and was not recalculated on the adjusted amount. This amount is not characterized as a questioned cost in the 2 CFR 200.516 sense because it reflects an inability to test, rather than an identified instance of noncompliance or unallowable cost. Repeat Finding from Prior Year: No — new condition for FY2024. (ALN 93.566 received an unmodified compliance opinion in FY2023; the qualified opinion issued for FY2023 pertained to the separate ALN 93.567 program’s matching requirement, Finding 2023-006.) Recommendation: AIRS should coordinate with ADES on restoring ARRPODS access and evaluate whether independently maintained case-management task logs or client files could substitute for ARRPODS extracts in future periods, so that a similar scope limitation does not recur for FY2025. Views of Responsible Officials: Management concurs with this audit finding Corrective Action Plan: See corrective action plan

Corrective Action Plan

AIRS management will work with ADES to gain access to the ARRPODS data. AIRS will also begin to keep records outside of ADES systems.

Categories

Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 1239635 2024-004
    Material Weakness Repeat
  • 1239636 2024-005
    Material Weakness Repeat
  • 1239637 2024-004
    Material Weakness Repeat
  • 1239638 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $1.12M
93.567 REFUGEE AND ENTRANT ASSISTANCE VOLUNTARY AGENCY PROGRAMS $991,344
19.510 U.S. REFUGEE ADMISSIONS PROGRAM $963,812
93.576 REFUGEE AND ENTRANT ASSISTANCE DISCRETIONARY GRANTS $550,242
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $448,597