FAC Explorer

Finding 33215 (2022-005)

Significant Deficiency
Requirement
H
Questioned Costs
$1
Year
2022
Accepted
2023-04-16
Audit: 36467
Organization: Heartland Alliance for Human Needs & Human Rights (IL)
Auditor: Bdo USA LLP

AI Summary

  • Core Issue: Management failed to maintain proper documentation for expenditures charged to federal programs within the required period of performance.
  • Impacted Requirements: Noncompliance with CFR regulations regarding internal controls and cost allocation could lead to improper charging of expenses.
  • Recommended Follow-Up: Implement and consistently follow policies to ensure documentation of expenditures is maintained and compliant with period of performance requirements.

Finding Text

2022-005: Internal Control Over Compliance and Compliance with Period of Performance Program: U.S. Department of State AL Number: 19.016 AL Name: Iraq Assistance Program Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SLMAQM19GR2288 September 29, 2019 through June 30,2022 Program: U.S. Department of State AL Number: 19.518 AL Name: Overseas Refugee Assistance Program for Western Hemisphere Grant Award Numbers Under the Uniform Guidance Requirements: Direct Award Number Award Period SPRMCO20CA0209 September 20, 2020 through September 29, 2021 N/A September 20, 2021 through September 29, 2022 Criteria - CFR ?200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its grants? period of performance process. In accordance with CFR Section 200.403(h), cost must be incurred during the approved budget period. The federal awarding agency is authorized at its discretion to waive prior written approvals to carry forward unobligated balances to subsequent budget period pursuant to ?200.308(e)(3). In accordance with CFR Section 200.458, pre-award costs are those incurred prior to the effective date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. Such costs are allowable only to the extent they would have been allowable if incurred after the date of the federal award and only with the written approval of the federal awarding agency. In accordance with CFR Section 200.344, the federal awarding agency or pass-through entity will close out the federal award when it determines that all applicable administrative actions and all required work of the federal award have been completed by the nonfederal entity. Per CFR Section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance. Condition ? During our testing of period of performance, we noted exceptions in the ability of management to support expenditures were incurred and charged to federal programs within the period of performance. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were incurred during the period of performance and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect - The lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with laws, regulations, and the provisions of grant agreements, which could ultimately lead to expenditures not being charged to the major programs in the correct period. Questioned Costs ? $29,459 Context: Assistance Listing Number: 19.016 During our testing of the period of performance compliance requirement for grant award periods that ended during the fiscal year, we sampled 12 expenditures, totaling $292,901, for the Iraq Assistance Program and noted one item amounting to $28,766 did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Additionally, during our testing of the period of performance compliance requirement for grant costs incurred throughout the year, we sampled 40 expenditures, totaling $11,811, for the Iraq Assistance Programs and noted that four items, totaling $672, did not have proper documentation for the allocation of the expenditure. Assistance Listing Number: 19.518 During our testing of the period of performance compliance requirement for grant award periods that started and ended during the fiscal year, we sampled 81 expenditures, totaling $15,252, for the Overseas Refugee Assistance Program for Western Hemisphere and noted two items, totaling $21, did not have adequate supporting documentation for the subrecipient expenditures charged to the program. Repeat Finding - This finding is not a repeat finding. Recommendation - We recommend that the Organization ensure its policies and procedures ensure that documentation of when the expenditure was incurred and liquidated is maintained and that these policies and procedures are followed on a consistent basis. Views of Responsible Officials - Management agrees with the finding and takes responsibility to comply with the period of performance compliance requirements. Management through the local offices has already developed a policy to ensure that the period of performance is adhered to.

Corrective Action Plan

Finding 2022-005: Internal Control Over Compliance and Compliance with Period of Performance Management through the local offices has already developed a policy to ensure that the period of performance is adhered too. Management is in the process of hiring another international compliance officer in both US and Iraq to particularly focus on grants performance requirements and sub-recipient grants management. Management through its Enterprise risk management is planning to schedule trainings for various departments concerning period of performance. Individual(s) Responsible for Corrective Action Plans: Simon Peter Kabogoza, Controller, Heartland Alliance International skabogoza@heartlandalliance.org Anticipated Completion Date: 12/2023

Categories

Questioned Costs Subrecipient Monitoring Period of Performance Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

Other Findings in this Audit

  • 33172 2022-007
    Significant Deficiency
  • 33173 2022-007
    Significant Deficiency
  • 33174 2022-004
    Significant Deficiency
  • 33175 2022-007
    Significant Deficiency
  • 33176 2022-004
    Significant Deficiency
  • 33177 2022-007
    Significant Deficiency
  • 33178 2022-004
    Significant Deficiency
  • 33179 2022-007
    Significant Deficiency
  • 33180 2022-004
    Significant Deficiency
  • 33181 2022-007
    Significant Deficiency
  • 33182 2022-004
    Significant Deficiency
  • 33183 2022-007
    Significant Deficiency
  • 33184 2022-004
    Significant Deficiency
  • 33185 2022-007
    Significant Deficiency
  • 33186 2022-004
    Significant Deficiency
  • 33187 2022-007
    Significant Deficiency
  • 33188 2022-004
    Significant Deficiency
  • 33189 2022-007
    Significant Deficiency
  • 33190 2022-004
    Significant Deficiency
  • 33191 2022-007
    Significant Deficiency
  • 33192 2022-004
    Significant Deficiency
  • 33193 2022-007
    Significant Deficiency
  • 33194 2022-004
    Significant Deficiency
  • 33195 2022-007
    Significant Deficiency
  • 33196 2022-004
    Significant Deficiency
  • 33197 2022-007
    Significant Deficiency
  • 33198 2022-004
    Significant Deficiency
  • 33199 2022-007
    Significant Deficiency
  • 33200 2022-004
    Significant Deficiency
  • 33201 2022-007
    Significant Deficiency
  • 33202 2022-004
    Significant Deficiency
  • 33203 2022-007
    Significant Deficiency
  • 33204 2022-007
    Significant Deficiency
  • 33205 2022-007
    Significant Deficiency
  • 33206 2022-007
    Significant Deficiency
  • 33207 2022-007
    Significant Deficiency
  • 33208 2022-007
    Significant Deficiency
  • 33209 2022-007
    Significant Deficiency
  • 33210 2022-007
    Significant Deficiency
  • 33211 2022-007
    Significant Deficiency
  • 33212 2022-007
    Significant Deficiency
  • 33213 2022-002
    Significant Deficiency
  • 33214 2022-003
    Significant Deficiency
  • 33216 2022-007
    Significant Deficiency
  • 33217 2022-002
    Significant Deficiency
  • 33218 2022-003
    Significant Deficiency
  • 33219 2022-005
    Significant Deficiency
  • 33220 2022-006
    Significant Deficiency Repeat
  • 33221 2022-007
    Significant Deficiency
  • 33222 2022-002
    Significant Deficiency
  • 33223 2022-003
    Significant Deficiency
  • 33224 2022-005
    Significant Deficiency
  • 33225 2022-006
    Significant Deficiency Repeat
  • 33226 2022-007
    Significant Deficiency
  • 37539 2022-002
    Significant Deficiency
  • 37540 2022-003
    Significant Deficiency
  • 37541 2022-005
    Significant Deficiency
  • 37542 2022-006
    Significant Deficiency Repeat
  • 37543 2022-007
    Significant Deficiency
  • 37544 2022-007
    Significant Deficiency
  • 37545 2022-007
    Significant Deficiency
  • 37546 2022-007
    Significant Deficiency
  • 37547 2022-007
    Significant Deficiency
  • 609614 2022-007
    Significant Deficiency
  • 609615 2022-007
    Significant Deficiency
  • 609616 2022-004
    Significant Deficiency
  • 609617 2022-007
    Significant Deficiency
  • 609618 2022-004
    Significant Deficiency
  • 609619 2022-007
    Significant Deficiency
  • 609620 2022-004
    Significant Deficiency
  • 609621 2022-007
    Significant Deficiency
  • 609622 2022-004
    Significant Deficiency
  • 609623 2022-007
    Significant Deficiency
  • 609624 2022-004
    Significant Deficiency
  • 609625 2022-007
    Significant Deficiency
  • 609626 2022-004
    Significant Deficiency
  • 609627 2022-007
    Significant Deficiency
  • 609628 2022-004
    Significant Deficiency
  • 609629 2022-007
    Significant Deficiency
  • 609630 2022-004
    Significant Deficiency
  • 609631 2022-007
    Significant Deficiency
  • 609632 2022-004
    Significant Deficiency
  • 609633 2022-007
    Significant Deficiency
  • 609634 2022-004
    Significant Deficiency
  • 609635 2022-007
    Significant Deficiency
  • 609636 2022-004
    Significant Deficiency
  • 609637 2022-007
    Significant Deficiency
  • 609638 2022-004
    Significant Deficiency
  • 609639 2022-007
    Significant Deficiency
  • 609640 2022-004
    Significant Deficiency
  • 609641 2022-007
    Significant Deficiency
  • 609642 2022-004
    Significant Deficiency
  • 609643 2022-007
    Significant Deficiency
  • 609644 2022-004
    Significant Deficiency
  • 609645 2022-007
    Significant Deficiency
  • 609646 2022-007
    Significant Deficiency
  • 609647 2022-007
    Significant Deficiency
  • 609648 2022-007
    Significant Deficiency
  • 609649 2022-007
    Significant Deficiency
  • 609650 2022-007
    Significant Deficiency
  • 609651 2022-007
    Significant Deficiency
  • 609652 2022-007
    Significant Deficiency
  • 609653 2022-007
    Significant Deficiency
  • 609654 2022-007
    Significant Deficiency
  • 609655 2022-002
    Significant Deficiency
  • 609656 2022-003
    Significant Deficiency
  • 609657 2022-005
    Significant Deficiency
  • 609658 2022-007
    Significant Deficiency
  • 609659 2022-002
    Significant Deficiency
  • 609660 2022-003
    Significant Deficiency
  • 609661 2022-005
    Significant Deficiency
  • 609662 2022-006
    Significant Deficiency Repeat
  • 609663 2022-007
    Significant Deficiency
  • 609664 2022-002
    Significant Deficiency
  • 609665 2022-003
    Significant Deficiency
  • 609666 2022-005
    Significant Deficiency
  • 609667 2022-006
    Significant Deficiency Repeat
  • 609668 2022-007
    Significant Deficiency
  • 613981 2022-002
    Significant Deficiency
  • 613982 2022-003
    Significant Deficiency
  • 613983 2022-005
    Significant Deficiency
  • 613984 2022-006
    Significant Deficiency Repeat
  • 613985 2022-007
    Significant Deficiency
  • 613986 2022-007
    Significant Deficiency
  • 613987 2022-007
    Significant Deficiency
  • 613988 2022-007
    Significant Deficiency
  • 613989 2022-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.676 Unaccompanied Alien Children Program $4.83M
19.016 Iraq Assistance Program $3.11M
98.001 Usaid Foreign Assistance for Programs Overseas $1.92M
19.518 Overseas Refugee Assistance Programs for Western Hemisphere $1.80M
14.896 Family Self-Sufficiency Program $1.60M
21.019 Coronavirus Relief Fund $726,535
19.019 International Programs to Combat Human Trafficking $598,098
93.604 Assistance for Torture Victims $532,152
19.221 Iran Assistance Program $428,156
16.575 Crime Victim Assistance $424,802
10.553 School Breakfast Program $406,704
93.567 Refugee and Entrant Assistance_voluntary Agency Programs $360,675
14.238 Shelter Plus Care $347,830
84.002 Adult Education - Basic Grants to States $328,399
14.181 Supportive Housing for Persons with Disabilities $320,000
14.241 Housing Opportunities for Persons with Aids $276,637
93.011 National Organizations of State and Local Officials $242,082
16.320 Services for Trafficking Victims $220,091
14.239 Home Investment Partnerships Program $220,000
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $194,934
21.027 Coronavirus State and Local Fiscal Recovery Funds $189,229
14.195 Section 8 Housing Assistance Payments Program $176,645
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $154,920
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $148,277
32.006 Covid-19 Telehealth Program $130,000
14.326 Project Rental Assistance Demonstration (pra Demo) Program of Section 811 Supportive Housing for Persons with Disabilities $123,708
14.231 Emergency Solutions Grant Program $105,564
93.924 Ryan White Hiv/aids Dental Reimbursement and Community Based Dental Partnership Grants $83,405
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $81,663
93.959 Block Grants for Prevention and Treatment of Substance Abuse $71,313
93.667 Social Services Block Grant $68,403
14.267 Continuum of Care Program $68,229
93.598 Services to Victims of A Severe Form of Trafficking $65,251
93.914 Hiv Emergency Relief Project Grants $52,987
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $44,570
93.566 Refugee and Entrant Assistance_state Administered Programs $43,513
93.236 Grants to States to Support Oral Health Workforce Activities $39,967
93.576 Refugee and Entrant Assistance_discretionary Grants $37,060
93.917 Hiv Care Formula Grants $36,305
14.238 Section 8 Housing Assistance Payments Program $34,804
93.940 Hiv Prevention Activities_health Department Based $34,211
93.247 Advanced Nursing Education Grant Program $30,404
19.510 U.s. Refugee Admissions Program $29,929
93.958 Block Grants for Community Mental Health Services $27,099
14.871 Section 8 Housing Choice Vouchers $24,327
14.218 Community Development Block Grants/entitlement Grants $22,316
14.235 Supportive Housing Program $16,286
16.816 John R. Justice Prosecutors and Defenders Incentive Act $15,900
64.033 Va Supportive Services for Veteran Families Program $14,484
14.881 Moving to Work Demonstration Program $8,487
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $5,700
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $4,951
14.850 Public and Indian Housing $4,599
97.024 Emergency Food and Shelter National Board Program $3,821