Finding Text
Finding 2022-001: Identification of Federal Award Compliance Requirements
Assistance Listing Number: 19.510
Federal Program: U.S. Refugee Admissions Program
Federal Agency: U.S. Department of State
Pass-Through Entity: Church World Service
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria: Per Title 2 of the Code of Federal Regulations (2 CFR) section 200.501, non-federal
entities that expend $750,000 or more during the non-federal entity’s fiscal year in federal
awards must have a Single Audit conducted in accordance with 2 CFR section 200.514.
Condition: We noted Team Rubicon received a federal subaward in excess of $750,000
requiring a Single Audit.
Cause: The error was primarily due to a misunderstanding of the $750,000 limit above
which a Single Audit would be required.
Effect or Potential Effect: A failure to identify federal compliance requirements could result in
Team Rubicon not being in compliance with federal statutes, regulations and the terms and
conditions of federal awards.
Questioned Costs: None identified
Context: During the year ended December 31, 2022, Team Rubicon received a grant in
excess of $750,000 from a recipient of a federal award, making Team Rubicon a subrecipient
of the award and subject to certain federal compliance requirements including a Single
Audit.
Repeat Finding: Not applicable
Recommendation: Management is responsible for establishing controls and procedures to
ensure contracts and grants are reviewed for key terms and conditions that may indicate
federal funding to ensure the proper identification and compliance with federal statutes,
regulations and the terms and conditions of the federal awards including the requirement for
a Single Audit.
Views of Responsible Official: Management agrees and acknowledges the finding.