Finding Text
Finding 2022-003: Special Tests and Provisions
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: Deficiency in Internal Control over Compliance
Criteria: Per the U.S. Department of State, Bureau of Population, Refugees, and Migration,
all forcibly displaced and stateless populations are considered at-risk and vulnerable
requiring partners to assess the protection needs and to demonstrate accountability to these
affected populations.
Condition: We noted Team Rubicon had procedures in place to identify, vet, train and deploy
volunteers; however, for external volunteers there were no formal internal control procedures
to confirm these external volunteers were properly screened and oriented on and agreed to
adhere to the program policies.
Cause: An external volunteer had been borrowed from an adjacent federally funded entity
that served a similar mission and population.
Effect or Potential Effect: A failure to properly vet and train volunteers 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: We noted that for an external volunteer, Team Rubicon could not produce evidence
that the volunteer was properly screened and oriented, or had agreed to adhere to the
program policies.
Repeat Finding: Not applicable
Recommendation: Management is responsible for establishing controls and procedures to
ensure compliance with federal statutes, regulations and the terms and conditions of the
federal awards.
Views of Responsible Official: Management agrees and acknowledges the finding.