Finding Text
Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Furthermore, the Cooperative Agreements entered into by the Organization and its funding agencies contain documentation requirements related to refugee case files which must be maintained.
Condition: Refugee case files, specifically related to the Afghan Placement and Assistance Program, lacked certain documentation required by the Cooperative Agreements.
Cause: Due to the high volume of Afghan Placement and Assistance Program arrivals in a short time span, the Organization was directed by its funding agencies to focus first on the provision of services to the clients, knowing that documentation of such services may be lacking. Furthermore, due to the demands of the program, the Organization also experienced considerable turnover in program staff which led to a lack of completion and maintenance of the documentation required by the Cooperative Agreements.
Effect: Refugee case files were incomplete and lacked the documentation required by the Cooperative Agreements.
Questioned Costs: None reported.
Context: A nonstatistical sample of 30 arrivals were tested, of which required documentation was missing within 8 of the files tested.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that management continue to monitor and enhance its procedures and internal controls over federal award compliance to incorporate a detailed, timely review of refugee case files to ensure documentation is complete and consistent with the requirements of the Cooperative Agreements.
Views of Responsible Officials: Management agrees with the finding. However, management notes that the
Cooperative Agreement specific to the Afghan Placement and Assistance Program directed the Organization to focus on the provision of services and to include documentation of such activities to the extent possible. Furthermore, the Organization’s funding agencies have performed numerous monitoring reviews of the case files, including reviews specific to the Afghan Placement and Assistance Program. While the results of these reviews did note similar findings, subsequent to year-end, the Organization received written documentation that all such findings have been satisfactorily resolved and that the Organization is in compliance with the terms and conditions of the Cooperative Agreement.