Finding 485616 (2023-001)

Finding 2023-001: Eligibility Documentation Information on the Federal Program: 93.566 Afghan Arrival Job Readiness Criteria or Specific Requirement: As specified in 2 CFR section 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Upwardly Global's internal compliance controls require that each potential participant is screened to ensure that they are eligible to participate in the program prior to admission into the program. During our review of the selected participants, we noted that the documentation to support eligibility for each participant was not retained or available for review. Cause: Upwardly Global's internal compliance controls do not require that eligibility documentation for each participant be retained and available for review. Effect or Potential Effect: It is possible that Upwardly Global provided services to ineligible individuals through the program, as appropriate eligibility documentation cannot verified. Questioned Costs: None. Context: A sample of twenty participants were selected for testing. We consider our sample selection to be representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that Upwardly Global amend their internal compliance controls to require that all supporting eligibility documentation be retained in each participant's file.