Finding Text
Condition: In our testing of the Unaccompanied Children Program, we noted several compliance matters as noted in findings
2024-001 and 2024-002 that stem in part from either a failure of or a lack of controls to prevent, or detect and
correct, matters for Federal awards. Many of the errors seem to stem from the entity’s use of manual
spreadsheets to complete many allocations, communication issues between program managers and financial
personnel, and errors that were not noted and corrected in a timely manner. As a result of a lack of strong controls,
the budget was exceeded, disbursements were made in excess of per child allowable amounts, unallowed items
were reimbursed, and amendments were not requested promptly for budget overages. Criteria: Strong controls over Federal programs are necessary to ensure that fund are used appropriately, managed
appropriately internally and accurate reporting is maintained that can be made available to all interested parties
within the entity and to the grantor as required. Grantee entities are to be responsible stewards of funds and
should have strong monitoring and controls in place to ensure that is met.
Cause: Errors in understanding allowable amounts per child, errors in understanding allowable items, lack of controls and
processes to monitor gift cards, over-reliance on many manual processes and spreadsheets, and lack of
communication appears to be creating some disconnect and issues that is allowing this breakdown in monitoring
and reporting to occur.
Effect: As a result of the control concerns, we do believe that a larger error or several smaller issues that total a larger
error could occur and not be timely noted and/or corrected by the entity.
Recommendation: We recommend enCircle work on controls that put in place monitoring over program usage of funds by
independent individuals to verify per child amounts, gift cards, and other similar items are being appropriately
monitored. We also recommend that enCircle investigate whether their current accounting system can help with
the allocation of personnel and invoices across programs so there is less reliance on manual processes and journal
entries. Additionally, we recommend that stronger monitoring and review processes be put in place for all
programs to ensure budgetary and reporting compliance.
Views of Responsible Officials and Planned Corrective Action: enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding.
Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct
coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly,
so that these allocations are updated automatically by HR when position roles change.