Finding Text
Finding No.2023-002: Maintain Supporting Documentation for Federal Report Submissions
Assistance Listing Number: 93.566
Assistance Listing Program Title: Refugee and Entrant Assistance – State - Administered Programs
Federal Agency: Department of Health and Human Services (HHS)
Passed Through Entity: California Rural Legal Assistance Foundation
Federal Award Number: Not available in the contract
Federal Award Year: October 1, 2022 – October 31, 2024
Compliance Requirement: Reporting
Criteria or Specific Requirements:
Section 6 of the Memorandum of Understanding between California Rural Legal Assistance Foundation (CRLAF) and the Council on American-Islamic Relations, San Francisco Bay Area Office (CAIR-SFBA), outlines the subrecipient's reporting requirements for demographic data.
a. The subgrantee shall regularly update a reporting database, the “ALSP Reporting Database”, shared with CRLAF and California Department of Social Services (CDSS), that quantitatively describes the services provided under this project. The subgrantee shall collect and report in this database the following information, without disclosing personally identifiable information or other confidential information:
• Number of individuals provided legal assistance
• For immigration legal services: case type
• For non-legal services: service type
• Case outcomes, as feasibly possible
• General demographic information, reported anonymously, about individuals served: age, language, nationality, and county of residence
b. The deadline to update the reporting database with information from individuals served in each month of the grant term shall be the 5th day of the following month.
Condition:
During our testing of 10 reporting samples, we identified two instances wherein CAIR-CA did not retain confirmation or proof of submission (e.g., email receipts, submission confirmations from the federal portal) for demographic data reports submitted under the contract between CRLAF and Council on American-Islamic Relations, CAIR-SFBA.
Additionally, we were informed that demographic data updates are entered directly into the Afghan Legal Services Project (ALSP) Reporting Database. As a result, no copies of submitted reports were generated or retained for review.
Cause:
CAIR-CA has not established a formal process requiring the retention of submitted reports and confirmations of submission as part of its grant reporting procedures.
Effect:
The absence of documentation may affect CAIR-CA’s ability to demonstrate compliance with the applicable federal requirements.
Questioned Cost: None
Recommendation:
We recommend that CAIR-CA implement a standardized process of retaining copies of documentation of report submissions. This process should include saving submission confirmations for all required federal reports, such as email receipts, portal confirmations, or screenshots, as evidence of timely and accurate submission.
Views of Responsible Officials and Corrective Action Plan:
Management concurs with the finding and has already begun strengthening its reporting procedures to include the retention of submission confirmations as part of its grant documentation.
Responsible person: Jackie Ramirez, Operations & Finance Associate Director
Expected Implementation date: October 31, 2025.