Finding 576245 (2024-004)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-09-12
Audit: 366160
Organization: Opening Doors, Inc. (CA)

AI Summary

  • Core Issue: A significant deficiency was found in internal controls over compliance, specifically regarding the lack of documented approval for a programmatic report.
  • Impacted Requirements: The failure to retain approval documentation violates reporting requirements set by OMB, potentially leading to inaccuracies in federal reports.
  • Recommended Follow-Up: Strengthen policies to ensure all programmatic reports are reviewed and approved with proper documentation before submission to the grantor.

Finding Text

Federal Agency: U.S. Department of Health & Human Services Federal Program Name: Refugee and Entrant Assistance Voluntary Agency Programs Assistance Listing Number: 93.576 Federal Award Identification Number and Year: 2024 Pass-Through Agency: Church World Services, Inc. Pass-Through Number: CWS-2024-04-015 2024 Award Period: 10/1/2023-9/30/2024 Compliance Requirement Affected: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. Condition: For one programmatic report did not have a program manager's review and approval that could be verified. Context: A nonstatistical sample of 5 out 11 Programmatic reports were selected for testing for the Refugee and Entrant Assistance Voluntary Agency Programs program. The condition noted above was identified during our procedures over ODI's Reporting Federal compliance requirements. Effect: ODI did not retain documentation of the programmatic report approval, which could result in inaccuracies in reports remitted to the Federal grantor. Cause: ODI has a control designed to review and approve Federal Programmatic reports changes. However, documentation of approval could not be provided. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that ODI strengthen its current policies and procedures to ensure that documentation is retained for review and approval of all Programmatic Reports, prior to submission to the grantor. Management’s Views: Management takes responsibility for the finding and believes that in future years, they will be able to implement proper controls to mitigate this finding.

Corrective Action Plan

Auditor's Recommendation: Strengthen policies and procedures to ensure proper documentation retention for review and approval of all Programmatic Reports prior to grantor submission. Management Response: While ODI does not disagree with the audit finding, the Agency does clarify the context of the finding. ODI has a process for monitoring activities under Federal awards: Program Managers and Directors are responsible for monitoring activities under Federal awards, with the support of the Agency’s Compliance Specialist. The Agency tracks comparisons of program accomplishments to program objectives and reports these data to grantors as required and, where necessary, communicates significant development to the Federal agency and/or pass-through entity. Corrective Action: Establish comprehensive guidelines to retain documentation of quality control and review for programmatic reports through electronic approvals via email and/or approved tracked changes or review notes within software platforms demonstrating review and approval. Responsible Personnel: Jessie Mabry, CEO; Jeremy Huynh, Compliance Specialist Implementation Date: Immediate implementation to assess tracking methods for Federal programmatic reports, and to develop written guidelines for documenting programmatic report quality control.

Categories

Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 576233 2024-002
    Material Weakness
  • 576234 2024-003
    Material Weakness
  • 576235 2024-002
    Material Weakness
  • 576236 2024-003
    Material Weakness
  • 576237 2024-002
    Material Weakness
  • 576238 2024-003
    Material Weakness
  • 576239 2024-002
    Material Weakness
  • 576240 2024-003
    Material Weakness
  • 576241 2024-002
    Material Weakness
  • 576242 2024-003
    Material Weakness
  • 576243 2024-002
    Material Weakness
  • 576244 2024-003
    Material Weakness
  • 1152675 2024-002
    Material Weakness
  • 1152676 2024-003
    Material Weakness
  • 1152677 2024-002
    Material Weakness
  • 1152678 2024-003
    Material Weakness
  • 1152679 2024-002
    Material Weakness
  • 1152680 2024-003
    Material Weakness
  • 1152681 2024-002
    Material Weakness
  • 1152682 2024-003
    Material Weakness
  • 1152683 2024-002
    Material Weakness
  • 1152684 2024-003
    Material Weakness
  • 1152685 2024-002
    Material Weakness
  • 1152686 2024-003
    Material Weakness
  • 1152687 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.510 U.s. Refugee Admissions Program $4.96M
93.576 Refugee and Entrant Assistance Discretionary Grants $1.98M
14.267 Continuum of Care Program $613,649
93.569 Community Services Block Grant $74,961
59.046 Microloan Program $64,444
21.020 Community Development Financial Institutions Program $16,108