Finding Text
Finding 2023-001 –Expenditures for Allowable Costs (19.510: U.S. Refugee Admissions Program & 93.567 Refugee Entrant Assistance Voluntary Agency Program)
Material Weakness
Condition: During our testing we found 9 of 45 expenditures of the Refugee Admissions Program (19.510) and 12 of 45 expenditures of the Refugee Entrant Assistance Voluntary Agency Program (93.567) were found to have insufficient documentation to determine if cost were allowable or unallowable to each federal program.
Criteria: For federal expenditures relating to this program, certain costs are allowed/unallowed, which are explained in the Compliance Supplement and the Cooperative Agreement with United States Conference of Catholic Bishops (USCCB).
Cause: Of the 90 expenditures tested, 21 of them did not have sufficient supporting documentation to determine if the expenditure appropriately meets the allowable cost requirements of the federal programs.
Effect: Insufficient documentation of what the funds are being used for could have an impact on future funding.
Recommendation: We recommend that management implement internal controls that require program directors to collect receipts and contracts from refugees or have program directors supervise or make purchases for refugees that will allow collecting of receipts for documentation easier.
View of Responsible Officials: The corrective actions being implemented include the following:
- Food Purchases
o The practice of purchasing food will be to have the Caseworker for each case take the family shopping to Giant Foods, where there is a Catholic Charities account. The Caseworker should shop with the family and then after the purchase is completed the clients signs the required RF-35 documentation and the receipt is then given to the Program Director to pay within the accounting software. A copy of the signed RF-35 and receipt will be made available for the client case file and for the Fiscal department for billing purposes. o If the option of shopping at Giant Foods is not available due to dietary restrictions or culture requirements, gift cards to these specific grocery stores will be made using a Catholic Charities credit card. The gift card will be given to the family for them to sign the appropriate RF-35. The Caseworker will then take the family shopping to ensure clients spend funds on federally approved food items. A copy of the receipt for the gift card purchases and the signed RF-35 as well will be made available for the client case file and for the Fiscal department for billing purposes.
- Rent Payments
o The practice will be to have a lease from the Landlord to issue a check for security deposit and rent. On the day of move in, the lease will be signed by the client, the RF-35 will be signed, and then the check will be released to the Landlord. Once the lease is signed, a copy of the lease and the signed RF-35 will be made available for the client case file and for the Fiscal department for billing purposes.
o The practice when a client is going to be living with their US-tie is that a letter of agreement between the case’s primary applicant and the US-tie will be established explaining the amount the client is responsible for paying for rent and utilities. That agreement will then be signed by the client, the US-tie, and will be witnessed by a third party (Caseworker, Program Director, Operations Director). That agreement will then be utilized as the documentation for requesting rent payments on behalf of the client along with the signed RF-35. A copy of this agreement and signed RF-35s will be made available for the client case file and for the Fiscal department for billing purposes.
o The practice when two unrelated clients are going to be living together is as follows: all appropriate required documentation establishing the responsibilities between the two clients will be established. The lease and all agreements will then be signed and will be witnessed by a third party (Caseworker, Program Director, Operations Director). The lease and signed agreement will then be utilized as the documentation for requesting rent payments on behalf of the clients along with the signed RF-35s for each case. A copy of the lease, this agreement, the signed RF-35s will be made available for each of the clients’ case files and for the Fiscal department for billing purposes. o Rent payments made after the initial payment will be made in the amount of the client’s rent according to the lease and will be accompanied by a signed RF-35. A copy of each signed RF-35 will be made available for the client case file and for the Fiscal department for billing purposes. - Utilities
o Educate the clients to turn utility bills into the Caseworker and have the client sign a RF-35 in the amount of the utility bill. The Caseworker then gives the utility bill to the Program Director to enter the invoice into the accounting software for payment. A copy of the utility bill and the signed RF-35 will be made available for the client case file and for the Fiscal department for billing purposes.
o If the Landlord pays the utilities and seeks reimbursement, the landlord will provide a copy of an invoice for the client to turn into the Caseworker and have the client sign a RF-35 for the amount of the utility bill. The Caseworker then gives the invoice to the Program Director to enter the invoice into the accounting software for payment. A copy of the invoice and the signed RF-35 will be made available for the client case file and for the Fiscal department for billing purposes.