EIN: 135660870
UEI: VYJKCDDX9G95
Audited by: KPMG LLP
Cognizant agency: 98 [U.S. Agency for International Development]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 16, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 16, 2026 (12 days from today).
What is a management decision? →2025 001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Beneficiary Payments U.S. Department of State: Bureau of Population and Refugees and Migration: U.S. Refugee Admissions Program: FY24 MRA Capacity Development Funds (ALN 19.510, award number SPRMCO23CA0361) FY2023 25 Year 3 Reception and Placement Program Affiliate MRA DA+Admin (ALN 19.510, award number SPRMCO24CA0356) FY2023 25 Year 3 Reception and Placement Program Affiliate ERMA DA+Admin (ALN 19.510, award number SPRMCO24CA0357) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency and noncompliance Criteria: 2 CFR section 200.303 requires that non federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non federal entity is managing the federal awards in compliance with federal statues, regulations, and the terms and conditions of federal awards. The specific requirements for activities allowed or unallowed are unique to each federal program and are found in the federal statutes, regulations, and the terms and conditions of the federal award pertaining to the program. 2 CFR Part 200 establishes cost principles for determining costs applicable to federal awards with nonprofit organizations. The Uniform Guidance (2 CFR 200.403) requires that costs charged to federal awards be necessary, reasonable, allocable, adequately documented, and in compliance with the terms and conditions of the federal award. Costs that do not provide a direct programmatic benefit, or where the benefit cannot be reasonably demonstrated or allocated, and are incurred outside the approved scope of the award are not allowable as direct charges. Condition and context: On February 13, 2025, IRC’s Ethics & Compliance Unit (ECU) received a whistleblower report alleging that an IRC Housing Coordinator located in an office in Northern California submitted unauthorized and fraudulent requests for funds, which were uploaded onto USIO bank debit cards, claiming they were expenses for newly resettled IRC clients, and instead using the funds for personal benefit. These USIO cards are intended to be used to cover expenses for newly arrived refugees during the initial 90 day period, including rent, food and other miscellaneous expenses. An internal investigation was initiated in February 2025 which found that the Housing Coordinator had loaded funds onto USIO bank debit cards between May 8, 2023 and February 11, 2025 which were for purposes other than refugees. The investigation concluded that there were unauthorized and fraudulent requests for funds in the amount of $215,639, plus the related indirect costs that were applied on these direct costs of $33,920, for a total of $249,559 related to federal funds expended in 2025 and charged to the grants identified in this finding. The total expenditures in this program included on the 2025 schedule of expenditures of federal awards amount to $42,671,438. This unauthorized and fraudulent requests for funds noted of $249,559 is not included in the total expenditures in this program on the 2025 schedule of expenditures of federal awards as the amounts were recoded to unrestricted funds. IRC communicated this matter to the federal agency in February 2025 when the investigation began and again in September 2025 when the investigation was completed. The expenditures were reallocated to IRC’s unrestricted funds so that the federal grants were not charged. Cause: The internal investigation completed by ECU concluded that the unauthorized and fraudulent requests for funds resulted from the Housing Coordinator’s ability to request the transactions and approve the transactions because he obtained his direct report’s general ledger log in credentials. Additionally, there were several control gaps in the Northern California office, including the following: • There was a lack of safekeeping of blank USIO Cards – this office was not following the established control to keep the blank cards in a locked safe. • USIO cards were not tracked or recorded properly – this office was not always following the established control to have the refugees sign a log book upon receipt of a USIO card. • A lack of oversight from the heads of programs and finance in this office regarding reconciliations between budgeted and actual amounts with irregular transactions being flagged (excessive housing expenses). Effect: The auditee charged certain costs directly to the program that did not meet the requirements noted above, and were therefore, not allowable. Questioned Costs: Questioned costs were $249,559, however, IRC reallocated these costs to IRC’s unrestricted funds, so that the grants were not charged. Recommendation: IRC should design and implement enhanced internal control procedures over the authorization and disbursement of funds to IRC refugee clients through USIO cards to ensure that funding provided is allowable. Additionally, IRC should provide training to employees about sharing their personal credentials to access IRC’s general ledger. Views of Responsible Officials: Management agrees with this finding, which was identified by IRC in February 2025 and raised to KPMG prior to the single audit. Corrective actions related to USIO portal access, office leadership and structure, training and policies, and spot checking have been implemented and will continue through June 2026.
Show full finding ▾Hide full finding ▴2025 001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Beneficiary Payments U.S. Department of State: Bureau of Population and Refugees and Migration: U.S. Refugee Admissions Program: FY24 MRA Capacity Development Funds (ALN 19.510, award number SPRMCO23CA0361) FY2023 25 Year 3 Reception and Placement Program Affiliate MRA DA+Admin (ALN 19.510, award number SPRMCO24CA0356) FY2023 25 Year 3 Reception and Placement Program Affiliate ERMA DA+Admin (ALN 19.510, award number SPRMCO24CA0357) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency and noncompliance Criteria: 2 CFR section 200.303 requires that non federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non federal entity is managing the federal awards in compliance with federal statues, regulations, and the terms and conditions of federal awards. The specific requirements for activities allowed or unallowed are unique to each federal program and are found in the federal statutes, regulations, and the terms and conditions of the federal award pertaining to the program. 2 CFR Part 200 establishes cost principles for determining costs applicable to federal awards with nonprofit organizations. The Uniform Guidance (2 CFR 200.403) requires that costs charged to federal awards be necessary, reasonable, allocable, adequately documented, and in compliance with the terms and conditions of the federal award. Costs that do not provide a direct programmatic benefit, or where the benefit cannot be reasonably demonstrated or allocated, and are incurred outside the approved scope of the award are not allowable as direct charges. Condition and context: On February 13, 2025, IRC’s Ethics & Compliance Unit (ECU) received a whistleblower report alleging that an IRC Housing Coordinator located in an office in Northern California submitted unauthorized and fraudulent requests for funds, which were uploaded onto USIO bank debit cards, claiming they were expenses for newly resettled IRC clients, and instead using the funds for personal benefit. These USIO cards are intended to be used to cover expenses for newly arrived refugees during the initial 90 day period, including rent, food and other miscellaneous expenses. An internal investigation was initiated in February 2025 which found that the Housing Coordinator had loaded funds onto USIO bank debit cards between May 8, 2023 and February 11, 2025 which were for purposes other than refugees. The investigation concluded that there were unauthorized and fraudulent requests for funds in the amount of $215,639, plus the related indirect costs that were applied on these direct costs of $33,920, for a total of $249,559 related to federal funds expended in 2025 and charged to the grants identified in this finding. The total expenditures in this program included on the 2025 schedule of expenditures of federal awards amount to $42,671,438. This unauthorized and fraudulent requests for funds noted of $249,559 is not included in the total expenditures in this program on the 2025 schedule of expenditures of federal awards as the amounts were recoded to unrestricted funds. IRC communicated this matter to the federal agency in February 2025 when the investigation began and again in September 2025 when the investigation was completed. The expenditures were reallocated to IRC’s unrestricted funds so that the federal grants were not charged. Cause: The internal investigation completed by ECU concluded that the unauthorized and fraudulent requests for funds resulted from the Housing Coordinator’s ability to request the transactions and approve the transactions because he obtained his direct report’s general ledger log in credentials. Additionally, there were several control gaps in the Northern California office, including the following: • There was a lack of safekeeping of blank USIO Cards – this office was not following the established control to keep the blank cards in a locked safe. • USIO cards were not tracked or recorded properly – this office was not always following the established control to have the refugees sign a log book upon receipt of a USIO card. • A lack of oversight from the heads of programs and finance in this office regarding reconciliations between budgeted and actual amounts with irregular transactions being flagged (excessive housing expenses). Effect: The auditee charged certain costs directly to the program that did not meet the requirements noted above, and were therefore, not allowable. Questioned Costs: Questioned costs were $249,559, however, IRC reallocated these costs to IRC’s unrestricted funds, so that the grants were not charged. Recommendation: IRC should design and implement enhanced internal control procedures over the authorization and disbursement of funds to IRC refugee clients through USIO cards to ensure that funding provided is allowable. Additionally, IRC should provide training to employees about sharing their personal credentials to access IRC’s general ledger. Views of Responsible Officials: Management agrees with this finding, which was identified by IRC in February 2025 and raised to KPMG prior to the single audit. Corrective actions related to USIO portal access, office leadership and structure, training and policies, and spot checking have been implemented and will continue through June 2026.
2025-001-Activities Allowed or Unallowed and Allowable Costs/Cost Principles - Beneficiary Payments Federal Agencies: U.S. Department of State/ Bureau of Population and Refugees and Migration Program Titles and ALN Numbers: 1. ALN #19.510: U.S. Refugee Admissions Program Federal Grant Numbers: 1. SPRMCO23CA0361- FY24 MRA Capacity Development Funds 2. SPRMCO24CA0356- FY2023-25 Year 3 Reception and Placement Program - Affiliate MRA DA+Admin 3. SPRMCO24CA0357- FY2023-25 Year 3 Reception and Placement Program - Affiliate ERMA DA+Admin Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: IRC’s management has taken several steps to stop fraudulent activities, prevent new fraud and improve IRC’s ability to detect future fraud. a. Upon identifying potentially unauthorized and fraudulent fund requests, all program office access to the USIO bank portal was immediately suspended. USIO debit card loads were centralized, and this process remains in place. b. Nine staff potentially involved in those activities were placed on leave during the investigation; five were eventually terminated. Following investigations, the IRC has made significant changes in leadership in structure in Northern California. By the end of June 2026, new Finance, Operations, and Program Delivery leadership will be in place, and the office will be broken down into two smaller offices, each with its own Executive Director. c. Working visits and in-person training on fraud prevention have been and will continue to be delivered to reinforce IRC’s compliance standards in all offices engaged in direct client payments. Additionally, network wide training are being provided focused on on compliance, CFR and fraud prevention for all staff. New policies on pre-paid cards and gift cards have also been issued. d. A Financial Analyst position was created under the RAI Head of Finance to focus on compliance. The analyst performs quarterly sample-based spot checks across all U.S. network offices, randomly selecting transactions for end-to-end review, including USIO payments. An automated tool also flags potential non-compliance issues such as irregular p-card payments and gift card purchases – vulnerabilities that could be exploited in NorCal-like situations. The RAI Head of Finance then compiles quarterly compliance reports for office leadership, highlighting areas for improvement. Anticipated Completion Date: June 30, 2026
2025 002 Reporting Federal Funding Accountability and Transparency Act U.S. Department of State: Bureau of Population and Refugees and Migration: Overseas Refugee Assistance Program for Middle East and North Africa: Provision of lifesaving protection & health response for Syrian refugees and vulnerable Lebanese (ALN 19.519, award number SPRMCO24CA0321) Overseas Refugee Assistance Program for South Asia: Comprehensive, Integrated Multi Sector Response for Rohingya Refugees and Host Communities in Cox’s Bazar (Y2) (ALN 19.523, award number SPRMCO24CA0239) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Improved (Re)integration Services Activity (ALN 98.001, award number 72052224CA00004) Lifesaving Integrated Humanitarian Services in Underserved Areas of Sudan (ALN 98.001, award number 720BHA22GR00218) Statistically valid sample: No, and it was not intended to be. Repeat finding: Yes (2024 001). Finding Type: Significant deficiency and noncompliance Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109 282), as amended by Section 6202 of Public Law 110 252, (Transparency Act) that are codified in 2 CFR Parts 25 and 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first tier subawards of $30,000 or more to System for Award Management (SAM.gov). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards and contractors (i.e., prime contractors) that award first tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non federal entities must establish and maintain effective internal control over federal awards that provide 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. The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in SAM.gov no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Condition and context: For ALN 19.519, there were 3 new or amended subawardee agreements entered into during fiscal year 2025 that required FFATA reporting. We selected 2 of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for both agreements was not submitted timely. Both of the agreements were entered into on September 30, 2024 and had a submission due date of October 31, 2024. SAM.gov notes the submission date for both agreements to be August 21, 2025. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions:7 Transactions Tested: 2 Subaward not reported: 0 Report not timely: 2 Subaward amount incorrect: 0 Subaward incorrect key elements: 0 Dollar amount of tested transactions: $403,678 Subaward not reported: $0 Report not timely: $403,678 Subaward amount incorrect: $0 Subaward incorrect key elements: $0 For ALN 19.523, there were 4 new or amended subawardee agreements entered into during fiscal year 2025 that required FFATA reporting. We selected 2 of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for both agreements was not submitted timely. Both of the agreements were entered into on September 1, 2024 and had a submission due date of October 31, 2024. SAM.gov notes the submission dates to be December 4, 2025 and December 8, 2025. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested: 2 Subaward not reported: 0 Report not timely: 2 Subaward amount incorrect: 0 Subaward incorrect key elements: 0 Dollar amount of tested transactions: $759,550 Subaward not reported: $0 Report not timely: $759,550 Subaward amount incorrect: $0 Subaward incorrect key elements: $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2025 that required FFATA reporting. We selected 5 for test work and noted that while all the key data elements were accurately submitted, the information for 4 of these agreements was not submitted timely. Two of these agreements were entered into on November 1, 2024, one was entered into on November 22, 2024 and the last was entered into on December 1, 2024. The submission due dates for these agreements were December 31, 2024 and January 31, 2025. SAM.gov notes the submission dates for three of these agreements to be December 18, 2025, and for the one agreement entered into on November 22, 2024, the submission date was noted to be January 7, 2025. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested: 5 Subaward not reported: 0 Report not timely: 4 Subaward amount incorrect: 0 Subaward incorrect key elements: 0 Dollar amount of tested transactions: $302,280 Subaward not reported: $0 Report not timely: $291,135 Subaward amount incorrect: $0 Subaward incorrect key elements: $0 Cause: Following the federal system migration, the USG FFATA reporting platform within SAM.GOV no longer displayed or made readily retrievable the submission date associated with individual FFATA. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting and maintaining appropriate documentation to evidence timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized and documenting that review in writing. Additionally, we recommend that IRC take screen shots during the submission process and maintain these with the subawardee agreements. This will evidence the submission in SAM.gov, specifically evidencing the submission date. Views of Responsible Officials: While Management maintains it acted in good faith to ensure all FFATA submissions are provided timely, the new FFATA reporting platform issues made it difficult for IRC to substantiate the dates of submission. IRC did contact FSD.gov to confirm what form of evidence would be considered sufficient in the absence of visible system date stamps. FSD.gov was unable to provide specific confirmation and instead directed IRC to published guidance https://www.fsd.gov/gsafsd_sp/en/under the federal funding accountability and transparency act how acknowledging existing “implementation challenges”. This guidance shifts the focus of compliance validation from system generated timestamps to whether the recipient acted in good faith to comply with reporting obligations. Relying on this, IRC’s internal control framework did not include a secondary documentation mechanism to independently evidence submission dates in the event that system functionality limited visibility. However, IRC remains committed to full FFATA compliance and will incorporate additional steps to strengthen the compliance documentation trail.
Show full finding ▾Hide full finding ▴2025 002 Reporting Federal Funding Accountability and Transparency Act U.S. Department of State: Bureau of Population and Refugees and Migration: Overseas Refugee Assistance Program for Middle East and North Africa: Provision of lifesaving protection & health response for Syrian refugees and vulnerable Lebanese (ALN 19.519, award number SPRMCO24CA0321) Overseas Refugee Assistance Program for South Asia: Comprehensive, Integrated Multi Sector Response for Rohingya Refugees and Host Communities in Cox’s Bazar (Y2) (ALN 19.523, award number SPRMCO24CA0239) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Improved (Re)integration Services Activity (ALN 98.001, award number 72052224CA00004) Lifesaving Integrated Humanitarian Services in Underserved Areas of Sudan (ALN 98.001, award number 720BHA22GR00218) Statistically valid sample: No, and it was not intended to be. Repeat finding: Yes (2024 001). Finding Type: Significant deficiency and noncompliance Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109 282), as amended by Section 6202 of Public Law 110 252, (Transparency Act) that are codified in 2 CFR Parts 25 and 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first tier subawards of $30,000 or more to System for Award Management (SAM.gov). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards and contractors (i.e., prime contractors) that award first tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non federal entities must establish and maintain effective internal control over federal awards that provide 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. The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in SAM.gov no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Condition and context: For ALN 19.519, there were 3 new or amended subawardee agreements entered into during fiscal year 2025 that required FFATA reporting. We selected 2 of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for both agreements was not submitted timely. Both of the agreements were entered into on September 30, 2024 and had a submission due date of October 31, 2024. SAM.gov notes the submission date for both agreements to be August 21, 2025. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions:7 Transactions Tested: 2 Subaward not reported: 0 Report not timely: 2 Subaward amount incorrect: 0 Subaward incorrect key elements: 0 Dollar amount of tested transactions: $403,678 Subaward not reported: $0 Report not timely: $403,678 Subaward amount incorrect: $0 Subaward incorrect key elements: $0 For ALN 19.523, there were 4 new or amended subawardee agreements entered into during fiscal year 2025 that required FFATA reporting. We selected 2 of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for both agreements was not submitted timely. Both of the agreements were entered into on September 1, 2024 and had a submission due date of October 31, 2024. SAM.gov notes the submission dates to be December 4, 2025 and December 8, 2025. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested: 2 Subaward not reported: 0 Report not timely: 2 Subaward amount incorrect: 0 Subaward incorrect key elements: 0 Dollar amount of tested transactions: $759,550 Subaward not reported: $0 Report not timely: $759,550 Subaward amount incorrect: $0 Subaward incorrect key elements: $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2025 that required FFATA reporting. We selected 5 for test work and noted that while all the key data elements were accurately submitted, the information for 4 of these agreements was not submitted timely. Two of these agreements were entered into on November 1, 2024, one was entered into on November 22, 2024 and the last was entered into on December 1, 2024. The submission due dates for these agreements were December 31, 2024 and January 31, 2025. SAM.gov notes the submission dates for three of these agreements to be December 18, 2025, and for the one agreement entered into on November 22, 2024, the submission date was noted to be January 7, 2025. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested: 5 Subaward not reported: 0 Report not timely: 4 Subaward amount incorrect: 0 Subaward incorrect key elements: 0 Dollar amount of tested transactions: $302,280 Subaward not reported: $0 Report not timely: $291,135 Subaward amount incorrect: $0 Subaward incorrect key elements: $0 Cause: Following the federal system migration, the USG FFATA reporting platform within SAM.GOV no longer displayed or made readily retrievable the submission date associated with individual FFATA. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting and maintaining appropriate documentation to evidence timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized and documenting that review in writing. Additionally, we recommend that IRC take screen shots during the submission process and maintain these with the subawardee agreements. This will evidence the submission in SAM.gov, specifically evidencing the submission date. Views of Responsible Officials: While Management maintains it acted in good faith to ensure all FFATA submissions are provided timely, the new FFATA reporting platform issues made it difficult for IRC to substantiate the dates of submission. IRC did contact FSD.gov to confirm what form of evidence would be considered sufficient in the absence of visible system date stamps. FSD.gov was unable to provide specific confirmation and instead directed IRC to published guidance https://www.fsd.gov/gsafsd_sp/en/under the federal funding accountability and transparency act how acknowledging existing “implementation challenges”. This guidance shifts the focus of compliance validation from system generated timestamps to whether the recipient acted in good faith to comply with reporting obligations. Relying on this, IRC’s internal control framework did not include a secondary documentation mechanism to independently evidence submission dates in the event that system functionality limited visibility. However, IRC remains committed to full FFATA compliance and will incorporate additional steps to strengthen the compliance documentation trail.
2025-002 Reporting - Federal Funding Accountability and Transparency Act Federal Agencies: U.S. Department of State/Bureau of Population and Refugees and Migration, and U.S. Agency for International Development Program Titles and ALN Numbers: 1. ALN #19.519: Overseas Refugee Assistance Programs for Middle East and North Africa 2. ALN #19.523: Overseas Refugee Assistance Program for South Asia. 3. ALN #98.001: United States Foreign Assistance for Programs Overseas Federal Grant Numbers: 1. SPRMCO24CA0321 - Provision of lifesaving protection & health response for Syrian refugees and vulnerable Lebanese 2. SPRMCO24CA0239- Comprehensive, Integrated Multi-Sector Response for Rohingya Refugees and Host Communities in Cox’s Bazar (Y2) 3. 72052224CA00004 - Improved (Re)integration Services Activity. 4. 720BHA22GR00218- Lifesaving Integrated Humanitarian Services in Underserved Areas of Sudan Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: The following corrective action will be taken to ensure the documentation for timely FFATA reporting in SAM.Gov is clearly evidenced: a. All staff responsible for entering FFATA details in Sam.Gov will be required to obtain a screenshot when the report is submitted to Sam.Gov showing the date of submission. Anticipated Completion Date: September 30, 2026
2024-001
FAC accepted this audit on May 13, 2025 — management decision was due November 13, 2025.
U.S. Department of State: Bureau of Population and Refugees and Migration: Oversees Refugee Assistance Programs for Africa: Advancing access to integrated life-saving assistance and protection services to promote selfreliance and resilience for refugees and host communities in Uganda (ALN 19.517, award number SPRMCO23CA0106) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives (ALN 98.001, award number 720BHA22GR00304) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non-federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For ALN 19.517, there were 3 new or amended subawardee agreements entered into during fiscal year 2024. We selected all three of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for all three agreements was not submitted timely. All of the agreements were entered into on October 1, 2023 and the information was submitted in January 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested - 3 Subaward not reported - 0 Report not timely - 3 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $957,943 Subaward not reported - $0 Report not timely - $957,943 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2024. We selected four for test work and noted that while all the key data elements were accurately submitted, the information for two of these agreements was not submitted timely. These two agreements were entered into on January 1, 2024 and March 1, 2024 and the information was not submitted until November of 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for certain subawards on a timely basis. We noted the following exceptions: Transactions Tested - 4 Subaward not reported - 0 Report not timely - 2 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $1,349,750 Subaward not reported - $0 Report not timely - $112,617 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 Cause: Responsible staff encountered challenges accessing SAM.gov due to credential errors, which resulted in delays in submitting or updating subrecipient details in a timely manner. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized. Views of Responsible Officials: Management agrees with this finding and will take the necessary actions to ensure its FFATA reporting is more timely.
Show full finding ▾Hide full finding ▴U.S. Department of State: Bureau of Population and Refugees and Migration: Oversees Refugee Assistance Programs for Africa: Advancing access to integrated life-saving assistance and protection services to promote selfreliance and resilience for refugees and host communities in Uganda (ALN 19.517, award number SPRMCO23CA0106) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives (ALN 98.001, award number 720BHA22GR00304) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non-federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For ALN 19.517, there were 3 new or amended subawardee agreements entered into during fiscal year 2024. We selected all three of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for all three agreements was not submitted timely. All of the agreements were entered into on October 1, 2023 and the information was submitted in January 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested - 3 Subaward not reported - 0 Report not timely - 3 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $957,943 Subaward not reported - $0 Report not timely - $957,943 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2024. We selected four for test work and noted that while all the key data elements were accurately submitted, the information for two of these agreements was not submitted timely. These two agreements were entered into on January 1, 2024 and March 1, 2024 and the information was not submitted until November of 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for certain subawards on a timely basis. We noted the following exceptions: Transactions Tested - 4 Subaward not reported - 0 Report not timely - 2 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $1,349,750 Subaward not reported - $0 Report not timely - $112,617 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 Cause: Responsible staff encountered challenges accessing SAM.gov due to credential errors, which resulted in delays in submitting or updating subrecipient details in a timely manner. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized. Views of Responsible Officials: Management agrees with this finding and will take the necessary actions to ensure its FFATA reporting is more timely.
2024-001 Reporting - Federal Funding Accountability and Transparency Act 2024-001 Reporting - Federal Funding Accountability and Transparency Act Federal Agencies: U.S. Department of State/Bureau of Population and Refugees and Migration, and U.S. Agency for International Development Program Titles and ALN Numbers: 1.ALN #19.517: Overseas Refugee Assistance Programs for Africa 2.ALN #98.001: United States Foreign Assistance for Programs Overseas Federal Grant Numbers: 1. SPRMCO23CA0106 - Advancing access to integrated life-saving assistance and protection services to promote self-reliance and resilience for refugees and host communities in Uganda 2. 720BHA22GR00304 - Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: The following corrective action will be taken to ensure timely FFATA reporting of all applicable subgrant details in SAM.Gov: 1.IRC will update its onboarding process descriptions and checklists to ensure all staff responsible for FFATA reporting are provided the Sam.Gov credentials required for entering data into the system within 15 days of starting. 2.All staff responsible for entering FFATA details in Sam.Gov will be provided additional training and user guides detailing FFATA reporting requirements and processes. The updated process requirements will require obtaining screenshots when system errors/access prevents entering details within the required 30 days. 3.Quarterly detective review processes will be put in place to monitor compliance with all FFATA compliance and corrective actions will be taken with staff who are not performing to standard. Anticipated Completion Date: September 30, 2025
U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services: Refugee and Entrant Assistance State Administered Programs: Refugee and Entrant Assistance State / Replacement Designee Administered Programs: Florida Department of Children and Families: Comprehensive Refugee Services - Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) Maryland Department of Human Resources MORA Office: Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-23-507) Refugee Transitional Cash Assistance (RTCA) Maryland (ALN 93.566, award number FIA/RTCA-24-507) Extended Case Management Program (ALN 93.566, award number FIA/ECMP-24-514) New York State Office of Temporary & Disability Assistance: Refugee School Impact Program (RSIP) (ALN 93.566, award number TDA01-C00948GG-3410000) Catholic Charities, Diocese of Fort Worth: Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) Refugee Support Services (RSS) Program (ALN 93.566, award number FFY2024-27927CRSS) Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566, award number FFY2024-27927C-CMA Refugee Support Services (RSS) Program - Afghan Supplemental Appropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) Colorado Department of Human Services: REACH: Cash and Medical Assistance (ALN 93.566, award number 24 IHGA 184529) U.S. Department of Health and Human Services: Unaccompanied Children Program: Heartland Human Care Services: Unaccompanied Minors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of the Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027, award number C-73-23-083-X-00) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency Criteria: Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. After direct costs have been determined and assigned directly to awards or other work, as appropriate, indirect costs are those remaining to be allocated to benefitting cost objectives. A cost may not be allocated to a federal award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to a federal award as a direct cost. Not-for-profit organizations should charge indirect costs to federal awards in compliance with the cost principles in 2 CFR Part 200, Subpart E, Appendix IV, and CAS (if applicable), and in accordance with any negotiated rate agreements and specific award conditions/limitations. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For the three programs identified in this finding, there were a total of 233 grants (219 for 93.566, 3 or 93.676 and 11 for 21.027) in the population and 32 grants (27 for 93.566, 2 for 93.676 and 3 for 21.027) selected for test work. Out of the 32 grants selected, there were 14 grants (10 for 93.566, 1 for 93.676 and 3 for 21.027) received by IRC from a pass-through entity. For the 13 grants received from pass-through entities, the indirect costs included in the general ledger were not accurate as the amounts did not represent the direct costs multiplied by the indirect cost rate. The differences are noted below for our samples: 93.566 – general ledger was overstated by $673,702 93.676 – general ledger was understated by $2,860 21.027 – general ledger was overstated by $97,300 While these differences existed, the local office had reported the correct amount of indirect costs to the pass-through entity and had requested the correct amount for reimbursement so there are no questioned costs or noncompliance. IRC identified these errors subsequent to year-end when reconciling the information provided by the local office to the general ledger and recorded the adjustments in fiscal year 2025. Cause: In some cases, the exclusions or the indirect cost rate used to record the general ledger balance were not accurate. IRC was short-staffed, preventing regular reconciliations until year-end when the errors were identified. Since the errors were not material, the corrections were recorded in fiscal year 2025. Effect: There is the potential for IRC to report to the pass-through entity and request for reimbursement amounts that would not be allowable. Questioned Costs: None. Recommendation: IRC should timely reconcile all information provided by the local offices related to spending on grants provided by pass-through entities, including the indirect costs. If differences are noted, adjustments should be made in the correct fiscal year so that costs are appropriately presented. Views of Responsible Officials: While the identified NICRA calculation errors did not result in over/under recovery, Management agrees with the finding and acknowledges the need to strengthen governing controls.
2024-002 Allowable Indirect Costs Federal Agencies: U.S. Department of Health and Human Services, and U.S. Department of the Treasury Program Titles and ALN Numbers: 1.ALN #93.566: Refugee and Entrant Assistance State/Replacement Designee Administered Programs2.ALN #93.676: Unaccompanied Children Program3.ALN #21.027: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Grant Numbers: U.S. Department of Health and Human Services: 1. Refugee and Entrant Assistance State Administered Programs/Refugee andEntrantAssistance State / Replacement Designee Administered Programs: a. Florida Department of Children and Families: Comprehensive Refugee Services -Leon County (Tallahassee), Florida (ALN 93.566, award number LK207) b. Maryland Department of Human Resources MORA Office: i. Refugee Transitional Cash Assistance (RTCA) Maryland (ALN93.566,award number FIA/RTCA-23-507) ii. Refugee Transitional Cash Assistance (RTCA) Maryland (ALN93.566,award number FIA/RTCA-24-507) iii. Extended Case Management Program (ALN 93.566, award numberFIA/ECMP-24-514) c.New York State Office of Temporary & Disability Assistance: Refugee SchoolImpact Program (RSIP) (ALN 93.566, award numberTDA01 C00948GG-3410000) d. Catholic Charities, Diocese of Fort Worth: i. Refugee Cash Assistance (ALN 93.566, award number FFY2024-22536C-CMA) ii. Refugee Support Services (RSS) Program (ALN 93.566, award numberFFY2024-27927C-RSS) iii. Refugee Cash and Medical Assistance (CMA) Program (ALN 93.566,awardnumber FFY2024-27927C-CMA) iv. Refugee Support Services (RSS) Program - Afghan SupplementalAppropriations (ASA) (ALN 93.566, award number FFY2024-27927C-ASA-RSS) e. Colorado Department of Human Services: REACH: Cash and MedicalAssistance(ALN 93.566, award number 24 IHGA 184529) 2. Unaccompanied Children Program/Heartland Human Care Services:UnaccompaniedMinors (ALN 93.676, award number 90ZU0358-03-00) U.S. Department of Treasury: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds: 1. City of Phoenix: ARPA Funding Round 2 (ALN 21.027, award number 157893-0 FE) 2. Maricopa County (Arizona): Refugee Relocation Program - RA Services (ALN 21.027,award number C-73-23-083-X-00) Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: The following corrective action will be taken to update and strengthen internal controls to ensure indirect costs are applied correctly and any correction is completed within the applicable fiscal year: 1. A communication will be released to all IRC finance staff to share this exception and reinforce the requirement that: i) indirect cost rates, and any applicable exclusions are provided to the consolidation unit at the start of each award, ii) Indirect cost calculation are reviewed and reconciled between the invoice and the General ledger. 2. A tool will be released to be used by all field finance leads monthly, before the submission of invoices, and at the closure of each award to verify the accuracy of the indirect cost calculation. Any differences identified will be adjusted. 3. The awards financial management unit and the regional finance teams will apply the above tool on a quarterly basis for additional oversight and monitoring for any discrepancies. Anticipated Completion Date: September 30, 2025
FAC accepted this audit on April 24, 2024 — management decision was due October 24, 2024.
FAC accepted this audit on May 10, 2023 — management decision was due November 10, 2023.
FAC accepted this audit on May 1, 2022 — management decision was due November 1, 2022.
FAC accepted this audit on May 1, 2021 — management decision was due November 1, 2021.
FAC accepted this audit on June 4, 2020 — management decision was due December 4, 2020.
Period of Performance Federal Program: Foreign Assistance for Programs Overseas CFDA Number: 98.001 Federal Agency: U.S. Agency for International Development (USAID), including Office of Foreign Disaster Assistance (OFDA) Federal Grant Numbers/Award Year: 720FDA18CA00054 (9/5/18-12/31/19) 720FDA18GR00077 (6/1/18-5/31/19) Criteria: Under 2 CFR Section 200.309 states a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance. Condition and Context: IRC?s internal controls over costs charged to a Federal award include procedures to ensure costs incurred are during the period of performance. During our testwork over period of performance, we reviewed all transactions before the period of performance and after the period of performance for the above listed Federal grants. As a result of our testwork, we identified 6 costs incurred before the grant period and 5 costs incurred after the grant period. Effect: Costs were improperly charged to the grant. Cause: There are insufficient award management controls in place at the IRC field and headquarter (HQ) levels to ensure all expenses reported in interim and final financial reports are incurred within the performance period. Questioned Costs: Questioned costs were approximately $1,000. Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: This is not a repeat finding. Recommendation: We recommend that IRC enhance its policies and procedures over period of performance to ensure costs are charged to grants during the period of performance. Views of Responsible Officials: While the impact of this deficiency was minimal, management agrees that more robust controls are needed to ensure all expenses recorded to awards are incurred during the performance period. The envisioned enhancements will not only achieve stronger compliance, but also better insight and analysis of full project costs. Effective with the June 2020 close and each following month, all IRC field offices will be required to utilize an analytic tool for all awards identifying all transactions in the general ledger that were recorded outside of the period of performance and make corrections when not justified. IRC/HQ Finance will replicate this same activity on a quarterly basis as an additional control.
Show full finding ▾Hide full finding ▴Period of Performance Federal Program: Foreign Assistance for Programs Overseas CFDA Number: 98.001 Federal Agency: U.S. Agency for International Development (USAID), including Office of Foreign Disaster Assistance (OFDA) Federal Grant Numbers/Award Year: 720FDA18CA00054 (9/5/18-12/31/19) 720FDA18GR00077 (6/1/18-5/31/19) Criteria: Under 2 CFR Section 200.309 states a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance. Condition and Context: IRC?s internal controls over costs charged to a Federal award include procedures to ensure costs incurred are during the period of performance. During our testwork over period of performance, we reviewed all transactions before the period of performance and after the period of performance for the above listed Federal grants. As a result of our testwork, we identified 6 costs incurred before the grant period and 5 costs incurred after the grant period. Effect: Costs were improperly charged to the grant. Cause: There are insufficient award management controls in place at the IRC field and headquarter (HQ) levels to ensure all expenses reported in interim and final financial reports are incurred within the performance period. Questioned Costs: Questioned costs were approximately $1,000. Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: This is not a repeat finding. Recommendation: We recommend that IRC enhance its policies and procedures over period of performance to ensure costs are charged to grants during the period of performance. Views of Responsible Officials: While the impact of this deficiency was minimal, management agrees that more robust controls are needed to ensure all expenses recorded to awards are incurred during the performance period. The envisioned enhancements will not only achieve stronger compliance, but also better insight and analysis of full project costs. Effective with the June 2020 close and each following month, all IRC field offices will be required to utilize an analytic tool for all awards identifying all transactions in the general ledger that were recorded outside of the period of performance and make corrections when not justified. IRC/HQ Finance will replicate this same activity on a quarterly basis as an additional control.
2019-001 Period of Performance Federal Agency: U.S. Agency for International Development (USAID), including Office of Foreign Disaster Assistance (OFDA) Program Titles and CFDA Numbers: Foreign Assistance for Programs Overseas (CFDA #98.001) Federal Grant Numbers: 720FDA18CA00054 (9/5/18-12/31/19), 720FDA18GR00077 (6/1/18-5/31/19) Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: The following corrective action will be taken to update and strengthen internal controls to prevent costs being applied to awards outside the period of performance: 1. A communication will be released to all IRC finance and grant management staff to share this exception and reinforce the USG requirement that all cost be incurred within the period of performance unless a prior approval has been issued as per 2CFR200.458. 2. A tool will be released to be used by all field finance leads during monthly close processes which will identify expenses that were recorded outside the period of performance requiring confirmation that these costs were incurred within the period of performance. Costs that are not justified will be reclassified. 3. Regional Controllers will apply the above tool on a quarterly bases prior to the submission of quarterly, final, and final SF425s to ensure all expenses reported only included expenses incurred within the period of performance. Anticipated Completion Date: July 31, 2020
Procurement Federal Program: Overseas Refugee Assistance Programs for Strategic Global Priorities CFDA Number: 19.522 Federal Agency: U.S. Department of State: Bureau of Population, Refugees and Migration (BPRM) Federal Grant Numbers/Award Year: SPRMCO18CA0098 (9/15/18-9/15/19) Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Condition and Context: Uniform Guidance requires price or rate quotations from an adequate number of qualified sources for small purchases. We selected eleven procurements, noting for one selection, the appropriate number of price or rate quotations were not obtained. Effect: IRC is not in compliance with the Uniform Guidance procurement standards. Cause: While IRC has robust procurement systems in place, the procurement of the questioned printing services was routed through IRC's affiliate in London, United Kingdom due to proximity and time frame for completion. The administrative support staff of the affiliate office was unaware of the procurement requirements resulting in the failure to receive bids ensuring best cost for product. Questioned Costs: Questioned costs were approximately $10,000. Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: This is not a repeat finding. Recommendation: We recommend that IRC enhance its policies and procedures over procurements to ensure costs follow IRC?s procurement policy in accordance with Uniform Guidance, and the sufficient number of price or rate quotations are obtained. Views of Responsible Officials: Management agrees that while the printed materials were needed and ultimately used to achieve program results, required Federal and IRC procurement protocols were not followed. Management is conducting an after-the-fact market survey to determine if the grant overpaid for the printing services and will refund the grant for any overpayment. Having an affiliated office conduct the procurement for a federally funded good or service on behalf of IRC is truly an exceptional circumstance and, as a result, procurement compliance protocols were not understood or followed. Going forward, IRC will update its framework agreements with its affiliates by strengthening procurement protocols and controls that are consistent with donor requirements thus preventing future exceptions.
Show full finding ▾Hide full finding ▴Procurement Federal Program: Overseas Refugee Assistance Programs for Strategic Global Priorities CFDA Number: 19.522 Federal Agency: U.S. Department of State: Bureau of Population, Refugees and Migration (BPRM) Federal Grant Numbers/Award Year: SPRMCO18CA0098 (9/15/18-9/15/19) Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Condition and Context: Uniform Guidance requires price or rate quotations from an adequate number of qualified sources for small purchases. We selected eleven procurements, noting for one selection, the appropriate number of price or rate quotations were not obtained. Effect: IRC is not in compliance with the Uniform Guidance procurement standards. Cause: While IRC has robust procurement systems in place, the procurement of the questioned printing services was routed through IRC's affiliate in London, United Kingdom due to proximity and time frame for completion. The administrative support staff of the affiliate office was unaware of the procurement requirements resulting in the failure to receive bids ensuring best cost for product. Questioned Costs: Questioned costs were approximately $10,000. Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: This is not a repeat finding. Recommendation: We recommend that IRC enhance its policies and procedures over procurements to ensure costs follow IRC?s procurement policy in accordance with Uniform Guidance, and the sufficient number of price or rate quotations are obtained. Views of Responsible Officials: Management agrees that while the printed materials were needed and ultimately used to achieve program results, required Federal and IRC procurement protocols were not followed. Management is conducting an after-the-fact market survey to determine if the grant overpaid for the printing services and will refund the grant for any overpayment. Having an affiliated office conduct the procurement for a federally funded good or service on behalf of IRC is truly an exceptional circumstance and, as a result, procurement compliance protocols were not understood or followed. Going forward, IRC will update its framework agreements with its affiliates by strengthening procurement protocols and controls that are consistent with donor requirements thus preventing future exceptions.
2019-002 Procurement Federal Agency: U.S. Department of State: Bureau of Population, Refugees and Migration (BPRM) Program Titles and CFDA Numbers: Overseas Refugee Assistance Programs for Strategic Global Priorities (CFDA #19.522) Federal Grant Numbers: SPRMCO18CA0098 (9/15/18-9/15/19) Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: The following corrective action will be taken to update and strengthen internal controls to ensure compliance with USG procurement requirements including competitive bidding: 1. A communication will be released to all IRC supply chain and program staff to share that all procurement must follow IRC?s standard Supply Chain standard operating procedures (SOPs) which are fully compliant with the USG?s procurement requirements defined in 2CFR200.318-.326. 2. The Global Supply Chain Senior Director will review with IRC UK procurement and administrative staff the competitive bidding requirements detailed in IRC?s Supply Chain SOPs. 3. Any global units based in the UK therefore need to ensure any procurement of good and services is carried out through the UK procurement team and in compliance with the SOPs. 4. Any payment that needs to be submitted to New York HQ finance relating to UK suppliers will require confirmation from budget holders that the relevant procurement process has been followed. 5. IRC will conduct an after-the-fact assessment of market-based cost associated with the technical requirements for the printing to calculate the possible over charge to the USG. The documentation and analysis will be provided to BPRM for consideration when determining the possible value of the disallowed costs. Anticipated Completion Date: July 31, 2020
FAC accepted this audit on June 25, 2019 — management decision was due December 25, 2019.
FAC accepted this audit on June 17, 2018 — management decision was due December 17, 2018.
FAC accepted this audit on June 28, 2017 — management decision was due December 28, 2017.
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