ASYLUM ACCESSNon-Profit

Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.

Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Information on the Federal Programs: Assistance Listing Number 19.518 Criteria: The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their firsttier subawards to meet the FFATA reporting requirements. Prime Awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Criteria (continued): CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant governmentwide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: Asylum Access has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: Asylum Access does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Context: Absent proper policies and procedures, Asylum Access is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Effect: Asylum Access did not comply with the requirements noted above. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where Asylum Access is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.