The Center for Victims of TortureNon-Profit

Finding 2025-001: Non-Compliance with Federal Fund Accountability and Transparency Act Information on the Federal Programs: 98.001 (Helping Survivors Heal) Criteria or Specific Requirement: In accordance with 2 CFR Chapter 1, Part 170, prime awardees of 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-award equal to or greater than $30,000 in Federal funds that does not include recovery funds. Condition: We identified two of two instances tested in which CVT did not submit a sub-recipient's FFATA report in a timely manner. Cause: CVT was made aware of the FFATA reporting requirement in February 2025, at which time FFATA reports were submitted for all sub-recipients in place. Effect or Potential Effect: CVT was not in compliance with FFATA reporting requirements. Questioned Costs: None noted as this compliance requirement is a administrative reporting requirement that does not impact cost eligibility. Context: We performed statistical sampling procedures over CVT's sub-recipients required to be reported under FFATA. We consider this sample representative of the population. Identification as a Repeat Finding, if Applicable: Refer to finding 2024-001. Recommendation: We recommend that CVT clearly communicate FFATA reporting requirements to responsible staff, and conduct regular trainings to ensure that there is an understanding of requirements to be in compliance with FFATA.

Finding 2024-001: Non-Compliance with Federal Fund Accountability and Transparency Act Information on the Federal Programs: 98.001, 93.576 Criteria or Specific Requirement: In accordance with 2 CFR Chapter 1, Part 170, prime awardees of 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-award equal to or greater than $30,000 in Federal funds that does not include recovery funds. Condition: We identified three instances in which CVT did not submit a sub-recipient's FFATA report. Cause: CVT does not have the appropriate staffing in place to ensure compliance with this specific requirement. Effect or Potential Effect: CVT was not in compliance with FFATA reporting requirements. Questioned Costs: None noted as this compliance requirement is a administrative reporting requirement that does not impact cost eligibility. Context: We performed statistical sampling procedures over CVT's sub-recipients required to be reported under FFATA. We consider this sample representative of the population. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that CVT clearly communicate FFATA reporting requirements to responsible staff, and conduct regular trainings to ensure that there is an understanding of requirements to be in compliance with FFATA.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

2022-001 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for AfricaAgency for International DevelopmentDepartment of State - Federal Financial Assistance Listing # 98.001, USAID Foreign Assistance for Programs OverseasProcurement, Suspension and DebarmentType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 and #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities, other than states, must follow when operating federal programs and the required procurement procedures based on the amount of the transaction.Condition: CVT has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, CVT was not testing vendors for suspension and debarment.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred.Questioned Costs: None reported.Context/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 60 transactions out of 2,935 total transactions was selected for testing. Required documentation related to procurement was not maintained for 13 of the items selected, and 13 of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 60 transactions out of 1,594 total transactions were selected for testing. Required documentation related to procurement was not maintained for six of the items selected, and seven of the items selected did not have support for suspension, and debarment.Repeat Finding from Prior Year: Yes, prior year finding 2021-001.Recommendation: We recommend that management maintain adequate supporting documentation and records to document history, methods of procurement, and documentation to support check for suspension and debarment to comply with these CFR sections.Views of Responsible Officials: Management agrees with this finding.

2022-002 Department of State ? Bureau of Population, Refugees, and Migration Federal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentAllowable Activities, Allowable CostsType of Finding: Material Weakness in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule.Criteria: CVT?s internal control structure should be designed to properly follow the allocation of international employees pay to each location served in accordance with the policy established by CVT. This includes documentation of approval of employee timecards.Condition: CVT has an internal control system designed to detect or prevent improper allocation of international employees to locations served in a timely manner in accordance with their established policy, however, the controls did not operate as designed for four months tested.Cause: The controls in place did not operate as designed.Effect: Risk of unallowable costs being submitted for reimbursement.Questioned Costs: None reportedContext/Sampling: A nonstatistical sample of four months out of 12 total months of payroll was selected for testing which accounted for $565,110 of $4,050,524 federal program expenditures. Seventeen instances were identified where the timecards were not signed by the supervisor and 44 instances where the allocation of payroll did not match the timecards for the calculation of the allocation of wages to the program. There were also six identified instances where the payroll allocation support did not match the amounts recorded in the general ledger.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over international employee timesheet allocation to make sure payroll is properly allocated to each location serviced in accordance with the policy established by CVT.Views of Responsible Officials: Management agrees with this finding.

2022-003 Department of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasAllowable Activities, Allowable CostsType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: CVT?s internal control structure should be designed to properly follow the allocation of international employees pay to each location served in accordance with the policy established by CVT. This includes documentation of approval of employee timecards.Condition: CVT has an internal control system designed to detect or prevent improper allocation of international employees to locations served in a timely manner in accordance with their established policy, but the controls did not operate as designed for two months tested.Cause: The controls in place did not operate as designed.Effect: Risk of unallowable costs being submitted for reimbursement.Questioned Costs: None reportedContext/Sampling: A nonstatistical sample of four months out of 12 total months of payroll was selected for testing which accounted for $393,481 of $1,924,291 federal program expenditures. Six instances were identified where the timecards were not signed by the supervisor and eight instances where the allocation of payroll did not match the timecards for the calculation of the allocation of wages to the program.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over international employee timesheet allocation to make sure payroll is properly allocated to each location serviced in accordance with the policy established by CVT.Views of Responsible Officials: Management agrees with this finding.

2022-004 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for AfricaAgency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasAllowable Activities, Allowable CostsType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 and #98.001 on the Schedule.Criteria: Internal control procedures should ensure the correct wage rate is paid to employees.Condition: CVT has an internal control process designed to approve the payrates, but the controls did not operate as designed for one month tested under both programs.Cause: The controls in place did not operate as designed and failed to detect that employees were paid with a rate that did not agree to the approved contract.Effect: Multiple international employees had a lower wage rate than the approved wage rate form provided for one month tested.Questioned Costs: None reported.Context/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 4 months out of 12 total months of payroll was selected for testing which accounted for $565,110 of $4,050,524 federal program expenditures. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 months out of 12 total months of payroll was selected for testing which accounted for $393,481 of $1,924,291 federal program expendituresRepeat Finding from Prior Years: NoRecommendation: We recommend management revise their internal controls to make sure the employees contracted rates agree to the rate paid and submitted for reimbursement.Views of Responsible Officials: Management is in agreement with this finding.

2022-005 Department of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs Overseas, Award Number 720BHA22GR00046Allowable Activities, Allowable Costs, and Procurement, Suspension and DebarmentType of Finding: Significant Deficiency in Internal Control over ComplianceCriteria: CVT?s internal control structure should be designed to properly calculate, review, and approve expenses in accordance with the policy established by CVT.Condition: CVT has an internal control system designed to review and approve expenses, but the controls did not operate as designed as ineligible expenses were identified in one of the items selected for testing.Cause: The controls in place did not operate as designed and failed to detect that an expense was submitted for reimbursement twice.Effect: One item tested had an ineligible amount reported to the grantor.Questioned Costs: None reported.Context/Sampling: A nonstatistical sample of 60 transactions out of 1,594 total transactions was selected for testing which accounted for $496 of $1,924,290 of federal program expenditures.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over expenses to ensure amounts claimed for reimbursement are accurate and allowable.Views of Responsible Officials: Management agrees with this finding.

2022-006 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasCash ManagementType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule, and award number 720BHA22GR00046 under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR section 200.305 sets forth the advance payments? standards non-federal entities, other than states, must follow when operating federal programs and the requirement that cash advances be placed in an interest-bearing account. CVT?s internal control structure should be designed to properly place funds received as cash advances are placed in an interest-bearing account.Condition: CVT does not have internal control system designed to ensure advance payments are placed in an interest-bearing account.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: Risk of interest income that should be earned and reported.Questioned Costs: None reportedContext/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 6 requests out of 31 total requests were selected for testing. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 requests out of 17 total requests were selected for testing.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Views of Responsible Officials: Management agrees with this finding.

2021-001 Department of State ? Bureau of Democracy, Human Rights, and Labor CFDA # 19.345, Award Number S-LMAQM-16-CA-1185, Award Number S-LMAQM-20-CA-2297, Award Number S-LMAQM-20-CA-2258, Award Number NED 2020-1509, International Programs to Support Democracy, Human Rights and Labor Procurement, Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities, other than states, must follow when operating federal programs and the required procurement procedures based on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment, no control documentation was available to support that a search for suspension and debarment was performed on one item selected for testing. Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections. Effect: A risk that CVT could be contracting and awarding contracts to suspended or debarred vendors. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 transactions out of 5,450 total transactions was selected for testing. Repeat Finding from Prior Year: Yes, prior year finding 2020-001. Recommendation: We recommend that management maintain adequate supporting documentation and records to document history, methods of procurement, and documentation to support check for suspension and debarment to comply with these CFR sections. Views of Responsible Officials: Management agrees with this finding.

2021-002 Department of State ? Bureau of Democracy, Human Rights, and Labor CFDA # 19.345, Award Number S-LMAQM-19-CA-2170, International Programs to Support Democracy, Human Rights and Labor Allowable Activities and Allowable Costs Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: CVT?s internal control structure should be designed to properly calculate, review, and approve expenses in accordance with the policy established by CVT. Condition: CVT has an internal control system designed to review and approve expenses, but the controls did not operate as designed as ineligible expenses were identified in one of the items selected for testing. Cause: The controls in place did not operate as designed and failed to detect a change in contract in a timely manner which led to recording an expense that was not allowed based on the contract. Effect: One item tested had an ineligible amount reported to the grantor. Questioned Costs: $240 Context/Sampling: A nonstatistical sample of 60 transactions out of 5,450 total transactions was selected for testing which accounted for $240 of $7,199 of federal program expenditures. Repeat Finding from Prior Year: No Recommendation: We recommend management complete an extensive review over expenses to ensure amounts claimed for reimbursement are accurate and allowable. Views of Responsible Officials: Management agrees with this finding.

2021-003 Department of Health and Human Services ? Administration for Children and Families, Office of Refugee Resettlement (ORR), CFDA # 93.604, Award Number 90ZT0187-02-01, Assistance for Torture Victims Allowable Activities, Allowable Costs, and Procurement, Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: CVT?s internal control structure should be designed to properly review and approve invoices in accordance with the policy established by CVT. Condition: CVT has an internal control system designed to review and approve invoices, but one invoice tested did not have evidence of approval. Cause: The controls in place did not operate as designed. Effect: Risk of unallowable costs being submitted for reimbursement. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 60 transactions out of 2,847 total transactions was selected for testing which accounted for $25 of $4,140 federal program expenditures. Repeat Finding from Prior Year: No Recommendation: We recommend management complete an extensive review over expenses to ensure amounts claimed for reimbursement are approved and formally documented. Views of Responsible Officials: Management agrees with this finding.

2021-004 Department of State ? Bureau of Democracy, Human Rights, and Labor CFDA # 19.345, Award Number S-LMAQM-16-CA-1185, Award Number S-LMAQM-20-CA-2297, Award Number S-LMAQM-20-CA-2258, Award Number NED 2020-1509, International Programs to Support Democracy, Human Rights and Labor Allowable Activities, Allowable Costs Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: CVT?s internal control structure should be designed to properly follow the allocation of international employees pay to each location served in accordance with the policy established by CVT. Condition: CVT has an internal control system designed to detect or prevent improper allocation of international employees to locations served in a timely manner in accordance with their established policy, but the controls did not operate as designed. Cause: The controls in place did not operate as designed. Effect: Risk of unallowable costs being submitted for reimbursement. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 4 months out of 12 total months of payroll was selected for testing which accounted for $44 of $33,729 federal program expenditures. Repeat Finding from Prior Year: No Recommendation: We recommend management complete an extensive review over international employee timesheet allocation to make sure payroll is properly allocated to each location serviced in accordance with the policy established by CVT. Views of Responsible Officials: Management agrees with this finding.

2020-001 Department of State ? Bureau of Population, Refugees, and Migration CFDA # 19.517, Overseas Refugee Assistance Programs for Africa and CFDA # 19.519, Overseas Refugee Assistance Programs for Near East and South Asia Procurement, Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment, it was identified that there was no observable control documentation to directly indicate that a search for suspension and debarment was performed on vendors. Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect: A lack of established controls increases the overall risk that CVT is contracting and awarding contracts to suspended or debarred vendors. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 80 transactions out of 6,663 total transactions was selected for testing. Required documentation related to the search for suspension and debarment was not maintained for 10 of the items selected. Repeat Finding from Prior Year: No Recommendation: We recommend that management maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials: Management agrees with this finding.

2020-002 Department of State ? Bureau of Population, Refugees, and Migration CFDA # 19.517, Overseas Refugee Assistance Programs for Africa Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: CVT?s internal control structure should be designed to properly calculate and report each line item in their advance requests in accordance with the policy established by CVT. Condition: CVT has an internal control system designed to detect or prevent improper reporting of total cash advances to date in accordance with their established policy, but the controls did not operate as designed. Cause: The controls in place did not operate as designed and failed to detect an error in the amount reported for total cash advances to date. Effect: One report tested had an incorrect amount reported to the grantor. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of five reports out of 40 total transactions were selected for testing. The lines for testing were determined using auditor judgement and consideration of program materiality. Repeat Finding from Prior Year: No Recommendation: More extensive review over report submissions to ensure amounts reported are accurate and agree to financial records. Views of Responsible Officials: Management agrees with this finding.

2019-002 Department of State ? Bureau of Population, Refugees, and Migration CFDA # 19.517, SPRMCO-17-CA-2163, SPRMCO-17-CA-2127, SPRMCO-17-CA-2011 Overseas Refugee Assistance Programs for Africa Direct Allowable Costs Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: CVT?s internal control structure should be designed to properly follow the allocation of expatriate employees pay to each location served in accordance with the policy established by CVT. Condition: CVT has an internal control system designed to detect or prevent improper allocation of expatriate employees to locations served in a timely manner in accordance with their established policy, but the controls did not operate as designed. Cause: The process for entering expatriate employee timecards was a manual process until August 2019, leading to potential human error or manipulation going undetected up until the date. The controls in place did not operate as designed and failed to detect an error in the allocation of expatriate employee pay to the locations served in the month of May 2019. Effect: Expatriate employees had some of their pay allocated improperly and not in accordance with the policy established. Questioned Costs: None Reported Repeat Finding from Prior Year: No Recommendation: More extensive review over expatriate timesheet allocation to ensure expatriate payroll is properly allocated to each location serviced in accordance with the policy established by CVT. Views of Responsible Officials: Management agrees with this finding.

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