SAMARITAS

Significant deficiency in internal controls over compliance and instances of noncompliance related to period of performance. Federal Agency: United States Department of Health and Human Services Program Title: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Pass-Through Entities: Michigan Department of Labor and Economic Opportunity Assistance Listing Number: 93.566 Award Identification: All awards Criteria Per the standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance), Subpart D ‐ Post Federal Award Requirements, Section 200.309, only allowable costs incurred during the period of performance may be charged to the federal awards and the start date of a renewal award begins a new and distinct period of performance. Condition/Context During our audit, out of a sample of 25 transactions tested for period of performance, we identified three selections where the cost was incurred before the respective renewal award’s period of performance start date. All three charges that were outside of the period of performance related to charges for goods and services that were entered into the incorrect period due to timing of receipt of the invoice and close out of the prior award. Cause The Organization’s controls did not operate effectively to prevent or detect expenditures that were incurred outside of the federal award’s period of performance. Effect or Potential Effect The Organization charged to federal awards costs incurred outside the period of performance. Questioned Costs Award UHPAS26-5002: $117 Award RSI26-0033: 15 Award RSS26-00002: 24 Total Questioned Costs: $156 Recommendation We recommend the Organization strengthen its internal control processes and procedures to ensure there are adequate controls in place to identify and record charges in the correct period to prevent charges to federal awards that did not occur within the award’s period of performance. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan. Repeat Finding Repeat of finding 2024-001.

Finding 2024-001 Significant deficiency in internal controls over compliance and instances of noncompliance related to period of performance. Federal Agency: United States Department of Health and Human Services Program Title: Unaccompanied Children Program Pass-Through Entities: Global Refugee (fka Lutheran Immigration and Refugee Services) Assistance Listing Number: 93.676 Award Identification: All awards Criteria Per the standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance), Subpart D ‐ Post Federal Award Requirements, Section 200.309, only allowable costs incurred during the period of performance may be charged to the federal awards. Condition/Context During our audit, out of a sample of 25 transactions tested for period of performance, we identified three selections where the cost was incurred either before or after the respective award’s the period of performance. All three charges that were outside of the period of performance related to charges for goods and services that were entered into the incorrect period due to timing of receipt of the invoice and/or data entry error. Cause The Organization’s controls did not operate effectively to prevent or detect expenditures that were incurred outside of the federal award’s period of performance. Effect or Potential Effect The Organization charged to federal awards costs incurred outside the period of performance. Questioned Costs Award 90ZU0555-02-01: $1,829 Award 90ZU0521-02: 150 Total Questioned Costs: $1,979 Recommendation We recommend the Organization strengthen its internal control processes and procedures to ensure there are adequate controls in place to identify and record charges in the correct period to prevent charges to federal awards that did not occur within the award’s period of performance. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan. Repeat Finding Not a repeat finding.

Finding 2024-002 Significant deficiency in internal controls over compliance and instance of noncompliance related to eligibility. Federal Agency: United States Department of State Program Titles: Refugee Admissions Program Pass-Through Entity: Global Refugee (fka Lutheran Immigration and Refugee Services) Assistance Listing Number: 19.510 Award Identification: All awards Criteria Compliance requirements contained in Title 2 U.S. Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.303, require that a nonfederal entity establish and maintain effective internal control over the Federal award that provides 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 Federal award referenced requires that eligible participants be Afghan arrivals as defined in the award. Condition/Context During the year ended December 31, 2024, out of a sample of 25 eligible participants, two selections who were provided direct payments under the award were not Afghan arrivals as defined in the award and were therefore not eligible. Cause The Organization’s internal controls over eligibility did not operate effectively to ensure that only eligible participants benefited from the award. Effect or Potential Effect Ineligible participants benefited from the award. Questioned Costs Payments on behalf of ineligible beneficiaries identified under award SPRMCO23CA0364 totaled $3,263. Recommendation We recommend the Organization implement internal controls to ensure that only eligible participants benefit from federal awards. Views of Responsible Individuals Management agrees with the finding and has provided the accompanying corrective action plan. Repeat Finding Not a repeat finding.

Finding 2023-001 Significant deficiency in internal controls over compliance and instance of noncompliance related to cash management. Federal Agency: United States Department of Health and Human Services Program Titles: Unaccompanied Children Program Assistance Listing Number: 93.676 Pass-Through Entity: Direct award Award Numbers: 90ZU0555-01-01 Award Periods: April 1, 2023 through March 31, 2024 Criteria Compliance requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.305 Federal Payment, require that a non‐Federal entity must use a payment method that minimizes the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. When a non-federal entity must be paid in advance, the non-Federal entity must limit cash advance to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. Condition/Context During the year ended December 31, 2023, out of a sample of five cash draws, one selection represented a cash draw in excess of the immediate cash needs of the Organization. The Organization originally calculated the cash draw based upon the number of participants served in the program instead of the amount of allowable costs incurred for the program. Management of the Organization identified the overdraw and refunded $1,027,988 to the grantor within a month of the initial draw, which represents the amount drawn in excess of expenditures incurred. Cause The Organization did not have internal controls in place to ensure that the cash drawn was limited to the minimum amount needed for immediate cash needs of the program. Effect The Organization withdrew $1,027,988 in excess of immediate cash needs for the program and refunded the balance to the grantor after the error was identified within a month of the excess draw. Questioned Costs Not applicable. Repeat Finding Not a repeat finding. Recommendation We recommend the Organization implement internal controls to ensure that cash draws represent the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.