International Institute of Wisconsin, Inc.

EIN: 390806350

UEI: C8ZJBGFGQMJ8

Data as of August 26, 2026

International Institute of Wisconsin, Inc.5 audit years3 findings1 repeat
5
Audit Years
3
Total Findings
1
Repeat Findings

FY 2023-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 1, 2025. 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 January 1, 2026 (238 days ago).

What is a management decision? →
2023-001
Cost Allowability
MATERIAL WEAKNESSREPEATQUESTIONED COSTS

The Organization created an allocation plan at the beginning of the year; however, as new funding was awarded the plan stayed the same. During the first quarter of the fiscal year, nine employees payroll was over allocated to grants and programs. During the second quarter allocations were updated but still resulted in seven employees’ payroll being allocated to grants and programs. This issue was resolved in the third quarter. However in two months of the fourth quarter three employees were over allocated. The Organization did not accurately update allocation of payroll throughout the year to verify employees were not over allocated. Also, after year end, it came to the Organization’s attention that formulas in their allocation worksheet were not correct. Therefore the calculations of payroll allocations to the various programs were not done correctly. 4) Cause: The Organization does not maintain sufficient payroll allocation support and, accordingly, the payroll allocation is not recorded based on actual costs incurred. The Organization also does not have a process in place to verify the accuracy of their payroll allocations in place, and, accordingly, the payroll allocation is not recorded accurately based on time worked for each grant. 5) Effect: Payroll allocations should be updated and reviewed throughout the year to include all grants and programs to properly account for the activities of the Organization and to properly report payroll costs on cost reports to funding sources. 6) Questioned costs: • Salaries and Benefits $62,058 Major Programs o U.S. Committee for Refugees and Immigrants  Reception & Placement: $47,259  Matching Grant $4,423 Other Impacted Pass-Through Funding o WI Department of Children and Families  Refugee Support Services $7,834  Refugee Health Administration $2,429  Refugee Health Promotion $113 Salaries were computed by calculating FTE allocations over one for each individual employee and multiplying by their respective salary costs for the year. Payroll taxes were over-allocated salary costs multiplied by 7.65%. Employee Benefits were salary costs multiplied by 32%, which was the salaries to benefits ratio the Organization used for the year. 7) Prevalence or consequence: All quarters were impacted by allocation plan issues.  8) Recommendation to prevent future occurrences. We recommend that the Organization develop a time and/or activity reporting methodology to adequately document the payroll charges by grant and program. We also recommend that all cost allocations be reviewed and approved by the executive director. We also recommend that the Organization develop a review process and checks and balances system to adequately test that payroll charges are coded to the correct grants and programs. We also recommend that all calculations be reviewed and approved by the executive director. 9) Views of responsible officials at auditee. See attachment for Organization’s corrective action plan.

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Full finding narrative

1) Federal program and specific federal award Identification: Major Programs • CFDA #19.510 U.S. Refugee Admissions Program o Federal Agency: U.S. Department of State/Bureau of Population, Refugees, and Migration o Pass through Agency: U.S. Committee for Refugees and Immigrants • CFDA #93.576 Refugee and Entrant Assistance - Discretionary Grants o Federal Agency: U.S. Department of Health and Human Services o Pass through Agencies: Wisconsin Department of Children and Families and U.S. Committee for Refugees and Immigrants Other Impacted Pass-Through Funding • CFDA #93.566 Refugee and Entrant Assistance - Discretionary Grants o Federal Agency: U.S. Department of Health and Human Services o Pass through Agency: U.S. Committee for Refugees and Immigrants 2) Criteria: Payroll should be allocated to grants and programs based on actual payroll costs incurred. Allocations should be updated as new grant funds are awarded. Payroll allocation plans should be reviewed for accuracy and safeguard in place to identify any errors. 3) Condition: The Organization created an allocation plan at the beginning of the year; however, as new funding was awarded the plan stayed the same. During the first quarter of the fiscal year, nine employees payroll was over allocated to grants and programs. During the second quarter allocations were updated but still resulted in seven employees’ payroll being allocated to grants and programs. This issue was resolved in the third quarter. However in two months of the fourth quarter three employees were over allocated. The Organization did not accurately update allocation of payroll throughout the year to verify employees were not over allocated. Also, after year end, it came to the Organization’s attention that formulas in their allocation worksheet were not correct. Therefore the calculations of payroll allocations to the various programs were not done correctly. 4) Cause: The Organization does not maintain sufficient payroll allocation support and, accordingly, the payroll allocation is not recorded based on actual costs incurred. The Organization also does not have a process in place to verify the accuracy of their payroll allocations in place, and, accordingly, the payroll allocation is not recorded accurately based on time worked for each grant. 5) Effect: Payroll allocations should be updated and reviewed throughout the year to include all grants and programs to properly account for the activities of the Organization and to properly report payroll costs on cost reports to funding sources. 6) Questioned costs: • Salaries and Benefits $62,058 Major Programs o U.S. Committee for Refugees and Immigrants  Reception & Placement: $47,259  Matching Grant $4,423 Other Impacted Pass-Through Funding o WI Department of Children and Families  Refugee Support Services $7,834  Refugee Health Administration $2,429  Refugee Health Promotion $113 Salaries were computed by calculating FTE allocations over one for each individual employee and multiplying by their respective salary costs for the year. Payroll taxes were over-allocated salary costs multiplied by 7.65%. Employee Benefits were salary costs multiplied by 32%, which was the salaries to benefits ratio the Organization used for the year. 7) Prevalence or consequence: All quarters were impacted by allocation plan issues.  8) Recommendation to prevent future occurrences. We recommend that the Organization develop a time and/or activity reporting methodology to adequately document the payroll charges by grant and program. We also recommend that all cost allocations be reviewed and approved by the executive director. We also recommend that the Organization develop a review process and checks and balances system to adequately test that payroll charges are coded to the correct grants and programs. We also recommend that all calculations be reviewed and approved by the executive director. 9) Views of responsible officials at auditee. See attachment for Organization’s corrective action plan.

Corrective Action Plan

AUDIT FINDINGS Currently, IIW is concluding an outside objective review of grants/contracts, since August 2022, to confirm the audit findings for 2022 and combined with the 2023 regular audit IIW should be able to determine the exact amounts, any payback through adjustments made by the state for subsequent payments after errors were made, and the nature of the over allocation of FTE’s. The reason for the need to combine the 2022 with 2023 audits is that the state and federal fiscal year beginning and ending overlap IIW’s fiscal year period. IIW does not dispute findings from the 2022 & 2023 audits. Corrective Actions: • Participating in close financial monitoring with granting agencies • IIW Audit Manual created and ratified by IIW Board • Improved Segregation of Financial Roles • Implemented new financial system to facilitate improvements in GAAP • Implemented new chart of accounts to facilitate improved reporting, reconciliation, and billing • Improved reconciliation for both bank and programs • Improved financial controls for banking and investment management • Began reimbursement of identified funds that are required to be paid back to granting agencies Sincerely yours, Paul F. Trebian, Ed.D., MBA/TM, MA, BS President & CEO International Institute of Wisconsin ptrebian@iiwisconsin.org 414-403-9735 Cell CST

Prior Finding References

2022-001

About Allowable Costs / Cost Principles →
2023-002
Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS

The Organization used 32% of salaries and wages to report benefits throughout the year. Based on ending balances in benefit accounts, this percentage should have been 19.53%. 4) Cause: The Organization does not have a process in place to ensure benefits are being accurately charged to grants. 5) Effect: Payroll benefit percentages should be reviewed throughout the year for accuracy to ensure all grants and programs properly account for the activities of the Organization and to properly report benefit costs on cost reports to funding sources. 6) Questioned costs: • Employee Benefits $64,011 Major Programs o U.S. Committee for Refugees and Immigrants  Reception & Placement: $18,848  Matching Grant $8,761  Preferred Communities $19,798 Other Impacted Pass-Through Funding o WI Department of Children and Families  Refugee Support Services $12,265  Refugee Health Administration $2,505  Refugee Health Promotion $1,834 7) Prevalence or consequence: This impacted all quarters of the fiscal year. 8) Recommendation to prevent future occurrences. We recommend that the Organization develop a review process and checks and balances system to adequately test that benefit charges are coded to the correct grants and programs for actual amounts. We also recommend that all calculations be reviewed and approved by the executive director. 9) Views of responsible officials at auditee. See attachment for Organization’s corrective action plan.

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Full finding narrative

1) Federal program and specific federal award Identification: Major Programs • CFDA #19.510 U.S. Refugee Admissions Program o Federal Agency: U.S. Department of State/Bureau of Population, Refugees, and Migration o Pass through Agency: U.S. Committee for Refugees and Immigrants • CFDA #93.576 Refugee and Entrant Assistance - Discretionary Grants o Federal Agency: U.S. Department of Health and Human Services o Pass through Agencies: Wisconsin Department of Children and Families and U.S. Committee for Refugees and Immigrants Other Impacted Pass-Through Funding • CFDA #93.566 Refugee and Entrant Assistance - Discretionary Grants o Federal Agency: U.S. Department of Health and Human Services o Pass through Agency: Wisconsin Department of Children and Families and U.S. Committee for Refugees and Immigrants o 2) Criteria: Payroll benefits should be reported at actual costs not estimated percentage. 3) Condition: The Organization used 32% of salaries and wages to report benefits throughout the year. Based on ending balances in benefit accounts, this percentage should have been 19.53%. 4) Cause: The Organization does not have a process in place to ensure benefits are being accurately charged to grants. 5) Effect: Payroll benefit percentages should be reviewed throughout the year for accuracy to ensure all grants and programs properly account for the activities of the Organization and to properly report benefit costs on cost reports to funding sources. 6) Questioned costs: • Employee Benefits $64,011 Major Programs o U.S. Committee for Refugees and Immigrants  Reception & Placement: $18,848  Matching Grant $8,761  Preferred Communities $19,798 Other Impacted Pass-Through Funding o WI Department of Children and Families  Refugee Support Services $12,265  Refugee Health Administration $2,505  Refugee Health Promotion $1,834 7) Prevalence or consequence: This impacted all quarters of the fiscal year. 8) Recommendation to prevent future occurrences. We recommend that the Organization develop a review process and checks and balances system to adequately test that benefit charges are coded to the correct grants and programs for actual amounts. We also recommend that all calculations be reviewed and approved by the executive director. 9) Views of responsible officials at auditee. See attachment for Organization’s corrective action plan.

Corrective Action Plan

AUDIT FINDINGS Currently, IIW is concluding an outside objective review of grants/contracts, since August 2022, to confirm the audit findings for 2022 and combined with the 2023 regular audit IIW should be able to determine the exact amounts, any payback through adjustments made by the state for subsequent payments after errors were made, and the nature of the over allocation of FTE’s. The reason for the need to combine the 2022 with 2023 audits is that the state and federal fiscal year beginning and ending overlap IIW’s fiscal year period. IIW does not dispute findings from the 2022 & 2023 audits. Corrective Actions: • Participating in close financial monitoring with granting agencies • IIW Audit Manual created and ratified by IIW Board • Improved Segregation of Financial Roles • Implemented new financial system to facilitate improvements in GAAP • Implemented new chart of accounts to facilitate improved reporting, reconciliation, and billing • Improved reconciliation for both bank and programs • Improved financial controls for banking and investment management • Began reimbursement of identified funds that are required to be paid back to granting agencies Sincerely yours, Paul F. Trebian, Ed.D., MBA/TM, MA, BS President & CEO International Institute of Wisconsin ptrebian@iiwisconsin.org 414-403-9735 Cell CST

About Allowable Costs / Cost Principles →

FY 2022-06-30

FAC accepted this audit on September 28, 2023 — management decision was due March 28, 2024.

2022-001
Activities Allowed or Unallowed / Cost Allowability / Cash Management / Eligibility / Matching, Level of Effort, Earmarking / Period of Performance / Reporting / Subrecipient Monitoring
MATERIAL WEAKNESSQUESTIONED COSTS

The Organization created an allocation plan at the beginning of the year; however, as new funding was awarded the plan stayed the same. Starting in the second quarter of the fiscal year, nine employees payroll was over allocated to grants and programs. The Organization did not update allocation of payroll throughout the year to verify employees were not over allocated.4) Cause: The Organization does not maintain sufficient payroll allocation support and, accordingly, the payroll allocation is not recorded based on actual costs incurred.5) Effect: Payroll allocations should be updated throughout the year to include all grants and programs to properly account for the activities of the Organization and to properly report payroll costs on cost reports to funding sources.6) Questioned costs:? Salaries $81,319? Payroll Taxes $6,221? Employee Benefits $12,200Salaries were computed by calculating FTE allocations over 1 for each individual employee and multiplying by their respective salary costs for the year. Payroll taxes were over-allocated salary costs multiplied by 7.65%. Employee Benefits were salary costs multiplied by 15%, which was the salaries to benefits ratio for the year.7) Prevalence or consequence: The over allocation started in the second quarter of the fiscal year and continued throughout the remainder of the fiscal year.8) Recommendation to prevent future occurrences. We recommend that the Organization develop a time and/or activity reporting methodology to adequately document the payroll charges by grant and program. We also recommend that all cost allocations be reviewed and approved by the executive director.9) Views of responsible officials at auditee. See attachment for Organization?s corrective action plan.

Show full finding ▾
Full finding narrative

Item 2022-0011) Federal program and specific federal award Identification:? CFDA #19.510 U.S. Refugee Admissions Programo Federal Agency: U.S. Department of State/Bureau of Population, Refugees, and Migrationo Pass through Agency: U.S. Committee for Refugees and Immigrants? CFDA #93.566 Refugee and Entrant Assistance - Discretionary Grantso Federal Agency: U.S. Department of Health and Human Serviceso Pass through Agency: Wisconsin Department of Children and Families and U.S. Committee for Refugees and Immigrants? CFDA #93.576 Refugee and Entrant Assistance - Discretionary Grantso Federal Agency: U.S. Department of Health and Human Serviceso Pass through Agencies: Wisconsin Department of Children and Families and U.S. Committee for Refugees and Immigrants2) Criteria: Payroll should be allocated to grants and programs based on actual payroll costs incurred. Allocations should be updated as new grant funds are awarded.3) Condition: The Organization created an allocation plan at the beginning of the year; however, as new funding was awarded the plan stayed the same. Starting in the second quarter of the fiscal year, nine employees payroll was over allocated to grants and programs. The Organization did not update allocation of payroll throughout the year to verify employees were not over allocated.4) Cause: The Organization does not maintain sufficient payroll allocation support and, accordingly, the payroll allocation is not recorded based on actual costs incurred.5) Effect: Payroll allocations should be updated throughout the year to include all grants and programs to properly account for the activities of the Organization and to properly report payroll costs on cost reports to funding sources.6) Questioned costs:? Salaries $81,319? Payroll Taxes $6,221? Employee Benefits $12,200Salaries were computed by calculating FTE allocations over 1 for each individual employee and multiplying by their respective salary costs for the year. Payroll taxes were over-allocated salary costs multiplied by 7.65%. Employee Benefits were salary costs multiplied by 15%, which was the salaries to benefits ratio for the year.7) Prevalence or consequence: The over allocation started in the second quarter of the fiscal year and continued throughout the remainder of the fiscal year.8) Recommendation to prevent future occurrences. We recommend that the Organization develop a time and/or activity reporting methodology to adequately document the payroll charges by grant and program. We also recommend that all cost allocations be reviewed and approved by the executive director.9) Views of responsible officials at auditee. See attachment for Organization?s corrective action plan.

Corrective Action Plan

International Institute of Wisconsin, Inc.Single Audit Corrective Action PlanFor the Fiscal Year Ended June 30, 2022AUDIT FINDINGFinding Reference Number: 2022-001Description of Finding: Payroll and related expenses were over allocated to grants.Statement of Concurrence or Nonconcurrence:This letter is in response to the condition set forth on page 34 Item #9, of the IIW 2022 Audit.Paul F. Trebian, President & CEO of IIW as of June 7, 2023, has discussed with IIW?s account and dataspecialist circumstances around the information provided on page 33 for Internal Control over majorprograms. Findings of audit indicate over allocation of FTEs against Type A (state contracts) for$250,000; and Type B (federal contracts) for $62,500.IIW agrees with the findings of the IIW 2022 Audit.Corrective Action:Currently, IIW is conducting an outside objective review of grants/contracts, since August 2022, toconfirm the audit findings for 2022 and combined with the next 2023 regular audit IIW should be able todetermine the exact amounts, any payback through adjustments made by the state for subsequentpayments after errors were made, and the nature of the over allocation of FTE?s.The reason for the need to combine with the next year 2023 audit is that the state and federal fiscal yearbeginning and ending overlap IIW?s fiscal year period.This is an important matter to investigate in an objective manner, so that we can determine a course ofaction to properly address the matter. Once the entire matter has been analyzed, IIW will be able todetermine actions to perform to provide process improvement to prevent over allocation in the future. Asa part of that process, the organization will certainly adopt the audit recommendation that it develop atime and/or activity reporting methodology to adequately document the payroll charges by grant andprogram, and that its cost allocations be reviewed and approved by the executive director.Name of Contact Person:Paul F. Trebian, Ed.D., MBA/TM, MA, BSPresident & CEOInternational Institute of Wisconsinptrebian@iiwisconsin.org414-403-9735 CellCSTProjected Completion DateIIW plans on wrapping up the investigation in a few weeks, and then will have more information tocommunicate following actions to adopt the audit recommendations and reporting methodology.QUESTIONED COSTS1. For each questioned cost, the organization should identify the amount by state financialassistance or award program and the program period.2. If the organization believes a questioned cost is an allowable cost, a statement providingreasons for the organization's position should be included.3. If the cost is questioned because the organization failed to provide the auditors withdocumentation supporting the allowability of the questioned cost, and the documentation subsequentlybecomes available, the organization should provide such documentation as part ofthe submission of the corrective action plan. The organization should describe how the records documentthe allowability of the cost.4. If the organization determines that the questioned costs are unallowable or that the chargescannot be supported, the organization should provide a statement to that effect and remit payment for theunallowable or unsupported costs with the corrective action plan.If the (Office of Policy and Management and/or Oversight Agency) has questions regarding thisPlan, please call Paul F. Trebian at 414-225-6220.Sincerely yours,Paul F. Trebian, Ed.D., MBA/TM, MA, BSPresident & CEOInternational Institute of Wisconsinptrebian@iiwisconsin.org414-403-9735 CellCST

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