EL PROGRAMA HISPANO CATOLICO

Finding #2025-001: Type: Significant deficiency on controls relating to reporting requirements. Assistance Listing Number: 16.575 – Crime Victim Assistance – Department of Justice. Requirement: In accordance with the grant agreement between El Programa Hispano Católico and the Department of Justice, the Organization is to submit various financial and performance reports on a quarterly, semi-annual or annual basis. The reports must be filed within 20 days or one month, depending on the type of report, or period end. Condition: There was no evidence of review or approval of the reports by a program supervisor before being submitted to the Department of Justice. Cause: This is not a control the Organization has previously utilized, so the cause is a lack of implementation. Effect: Reports could be submitted with inaccurate information. Questioned Costs: None. Repeat Finding: Yes. See 2024-007 Recommendation: We recommend that all required report filings have review and signature approval from appropriate management personnel before submission to funder. Management Response: Beginning March 2026, the Organization will require review and signature on all reporting before submission to funder.

Finding #2025-002: Type: Significant deficiency over preparation of the schedule of expenditures of federal awards (SEFA) Assistance Listing Number: 93.045, 93.052, 93.053 – Aging Services Cluster – Department of Health and Human Services 14.267 – Continuum of Care – Department of Housing and Urban Development 93.497, 93.671 – Family Violence Prevention Services – Department of Health and Human Services Requirement: The Organization should have systems in place to prepare a complete and accurate SEFA. Condition: Inaccuracies were identified in the SEFA prepared by management. Cause: This is not a control the Organization has previously utilized, so the cause is a lack of implementation. Effect: Inaccuracies of the SEFA may impact Single audit and major program determination. Changes to the SEFA resulted in approximately $150,000 less in federal expenditures. Questioned Costs: None. Repeat Finding: No. Recommendation: The Organization should implement additional procedures and controls to accurately capture all activity under federal awards in preparing the SEFA. This should involve active communication with the pass-through funding agencies so there is a clear understanding of the composition of funding. Management Response: Beginning March 2026, the Organization will work with funders to make sure there is accurate tracking of the federal components of any pass-through grant.

Finding 2024-003 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over activities allowed or unallowed and allowable costs/cost principles and significant deficiency in internal controls Criteria: According to CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: The Organization charged payroll expenditures to the grant which were not based on records maintained which reflected the work performed. Cause: Payroll is processed by an external third party, and the system was setup originally to base pay on time budgets rather than actual hours spent. In addition, there were errors in the payroll allocations to various programs Effect: The Organization charged expenditures to the grant which were unallowable. Likely Questioned Costs: $4,059 Repeat Finding: No Recommendations: We recommend the Organization review the payroll allocations in the payroll system to ensure they are supported by actual time spent on the program. In addition, the payroll calculations should be reviewed to ensure the amounts allocated to the various programs are correct. Views of Responsible Officials: The Organization uses a third-party vendor to process payroll. This system does not have the capability to allocate salaried employees based on time spent on the program recorded in the time keeping system. Because of this, the hours worked in each program need to be converted into percentages before payroll is submitted for processing. To ensure accuracy, the Organization will have a second reviewer confirm the manual entry conversion from hours worked to percentage of time worked for salaried employees for the remaining duration of time in a third-party payroll system. Effective January 2026, the Organization will implement a new payroll system that will be processed in-house. This system has improved functionality that will eliminate the need to make this conversion and the potential for errors.

Finding 2024-004 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to employee training and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, program employees must complete Crime Victims Compensation Training every 4 years. Condition: The Organization did not maintain proof that program employees completed the required training. Cause: The Organization’s policies and procedures did not require certificates of completion be maintained for training completed. Effect: If required training is not completed, program employees may lack the knowledge needed to operate the program. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure training is completed timely and certificates of completion are maintained. Views of Responsible Officials: Moving forward a new process of policy with record keeping guidance will be implemented to ensure the documentation is kept on file. For training courses that do not provide a completion certificate, staff will prepare a memo with self-attestation of completion for our records.

Finding 2024-005 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to Board Member training and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, at least one Board Member must complete at least 12 hours of training in the first year of service related to board rules and responsibilities, core victim services, confidentiality and civil rights. Condition: The Organization did not maintain proof that at least one board member had completed the required 12 hours of training. Cause: The Organization’s policies and procedures did not require certificates of completion be maintained for training completed. Effect: If required training is not completed, board members may lack the knowledge needed to oversee the program. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure training is completed timely and certificates of completion are maintained. Views of Responsible Officials: The delegates from the board did receive the training prior to entering the board but were unable to provide certification proof. Moving forward a new process of policy with record keeping guidance will be implemented to ensure the documentation is kept on file. For training courses that do not provide a completion certificate, Board members will prepare a memo with self-attestation of completion for our records.

Finding 2024-006 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over special tests and provisions related to employment eligibility and significant deficiency in internal controls Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, the Organization must obtain a criminal history record check on any employee, potential employee or volunteer working with victims of crime. Condition: The Organization was unable to locate the criminal history verification form for an employee working within the program. Cause: The Organization was previously a part of Catholic Charities of Oregon. The employee in question was originally hired by Catholic Charities of Oregon and the Organization did not re-verify eligibility when it spun off from Catholic Charities of Oregon. Catholic Charities of Oregon and the Organization were both unable to provide documentation that a criminal history verification was completed. Effect: Employees who are not eligible to be employed by the program may be employed. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure documentation of criminal history verification is maintained for all employees. Views of Responsible Officials: The Organization has long term employees that joined the organization when it was a program of Catholic Charities. The Organization does not maintain these records for employees that began with Catholic Charities. In early FY2026, The Organization will complete background checks on long term employees to ensure we maintain the proper documentation.

Finding 2024-007 Identification of the Federal Program: 16.575 – Crime Victim Assistance Compliance finding over reporting and significant deficiency in internal controls related to reporting Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and the Department of Justice, the Organization is to submit various financial and performance reports on a quarterly, semi-annual or annual basis. The reports must be filed within 20 days or one month, depending on the type of report, or period end. Condition: The Organization did not submit any of the required reports timely. In addition, no evidence of review was noted on one quarterly report or any of the performance reports. Cause: Internal control processes and procedures were not in place to ensure required reports were filed timely. Effect: The Department of Justice relies on reports to monitor the activities of the Organization, and without these reports, the Department of Justice cannot provide sufficient oversight of grant activities. Questioned Costs: None Repeat Finding: No Recommendations: We recommend the Organization develop internal control processes and procedures to ensure reports are filed timely. Views of Responsible Officials: The Director of Finance and Accounting Manager began implementing process and procedures to ensure all invoices are filed in a timely manner to funders in July 2024. The importance of understanding the requirements of the agreements has been stressed to the finance team. The team has also been instructed to save on SharePoint all communication with funders regarding changes of when invoices are to be filed when the instructions differ from the agreement. To ensure timely submission of the performance reports, the Organization will use Sales Force software to track all due dates. This system will send reminders and will record submission dates. To ensure review of all performance reports, procedures will be put in place outlining roles and responsibilities of report preparation by managers and review by Program Directors.

Finding 2024-008 Identification of the Federal Program: 93.568 – Low-Income Home Energy Assistance Program Compliance finding over reporting and significant deficiency in internal controls related to reporting Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and Multnomah County, the Organization is to submit monthly expenditure reports by the 20th calendar day of the month following the month in which the expenditures were incurred. In addition, the Organization is to submit semi-annual internal financial statements within 30 days of December 31st and June 30th. Condition: The Organization did not submit 7 of the required 12 monthly financial reports or semi-annual internal financial statements timely to Multnomah County. Cause: Internal control processes and procedures were not in place to ensure required reports were filed timely. Effect: Multnomah County relies on monthly reports to monitor the activities of the Organization, and without these reports, Multnomah County cannot provide sufficient oversight of grant activities. Questioned Costs: None Repeat Finding: Yes Recommendations: We recommend the Organization develop internal control processes and procedures to ensure reports are filed timely. Views of Responsible Officials: The Organization began implementing processes and procedures to ensure all invoices are filed in a timely manner to funders in July 2024. The importance of understanding the requirements of the agreements has been stressed to the finance team. The team has also been instructed to save on SharePoint all communication with funders regarding changes of when reports are to be filed when the instructions differ from the agreement. The Organization has been behind on financial statements and previously was not able to submit the semi-annual financial statements. As of June 30, 2025, the first semi-annual financial statements were submitted.

Identification of the federal program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Compliance finding over reporting and significant deficiency in internal controls related to reporting Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and Multnomah County, the Organization is to submit internal financial statements and budget to actual no later than 30 days after June 30th and December 31 st. Additionally, they are to submit SUN Community School Mid-Year reports by January 31st and annual reports by July 17th. Finally, the Organization is to submit quarterly reports for outputs and outcomes related to unconditional client assistance and cash transfers no later than 15 days after quarter end. Condition: The Organization did not submit the internal financial statements, mid-year reports or three of the four quarterly reports timely to Multnomah County. Cause: Internal control processes and procedures were not in place to ensure required monthly reports were filed timely. Effect: Multnomah County relies on the internal financial statements, mid-year reports, annual reports and quarterly reports to monitor the activities of the Organization, and without these reports, Multnomah County cannot provide sufficient oversight of grant activities. Questioned Costs: None Recommendations: We recommend the Organization develop internal control processes and procedures to ensure reports are filed timely. Views of responsible officials: We agree with the need for internal control processes and procedures to ensure both financial and programmatic reports are submitted timely. During the audited period, EPHC experienced staff turnover and vacancies. During this time there were limited accounting staff making timely monthly close challenging which caused delays in financial reporting. Finance team members are following these processes on a consistent basis beginning in fiscal year 2025. EPHC has been delayed in completing financial audits due to complications from separating from Catholic Charities and challenges related to staff turnover and hiring talent. Due to this delay, EPHC was not able to provide internal financial statements. During the audited period, this was communicated with Multnomah County on multiple occasions. In fiscal year 2025, EPHC will communicate with Multnomah County the timeline for reporting internal financial statements and request their approval for delayed reporting. Quarterly reports for outputs and outcomes were often submitted within days of the required reporting date. Beginning in fiscal year 2025, program staff will submit by the due date as outlined in the contract.

Identification of the federal program: 93.568 - Low-Income Home Energy Assistance Program Compliance finding over reporting and significant deficiency in internal controls related to reporting Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and Multnomah County, the Organization is to submit monthly expenditure reports by the 20th calendar day of the month following the month in which the expenditures were incurred. In addition, the Organization is to submit semi-annual internal financial statements within 30 days of December 31 st and June 30th. Condition: The Organization did not submit 2 of the required 12 monthly financial reports or semi-annual internal financial statements timely to Multnomah County. Cause: Internal control processes and procedures were not in place to ensure required reports were filed timely. Effect: Multnomah County relies on reports to monitor the activities of the Organization, and without these reports, Multnomah County cannot provide sufficient oversight of grant activities. Questioned Costs: None Recommendations: We recommend the Organization develop internal control processes and procedures to ensure reports are filed timely. Views of responsible officials: We agree with the need for internal control processes and procedures to ensure the financial reports are submitted on time. During the audited period, EPHC experienced staff turnover and vacancies. During this time there were limited accounting staff making timely monthly close challenging which caused delays in financial reporting. Beginning in fiscal year 2025, finance team members are following these processes on a consistent basis.

Identification of the federal program: 14.267 – Continuum of Care Program Significant deficiency in internal controls related to special tests and provisions Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization has established internal control procedures over special tests and provisions specifically as they apply to reasonable rent, however, the procedures were not applied to all items tested during the audit. Eight files were selected for testing, and one did not include evidence of internal control procedures being applied. Cause: The Organization had policies in procedures in place over special tests and provisions but they were not applied consistently. Effect: Errors could be made in determining whether a unit’s rent is reasonable, and without the consistent application of internal controls, these errors may go unnoticed resulting in a unit being rented whose fair market value rent is outside of the parameters set by the Department of Housing and Urban Development. Questioned Costs: None Recommendations: We recommend the Organization consistently apply internal controls. Views of responsible officials: We agree we need to apply our internal controls as outlined in our policies and procedures consistently. Seven of the eight files tested did follow our policies and procedures. During this fiscal year, we were negatively impacted by the effects of COVID and experienced program manager turnover. Program managers are following these processes on a consistent basis moving forward.

Identification of the federal program: 93.568 – Low-Income Home Energy Assistance Program Compliance finding over reporting and significant deficiency in internal controls related to reporting Criteria: In accordance with the grant agreement between El Programa Hispano Catolico and Multnomah County, the Organization is to submit monthly expenditure reports by the 20th calendar day of the month following the month in which the expenditures were incurred. Condition: The Organization did not submit financial reports timely to Multnomah County. Cause: Internal control processes and procedures were not in place to ensure required monthly reports were filed timely. Effect: Multnomah County relies on monthly reports to monitor the activities of the Organization, and without these reports, Multnomah County cannot provide sufficient oversight of grant activities. Questioned Costs: None Recommendations: We recommend the Organization develop internal control processes and procedures to ensure reports are filed timely. Views of responsible officials: We agree with the need for internal control processes and procedures to ensure the finance team files reports timely. During the audited period, the financial reporting was transitioning to EPHC from Catholic Charities, and staff were hired and trained on the financial reporting. Within 6 months of this transition starting, reports were submitted timely. Finance team members are following these processes on a consistent basis moving forward.

Finding 2021-001 Type of Finding: Material weakness in internal control over compliance. Federal Programs: All federal programs Criteria: The Uniform Guidance, under 2 CFR Part 200 Subpart F, requires the auditee to prepare a schedule of expenditures of federal awards for the period covered by the auditee?s financial statements which must include the total federal awards expended. Condition: While performing audit procedures on the schedule of expenditures of federal awards (SEFA), we noted the internal controls in place to identify federal awards and capture all relevant information for federal awards did not detect or prevent material misstatements on the schedule. We noted errors in the titles of federal agencies, assistance listing numbers, and federal expenditures that were improperly included or excluded from the SEFA. Cause: The internal controls currently in place were not properly designed or implemented to detect or prevent material misstatements on the SEFA. Effect: The SEFA was not complete and did not accurately reflect all required information and the SEFA was materially misstated at the commencement of the audit because it improperly included federal expenditures totaling $328,856 and improperly excluded federal expenditures totaling $283,600. Questioned Costs: None. Repeat Finding: No Context: The total of federal expenditures improperly included and improperly excluded from the SEFA represent approximately 8.9 and 7.7 percent of the adjusted SEFA total, respectively. Recommendation: We recommend management design and implement internal controls to ensure all federal assistance is identified at the program level and in the finance department. We also recommend that the Organization develop a process for detail reviewing the information included on the SEFA, including verification of federal award and expenditure amounts with grantors as necessary. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.

Finding 2019-001 - Determination of Personal Services Allocations Identification of the Federal Program(s): CFDA Title/Number: 16.575 Crime Victim Assistance Award identification number and year: (Joint-2015-EPHC-00005, VOCA-C-2016 -EPHC-00039, Joint-2017- EPHC-00020 & VOCA-OT-2016-EPHC -00043) Name of federal agency: United States Department of Justice Name of applicable pass-through entity: State of Oregon - Department of Justice Criteria: In accordance with 2 CFR 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must 1) be supported by a system of internal controls which provides reasonable assurance that the charge are accurate; 2) be incorporated into official records of the non-federal entity; 3) reasonably reflect total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; 4) encompass both 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; 5) comply with the established accounting policies of the non-federal entity; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than activity or cost objective. Budget alone do not qualify as support for charges to the federal awards, but may be used for interim accounting purposes, provided that the non-federal entity's system of internal controls includes processes to review after-the-fact interim charges made to federal awards based on budget estimates. All necessary adjustments must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Condition: Personal services charged were recorded based on budget to the program and an after-the-fact determination of personal services charged to the program was not conducted and adjustments, if necessary, were not recorded or documented. Our audit identified deficiencies in internal control over compliance with the criteria identified above that represent a significant deficiency. The Organization does not have procedures in place to ensure that the determination of personal services cost allocations were completed in accordance with program requirements. The Organization was not in compliance with the criteria identified above, as the Organization did not perform procedures to adjust the costs. Cause: The Organization was not aware of the requirement to make an after-the-fact accounting of time spent on the program. Effect: The amount of personal services charged to the federal award may be overstated or understated. Questioned Costs: The amount of salaries and wages charged to the federal programs that were based on budgeted percentages during the fiscal year 2019 is approximately $127,000. The amount of questioned costs cannot be determined since there are no records that accurately reflect the actual work performed. Context: During the 2019 audit, we identified the cost principles as a key compliance requirement, which includes the requirements for compensation for personal services described above. Payroll was charged based on budgeted percentage on sample selections tested. Identification as a Repeat Finding: This is a repeat finding (2018 initial finding 2018-002). Recommendation: The Organization should review the requirements for cost principles as they relate to compensation for personal services under Uniform Guidance and implement controls to ensure that the internal controls includes processes to review after-the-fact interim charges made to federal awards based on budget estimates and that all necessary adjustments are made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Views of Responsible Officials: Agree

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