HUMANITY & INCLUSIONNon-Profit

Finding 2024-001: Late FFATA Reporting Information on the Federal Programs: 19.511 and 98.001 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. For subaward information, the report must be made no later than the end of the month following the month in which the subaward was issued. Condition: We noted three instances where the subawards were reported after the deadline. Cause: HI-US experienced turnover during the year, leading to delays in the FFATA reporting. Effect or Potential Effect: The delay in reporting results in lack of compliance with the requirement. Questioned Costs: None noted. Context: HI-US did not register their subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System in a timely manner. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that HI-US ensure all first tier subawards in excess of $30,000 are timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System.

Federal Programs: All Programs Criteria: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Condition: Based on their understanding that HI US jointly implements their U.S. Government with the Federation, HI US did not register their subawards to the Federation in the Federal Funding Accountability and Transparency Act Subaward Reporting System. Alternately, in November 2020, HI US reported in the system several previously obligated subawards which were made by the Federation. Cause: HI US did not interpret the latest compliance supplement issued by the Office of Management and Budget regarding subaward reporting requirements to apply to the Federation, or update its financial and accounting policies, and as a result did not adhere to the guidance. Effect or Potential Effect: HI US could inadvertently fail to ensure that subrecipients are in compliance with Federal award agency regulations. Questioned Costs: None noted. Context: HI US did not register their subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that HI US update its policies and procedures to ensure all first tier subawards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System, which would include the subawards to the Federation. In addition, HI US should ensure any subawards are reported within the required time-frame. The list of data elements that are required to be reporting for each subaward in excess of $30,000 include the following: - Subaward Date; - Subawardee DUNS #; - Amount of Subaward; - Subaward Obligation/Action Date; - Date of Report Submission; - Subaward Number

Finding 2019-002 Compliance with U.S. Government Terrorism Requirements Information on the Federal Program: CFDA 98.001 Criteria: Recipients of U.S. Government funds must adhere to the U.S. Government's requirements under Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, on screening all potential vendors, consultants, subrecipients, etc. against the System for Award Management (SAM). The screening of all potential vendors, consultants, subrecipients, etc. must be documented in writing. Condition: Our audit procedures, which consisted of a test of controls over cash disbursements using statistical sampling as well as substantive testwork using prescribed sampling forms, revealed that HI US has screened the direct payees of its Federal expenditures; however, has not screened any vendors or individuals not directly charged to a Federal program. Due to the nature of HI US, most disbursements will be charged to the U.S. Government indirectly through recovery of the indirect expenses. Cause: During the current year transition in the accounting department, the screening process was not completed. Effect or Potential Effect: The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded parties by the United States Government. Questioned Costs: Undetermined Context: HI US engaged in relationships and made payments throughout the fiscal year to parties without a proper screening process in place. The issue is deemed to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: Due to the nature of the organization (primarily Federal funded), we believe there is a significant chance that most disbursements will be charged to the U.S. Government indirectly through recovery of the indirect expenses. As a result, we recommend management ensure a screening process is conducted and properly documented, even for items that are not charged directly to a Federal grant.

Finding 2019-003: Subrecipient Management and Monitoring Information on the Federal Program: CFDA 98.001 Criteria: As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures to prescribe to each individual subrecipient. Condition: HI US has a subrecipient policy, which requires a risk assessment and on-going monitoring procedures to be completed. However, during our 2019 audit, we were informed by management that HI US did not document its monitoring procedures with respect to reviewing the recipient contracted audit report of their subrecipient during 2019. Cause: HI US did not document the review of subrecipient audit report as required by their monitoring procedures. Effect or Potential Effect: Without formal documentation of this monitoring step, we were unable to conclude that there was appropriate oversight/monitoring procedures during the fiscal year. Lack of proper monitoring could result in misuse or mismanagement of Federal funds. Questioned Costs: Undetermined Context: Our audit work in this area consisted of substantive testwork over a sample of subrecipient expenditures that were selected based on a defined threshold. We consider our sample to be representative of the populations, and thus, is a statistically valid sample. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend HI US adhere to its current subaward policy and ensure all monitoring procedures over its subrecipient are performed and documented.