The Immigrant and Refugee Community OrganizationNon-Profit

Finding 2024-005 Reporting (Significant Deficiency) Federal Assistance Listing Number: 17.258/17.278, 21.027, 93.576, 93.568 Federal Programs: WIOA Cluster, Coronavirus State and Local Fiscal Recovery Funds, Low-Income Home Energy Assistance, Refugee Entrant Assistance Discretionary Grants Federal Agencies: Department of Labor, Department of Treasury, Department of Health and Human Services Pass Through Entities: Clackamas Workforce Partnership, Coalition of Communities of Color, Multnomah County, Oregon Dept. of Justice, Worksystems, U.S. Committee for Refugees and Immigrants Federal Award Year: 2022, 2023, 2024 Repeat Finding: 2023-005 Criteria: As part of the agreements with granting agencies, the Organization is required to submit financial and performance reports by specific dates throughout the grant period. Condition: A test of 12 reports from the four major programs/clusters identified that 7 reports lacked evidence of secondary review by management. Cause: Policies and procedures were not established to ensure that reports prepared for grantors are reviewed. Corrective actions taken by management from prior audit recommendations were implemented after the current fiscal year end. Effect: Failure to review reports may result in inaccurate financial and performance reporting to grantors. Recommendation: Appropriate policies and procedures should be established to ensure all reports are reviewed and approved by management. Views of Responsible Officials: Contact person responsible: Tanja Lux, Director of Finance Corrective action planned: We will establish policies and procedures to ensure all reports are reviewed and approved by management. We are introducing Program Management Standards on October 1, 2025. After implementation, we will work on the technology for how to document reviews.

Finding 2023-005 Reporting (Significant Deficiency) Federal Assistance Listing Number: 21.027, 93.576, 93.568 Federal Programs: Emergency Rental Assistance Program Federal Agencies: Department of Treasury, Department of Health and Human Services Pass Through Entities: Clackamas Workforce Partnership, Coalition of Communities of Color, Multnomah County, Oregon Dept. of Justice, Oregon Food Bank, Prosper Portland, Washington County, Worksystems, U.S. Committee for Refugees and Immigrants Federal Award Year: 2022, 2023 Repeat Finding: No Criteria: As part of the agreements with granting agencies, the Organization is required to submit financial and performance reports by specific dates throughout the grant period. Condition: A test of 9 reports from the three major programs identified that all reports lacked evidence of secondary review by management. Cause: Policies and procedures were not established to ensure that reports prepared for grantors are reviewed. Effect: Failure to review reports may result in inaccurate financial and performance reporting to grantors. Recommendation: Appropriate policies and procedures should be established to ensure all reports are reviewed and approved by management. Views of Responsible Officials: Contact person responsible: Tanja Lux, Director of Finance Corrective action planned: We will establish policies and procedures to ensure all reports are reviewed and approved by management.

Finding Number: 2022-004; Finding Type: Federal award finding; Federal Assistance Listing No.: 21.027; Program Name: Coronavirus State and Local Fiscal Recovery Funds; Federal Agency: Department of Treasury; Pass-Through Entity: Multnomah County, Worksystems, Inc., Prosper Portland; Grant Number: 2289-17-01, 20-30701, 21-30600, 21-30702, 21-30710, 22-30600, 22-30710, DCHS-SVCSGEN-12988-2021; DCHS-SVCSGEN-12994-2021, DCHS-SVCSGEN-14074-2022, HD-SVCSGEN-13829-2022; Federal Award Year: 2022; Control Deficiency Type: Significant deficiency over compliance; Instances of Noncompliance: Yes; Compliance requirement: Allowable Costs; Questions Costs: None; Repeat Finding: No Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Appendix IV – Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit Organizations, requires that organizations that have previously established indirect cost rates must submit a new indirect cost proposal to the cognizant agency for indirect costs within six months after the close of each fiscal year, unless approval is obtained from their cognizant agency to waive the requirement. Condition: During the audit, we requested a copy of the organization’s indirect cost rate proposal for audit purposes. The organization was unable to provide a copy to us, informing us that preparation and submission of the proposal was only required every two years, not annually. When we recommended that they confirm this with their cognizant agency, the organization was informed that submission of the proposal is indeed an annual requirement, and that they had missed the deadlines for both the fiscal 2021 and 2022 filings. Subsequently, the organization has received approval for an extension to May 31, 2023 for both years. Cause: Lack of internal controls to ensure that the indirect cost rate proposal is being submitted as required. Effect: The organization did not follow rules established under Uniform Guidance. Questioned costs: None. Audit Recommendation: We recommend that the organization implement internal control procedures to ensure that indirect cost rate proposal to be submitted in a timely manner. Management’s Response: Management has requested and was approved for an extension and will submit the indirect cost rate proposal before May 31, 2023. Thereafter, management will ensure that the indirect cost rate proposal is submitted annually

Finding number: 2020-003 CFDA number: 16.575 Program name: Crime Victim Assistance Federal agency: United States Department of Justice Pass-through entity: n/a Grant number: Joint-2019-IRCO-00029 Federal award year: 2019 through 2021 Finding type: Significant Deficiency and noncompliance Compliance requirement: Reporting Questioned costs: n/a Repeat finding: n/a Criteria: The organization must have internal controls in place to provide reasonable assurance that all the re-quired reports are submitted in a timely manner, are supported by underlying accounting and/or performance rec-ords, and are fairly presented in accordance with program requirements. Condition: During our audit, we noted that certain financial reports submitted to a funding agency had not been reviewed by someone independent of the preparer. In addition, three of the submitted reports contained financial information on expenditures that did not agree to the underlying accounting records. All quarterly reports filed during the year under audit were selected for testing. Cause: Internal controls are not designed and implemented to ensure that all required reports are submitted time-ly and with correct information. In addition, no one independent of the preparer reviewed the reports for accura-cy. Effect: Missed filings of required reports and incorrect information reported to the federal agency prevented prop-er oversight by the funding agency and an underreporting of expenditures totalling $11,181. Unallowable Costs: None. Audit Recommendation: We recommend that management implement procedures to ensure all required reports are submitted properly and in a timely manner, and strengthen the organization?s review procedures related to the preparation of its Financial Reports. At a minimum, someone independent of the preparer should review the re-ports and reconcile the data reported to that in underlying accounting records, to ensure that the information re-ported is complete and accurate. Management?s Response: Management agrees with our auditors? comments. Management has begun to implement procedures to ensure that all required Financial Reports submitted by our Program Team will be submitted on time. Before the report submission, the Program Team must obtain the Fiscal Team to review and approve these reports.