Jewish Family Services of Silicon ValleyNon-Profit

We have received and reviewed the comments in your audit report, which you provided following the audit of our financial statements for the fiscal year ending June 30, 2023. Below is our detailed response to the findings and recommendations: Finding 2023-001: Significant Deficiency in Internal Control over compliance related to reporting, specifically the Federal Audit Clearinghouse Data Collection Form - Modified and Repeated Criteria or Specific Requirements: Uniform Guidance 2 CFR 200.512(a) requires recipients expending $750,000 or more in Federal awards during their fiscal year to submit the data collection and reporting package within the earlier 30 calendar days after the receipt of the auditor’s report(s) or nine months after the end of the audit period. Auditor's Recommendation: Harshwal recommends that the Organization (Jewish Family Services of Silicon Valley, JSFSV) evaluate its policies and procedures regarding report submission to ensure the timely submission of all compliance reports. In addition, the Organization should maintain documentation to support the appropriate and timely submission of the single audit (SF-SAC form). Management Response: JFSSV acknowledges the delay in completing the FY23 audit. The unforeseen need for an additional auditor, identified during the FY22 audit process, significantly impacted our timeline. Despite this challenge, JFSSV promptly engaged a new auditing firm to ensure continuity and accuracy in our financial reporting. JFSSV has implemented proactive measures to streamline its audit preparation and submission processes to prevent similar delays in the future. These include enhancing internal review procedures, ensuring clear communication with auditors, and allocating sufficient resources for timely compliance with reporting requirements, federal regulations, and guidelines. JFSSV's progress is as follows: • FY22 audit was completed by June 24, 2023. • FY23 audit is on track for completion by December 2024. • FY24 audit is targeted for completion by March 2025, ensuring compliance with federal reporting timelines. JFSSV is fully committed to maintaining and improving its financial and operational controls. We will continue to monitor corrective actions and adjust our policies and procedures as necessary to prevent similar issues in the future.

2022-003

Finding 2022-001: Material Weakness in internal controls over compliance for earmarking and material noncompliance for earmarking in the U.S. Refugee Admissions Program: Effect: The Organization may not have met earmarking requirements outlined in the underlying award agreements nor have controls to monitor that earmarking requirements were met effectively. Auditor's Recommendation: We recommend that the Organization implement a process to identify the value of direct assistance provided to each eligible refugee as recorded within the financial records. Further, we recommend that internal controls over compliance be implemented to monitor direct aid distribution and meet the earmarking requirements included within the grant terms. Management Response: We agree with the recommendation and have also submitted the following response. In accordance with the U.S. Department of State, Bureau of Population, Refugees, and Migration (PRM) FY 2019 Reception & Placement (R&P) Cooperative Agreement, all affiliates are required to have written documents available for review evidencing the following: · R&P refugee per capita disbursement policy · How refugee per capita funds beyond the $975 minimum are spent (i.e., Flex Funds policy) · Pocket money disbursement policy · Structured training plan for new and existing staff · Policy on protection from sexual exploitation and abuse (PSEA) · Grievance policy · Policy on cultural orientation (CO) delivery and assessment of refugee understanding · Implementation of accountability to affected populations (AAP) framework Jewish Family Services of Silicon Valley ( JFSSV) has adequate policies and procedures and follows the grantor's guidelines on per-capita earmark funds as stated by the Funder. JFSSV will continue to follow the funder-approved policies and procedures, which state the following: “Per capita funds can be paid by the affiliate directly to the third party, or the affiliate may reimburse U.S. ties or clients for purchases as long as receipts are provided evidencing that the purchases were for allowable material needs. If there are per capita funds remaining at the end of the R&P period and all possible material needs have been provided to the case, including paying rent and utilities forward, the affiliate may write a check to the client for the remainder of the funds. The affiliate must ensure that the situation has been thoroughly documented in the case note log and that the case has no outstanding material needs. This option should be considered an exception and used sparingly.” JFSSV makes every effort to provide the minimum amount to all referred clients as required by the funder. JFSSV meets with clients to provide the initial per capita funding and reviews program requirements for the next per capita funding. If the client follows the program, they are funded. Sometimes, clients leave the program or do not provide adequate documents to be funded, resulting in unspent per capita funds. When this occurs, JFSSV follows the Cooperative Agreement #12.9 Availability of Per Capita Funds: A written statement must be submitted on or before December 31, 20xx, as a Post Award Task through [website link] reporting the amount of per capita funds and accrued interest unexpended and available as of September 30, 20xx. This statement must confirm the amount of those funds expended and reported as a part of the quarterly financial reports for October 1, 20xx, through September 30, 20xx. Should the Recipient have any unexpended per capita funds as of the financial report due on March 31, 20xx, such funds must be returned to the Bureau no later than April 30, 20xx. In addition, JFSSV undergoes vigorous monitoring visits, monthly invoice reviews, and program/fiscal audits, which they pass. JFSSV has provided Harshwal & Company LLP with contracts, cooperative agreements, program guidelines, internal Funder-approved policies & procedures, and all testing requirements with client backup. To address the specific concerns raised regarding internal controls over compliance and earmarking requirements, JFSSV will continue to: Enhanced Monitoring Process: JFSSV will continue monitoring processes to track the value of direct assistance provided to each eligible refugee. Internal Controls Implementation: JFSSV will continue reviewing its internal controls to oversee direct aid distribution with the funder and ensure all requirements are met effectively. Documentation and Reporting: JFSSV will continue to review all disbursements to ensure they are thoroughly documented and reported. This will include maintaining receipts, case notes, and other relevant documentation to provide clear evidence of compliance with earmarking requirements.

Finding 2022‐002: Eligibility‐(Material weakness in Compliance, Internal Control, and Service Provision within the APA (Assistance Program) Program) Effect: The Organization provided APA/R&P program funding to ineligible refugees and lawful permanent residents due to inadequate verification and inconsistent documentation practices. Auditor's Recommendation: The Organization should enhance its eligibility verification process to ensure that only enrolled refugees receive funding. Implementing regular training for staff and updating guidelines will help maintain accurate and complete documentation, ensuring compliance and maximizing the effectiveness of the APA/R&P program. Management Response: We agree with the recommendation and have also submitted the following response: Ensuring refugee eligibility as a sub-recipient of HIAS involves a comprehensive and diligent process. Staff are trained in verification and eligibility as required by the funder and follow an enhanced eligibility verification process. Screening is completed at the funder level to ensure refugee eligibility and program placement. Once approved, a referral is sent to the designated providers. Eligibility: The referral number designates the refugee to a program; even though the Funder system lists “None,” the referral is eligible. For the 7 in the sample, each refugee had a designated approved number from HIAS Verification: In the one exception where a refugee was a lawful permanent resident, JFSSV conducted its due diligence in the verification process and identified the client. This was immediately reported to the funder and rectified as required by the funder. Documentation: During the fiscal year 21/22, amidst the wrap-up of COVID-19, intake was conducted via telehealth processes, and verbal approval was accepted. Additionally, not all services required forms to be signed, such as “providing information on accessing legal permanent resident status, family reunification procedures, assisting school-age children.” These services were verbally discussed during the intake process and updated in the refugees' case notes in the funder system. JFSSV has provided Harshwal & Company LLP with detailed explanations on all samples and provided testing requirements with refugee backup during the audit. JFSSV ensures proper documentation and support as required by the grantor's requirements, and JFSSV adheres to all monitoring visits and grant program reviews To address the specific concerns raised regarding internal controls over compliance and eligibility verification, JFSSV will: Enhance the Eligibility Verification Process: JFSSV will continue to review and strengthen its eligibility verification process to ensure that only enrolled refugees receive funding. Regular Staff Training: JFSSV will ensure continuous training to ensure they are well-versed in the updated guidelines and best practices for eligibility verification and documentation required from the Funder. Improve Documentation Practices: JFSSV will continue best practices in validating eligibility determinations and related documentation to be complete, accurate, and current. This includes maintaining thorough records in the case note log within the Funder’s system.

Finding 2022-003: Internal Controls and Compliance over Reporting (Significant Deficiency) Conditions: The Organization did not submit the quarterly reports within the specified time frame in accordance with the HIAS agreements. Additionally, the Organization did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ending June 30, 2022. The Organization was not in compliance with the reporting requirements, federal regulations, and guidelines. Effect: The Organization was not in compliance with the reporting requirements, federal regulations, and guidelines, and it could be exposed to a reduction or elimination of funds by the federal awarding agencies. Auditor's Recommendation: JFSSV recommends that the Organization evaluate its policies and procedures regarding report submission to ensure the timely submission of all compliance reports. In addition, the Organization should maintain documentation to support the appropriate and timely submission of the single audit (SF-SAC form). Management Response: We agree with the recommendation and have also submitted the following response: According to the HIAS agreement, the following reporting deadlines are specified for HIAS to their funder PRM: Programmatic and Financial Reporting Deadlines: · HIAS must submit performance and financial reports to PRM thirty (30) days after the end of each reporting period and in accordance with the schedule outlined by PRM. · HIAS must also submit a final program and financial report ninety (90) calendar days after the period of performance end date. To ensure timely submission of the foregoing reports to PRM, the Agency “HIAS” shall submit performance and financial reports to HIAS as follows: Programmatic Reports: The Agency will file monthly R&P Period reports through the IRIS database, as well as other programmatic reports as requested by HIAS. Financial Reports: The Agency agrees to submit financial reports monthly on or before the 15th day of the following month after the books have closed. Financial reports must be submitted using the Arrivals and Expenditure Workbook provided by HIAS. HIAS agrees to make payments on these financial reports on or before the 25th day of the month for invoices submitted on or before the 15th day of the month. To ensure HIAS stays in compliance, JFSSV makes every effort to submit accurate reports on time. Funder HIAS agreed in an email sent to the auditors that invoice submission after the 15th is acceptable. As a result, the organization has never been denied reimbursement funding. Some of the delays with invoice submission were due to the following reasons: · When the 15th falls on a weekend (or Friday) or a company and Jewish holidays. · Additional effort to compile client and expense information due to volume and complexity. · The templates required for reporting and reimbursement have not yet been established. · Budget revisions. Furthermore, consultation reports are not considered "submitted" until they receive approval from HIAS. This process ensures no corrections, and the report is finalized and meets the requirements of HIAS reporting. It can take a few days to review and clarify any questions HIAS may have. JFSSV has presented Harshwal & Company LLP with funder approval on late filings and documentation of reporting submission. To address the specific concerns raised regarding internal controls over compliance and reporting, JFSSV will: Evaluate and Update Policies and Procedures: JFSSV will review HIAS-approved Policies and procedures and ensure documentation on any late invoices due to the items listed above. Enhance Communication and Coordination: JFSSV will continue to communicate and coordinate with HIAS to ensure the timely approval of consultation reports and to clarify any issues promptly. Maintain Comprehensive Documentation: JFSSV will maintain comprehensive documentation to support the submission of the single audit (SF-SAC form) and other compliance reports. JFSSV agrees with the delay in completing the FY22 audit. The unforeseen necessity for an additional auditor, which came to light during the initial audit process, significantly impacted JFSSV's timeline. Although this presented an unexpected challenge, JFSSV swiftly engaged a new auditing firm to restart the audit. Additionally, to ensure efficiency and accuracy moving forward, JFSSV made the decision to transfer our outsourcing accounting department. Furthermore, JFSSV is taking proactive measures to streamline its processes for future audits, with the aim of achieving faster turnarounds and compliance with reporting requirements, federal regulations, and guidelines. JFSSV is committed to maintaining and improving its financial and operational controls. We will monitor corrective actions and adjust our procedures as necessary to prevent similar issues in the future.