RELIEF INTERNATIONALNon-Profit

Finding 2021-001 Period of performance compliance finding and significant deficiency in internal control. Federal Agency: United States Department of State Assistance Listing Number: 19.517 Assistance Listing Name: Overseas Refugee Assistance Programs for Africa Award Number: SPRMCO20CA0044 - Award period August 15, 2020 through August 14, 2021; SPRMCO21CA3107 - Award period August 15, 2021 through August 14, 2022. Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition/Context/Questioned Costs The two awards fund ongoing project activities in Mabon County, South Sudan. During 2021, award number SPRMCO20CA0044 had a period of performance that ended on August 14, 2021 and award number SPRMCO21CA3107 had a period of performance that started the following day on August 15, 2021. During our testing of the period of performance compliance requirement, we noted errors in how payroll charges were allocated to the two awards during the month of August 2021. The Organization?s system of internal control did not accommodate allocating the payroll charges for these awards that stopped and started mid-month. We tested a sample of 25 expense transactions posted to the month of August 2021. Of this sample tested we noted one payroll transaction of $977 for award number SPRMCO20CA0044 where the entire month?s payroll was charged to the award. Instead, only half of the month should have been charged and so the grant was overcharged for this payroll transaction. Likewise, we noted nine payroll transactions totaling $15,132 for award number SPRMCO21CA3107 where the entire month?s payroll was charged to the award. Instead, only half of the month should have been charged and so the grant was overcharged for these payroll transactions. Cause The Organization?s system of internal control did not accommodate allocating the payroll charges for these awards that stopped and started mid-month. Effect The two awards had payroll charges in the month of August 2021 where approximately half of the cost should not have been charged to the awards. Repeat Finding This is not a repeat finding. Recommendation We recommend management implement procedures for awards that start or end mid-month to ensure payroll costs are reviewed and adjusted so that only costs that belong to the period of performance are charged to the award. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2020-001 Significant deficiency in internal control over compliance for allowable costs. Federal Agency: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Award Number: 72OFDA18CA00043-RI: Pass-Through from World Vision, Award period October 1, 2018 through November 30, 2020 Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements, Section 200.303, Internal Controls, require that a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context The Organization?s internal controls require review and approval of costs charged to Federal awards by a knowledgeable and authorized individual to ensure that costs are accurately recorded. Of approximately 62 items tested for nonpayroll costs, we noted 1 instance in which the amount charged to the Federal award was incorrect due to input error. As a result of this error, USAID award 72OFDA18CA00043-RI, passed through World Vision, was undercharged by $41.29. Cause The Organization?s internal controls over review of costs charged to a Federal award to ensure accuracy were not consistently implemented. Effect Deficiencies in internal controls related to cost recognition could result in questioned costs under 2 CFR 200.403. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendation We recommend the Organization enforce its policies for review of transactions by knowledgeable and authorized individuals to ensure that costs are accurately recorded. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2020-002 Significant deficiency in internal control over compliance for allowable costs. Federal Agency: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Award Number: 720FDA19GR00249: Award period August 1, 2019 through July 31, 2020 COVID-19 3AFRI01: Pass-Through from International Rescue Committee, Award period June 1, 2020 through November 30, 2020 Federal Agency: United States Department of State Assistance Listing Number: 19.519 Assistance Listing Name: Overseas Refugee Assistance Program for Near East Award Number: S-PRMCO-19-CA-0188: Award period September 1, 2019 through August 31, 2021 Criteria Allowable costs requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E - Cost Principles, Section 200.403(e) requires that costs charged to Federal awards must be determined in accordance with generally accepted accounting principles (U.S. GAAP). Condition/Context The Organization?s internal controls over allowable costs require that costs be recognized in the period in which they are incurred in accordance with U.S. GAAP, and that financial accounts be reconciled in order to charge costs to a Federal award timely. Of approximately 216 items tested for payroll and nonpayroll costs, we noted 3 instances in which costs incurred in 2019 were charged to the Federal award in 2020. The costs related to these 3 instances were incurred within the period of performance of the Federal award; however, the costs were recognized in a period subsequent to the period in which the costs were incurred. The costs totaled $55.35 for USAID award 720FDA19GR00249; $403.28 for USAID award COVID-19 3AFRI01, passed through International Rescue Committee; and $381.36 for Department of State award S-PRMCO-19-CA-0188. Cause The Organization?s internal controls over year-end cut-off in accordance with U.S. GAAP were not consistently implemented. Effect Deficiencies in internal controls related to U.S. GAAP cost recognition could result in questioned costs under 2 CFR 200.403. Questioned Costs None. Repeat Finding This is a repeat of finding 2019-002. Recommendation We recommend the Organization enforce its policies for timely processing of transactions and account reconciliations to comply with U.S. GAAP and the cost principles of 2 CFR 200. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2020-003 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development CFDA Number: 98.001 CFDA Name: USAID Foreign Assistance for Programs Overseas Award Number: 720FDA20CA00041: Award period October 1, 2020 through September 30, 2021 Federal Agency: United States Department of State CFDA Number: 19.519 CFDA Name: Overseas Refugee Assistance Program for Near East Award Number: S-PRMCO-20-CA-0012: Award period January 1, 2020 through December 31, 2020 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 - Reporting Subaward and Executive Compensation Information, prime grant recipients awarded a new Federal grant greater than or equal to $25,000 as of October 1, 2020 are subject to FFATA sub-award reporting requirements. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $25,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization?s internal controls over FFATA reporting included instructions to staff on procedures to set up and file in the FSRS database. Of 2 sub-awards selected for testing, support of FFATA filing was available; however, the data was not timely or accurately reported. See Schedule of Findings and Questioned Costs for chart/table. Cause The Organization?s internal controls over FFATA reporting were not consistently implemented on a timely basis. Effect The Organization did not fully comply with the FFATA subaward reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 - Reporting Subaward and Executive Compensation Information, for new Federal grants greater than or equal to $25,000 as of October 1, 2010, and with the requirements to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $25,000. Questioned Costs None Repeat Finding This is not a repeat of finding. Recommendation We recommend the Organization enforce its policies and control procedures, and provide additional training to staff, to ensure timely and accurate reporting as required in 2 CFR Part 170. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Significant deficiency in internal control over compliance and compliance for procurement. Federal Agency: United States Agency for International Development CFDA Number: 98.001 CFDA Name: USAID Foreign Assistance for Programs Overseas Award Number: 72OFDA18GR00223 award period July 7, 2018 to July 6, 2019 Criteria Procurement requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart D - Post Federal Audit Requirements, Section 200.320 requires that noncompetitive procurements must meet one of four requirements as noted in 200.320 paragraph (f). Condition/Context/Questioned Costs The Organization?s internal controls over noncompetitive procurements charged to a Federal award require adequate justification to support the noncompetitive procurement. Of the 40 procurements tested, we noted 1 instance in which noncompetitive methods were used that did not follow the Organization?s procurement policy. The Organization awarded a contract to an entity with whom the Organization had previously worked. The Organization signed a new contract with this entity without documentation to support the Organization followed its policy for a noncompetitive procurement. The Organization paid the contractor a total of $140,628.80 during the year ended December 31, 2019, which is reported as questioned costs. Cause The Organization?s internal controls over review and approval of procurements for Federal awards were not consistently implemented. Effect The Organization awarded contracts charged to Federal awards that did not comply with the Organization?s policy for noncompetitive procurement under 2 CFR 200.230. Repeat Finding This is a repeat finding of 2018-004. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Significant deficiency in internal control over compliance for allowable costs. Federal Agency: United States Agency for International Development CFDA Number: 98.001 CFDA Name: USAID Foreign Assistance for Programs Overseas Award Numbers: AID-OFDA-A-17-00019: Award period May 19, 2017 to May 15, 2019 72OFDA18GR00298: Award period August 1, 2018 to July 31, 2019 72OFDA18CA00043-RI: Pass-Through from World Vision, Award period December 20, 2018 to September 30, 2020 72OFDA18CA00045: Pass-Through from Solidarity International, Award period October 1, 2018 to September 30, 2020 Criteria Allowable costs requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E - Cost Principles, Section 200.403(e) requires that costs charged to Federal awards must be determined in accordance with generally accepted accounting principles (U.S. GAAP). Condition/Context The Organization?s internal controls over allowable costs require that costs be recognized in the period in which they are incurred in accordance with U.S. GAAP, and that financial accounts be reconciled in order to charge costs to a Federal award timely. Of approximately 170 items tested for payroll and nonpayroll costs, we noted 7 instances in which costs incurred in 2018 were charged to the Federal award in 2019. The costs related to these 7 instances were incurred within the period of performance of the Federal award; however, the costs were recognized in a period subsequent to the period in which the costs were incurred. Cause The Organization?s internal controls over year-end cut-off in accordance with U.S. GAAP were not consistently implemented. Effect Deficiencies in internal controls related to U.S. GAAP cost recognition could result in questioned costs under 2 CFR 200.403. Repeat Finding This is not a repeat finding. Recommendation We recommend the Organization enforce its policies for timely processing of transactions and account reconciliations to comply with U.S. GAAP and the cost principles of 2 CFR 200. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

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