Arizona Immigrant and Refugee Services, Inc.

Program Title: All federal programs Federal Financial Assistance Listing Number: N/A Federal Award Year: 2022, 2023, 2024, and 2025 Federal Agency: All federal agencies Type of Finding: Material Weakness in Internal Control over Compliance Criteria: As required under the Uniform Guidance, the single audit and data collection reporting package must be submitted to the Federal Audit Clearinghouse within 9 months after the end of the audit period. Condition: For the years ended September 30, 2022, 2023, 2024, and 2025, the financial statement audit and single audit were not scheduled or completed in a timely manner. As a result, the single audit and data collection reporting package for these years were not completed or submitted to the Federal Audit Clearinghouse within the required timeframe. Cause: The FY2023 audit was not completed and issued until October 2025, which delayed commencement of the FY2024 audit until August 2026. Effect: The financial statements and single audit for FY2024 were not completed in a timely manner, and AIRS remains out of compliance with the required submission timing under the Uniform Guidance. Questioned Costs: None reported Repeat Finding from Prior Year: Yes (Finding 2023-004, repeat of 2022-004) Recommendation: AIRS should continue working with the audit firm on a schedule that brings future audits and single audits current and ensures the data collection reporting package is submitted to the Federal Audit Clearinghouse by the due date for FY2025 and future years. Views of Responsible Officials: Management concurs with this audit finding Corrective Action Plan: See corrective action plan

Program Title: All federal programs Federal Financial Assistance Listing Number: N/A Federal Award Year: 2024 Federal Agency: All federal agencies Type of Finding: Material Weakness in Internal Control over Compliance Criteria: A non-federal entity is required to have written procurement policies and procedures in compliance with the Uniform Guidance (2 CFR 200.318 through 200.327), and, if it has a parent, affiliate, or subsidiary organization, written standards of conduct covering organizational conflicts of interest. Condition: AIRS has not completed written purchasing/procurement policies and procedures as required by 2 CFR 200.318(a) as of September 30, 2024. As an affiliate of the Ethiopian Community Development Council (ECDC), AIRS continues to meet the “affiliate” definition under 2 CFR 200.318(c)(2). Cause: Management has not yet fully created certain written policies and procedures as required under 2 CFR 200.318. Effect: AIRS is not in compliance with the written policies and procedures requirements of 2 CFR 200.318. Questioned Costs: None reported Repeat Finding from Prior Year: Yes (Finding 2023-005, repeat of 2022-005) Recommendation: AIRS should complete its written procurement policies and procedures and standards of conduct covering organizational conflicts of interest as soon as possible, ideally prior to the start of the FY2025 audit. Views of Responsible Officials: Management concurs with this audit finding Corrective Action Plan: See corrective action plan

Program Title: Refugee and Entrant Assistance State Administered Programs — Afghan Supplemental Services (Contract No. CTR061924) Federal Financial Assistance Listing Number: 93.566 Federal Award Year: 2024 Federal Agency: U.S. Department of Health and Human Services, passed through the Arizona Department of Economic Security Type of Finding: Material Weakness in Internal Control over Compliance / Scope Limitation resulting in Disclaimer of Opinion Criteria: Compliance requirements identified as direct and material to Contract No. CTR061924 under ALN 93.566 include Activities Allowed or Unallowed (A), Allowable Costs/Cost Principles (B), Cash Management (C), Eligibility (E), Period of Performance (H), and Reporting (L), per the 2025 OMB Compliance Supplement, Part 4, ALN 93.566. Condition: Of these six requirements, only the administrative-claim component of Allowable Costs (B) was substantively tested, using AIRS’s own accounting records. The remaining five requirements could not be tested because the evidence needed — ARRPODS-based unit/task activity records and client A-number eligibility data — was inaccessible. The Arizona Department of Economic Security (ADES) confirmed in writing (correspondence dated September 10, 2026) that this data is currently unavailable due to a stateside data conversion, a condition compounded by the inactive status of Contract No. CTR061924 for FY2024 and FY2025. Cause: This is an inherent scope limitation arising from circumstances beyond the control of both AIRS and the engagement team, rather than a restriction imposed by management, consistent with AU-C §705.13. AIRS does not maintain source documentation independent of ADES’s ARRPODS system sufficient to support billed units under CTR061924 in the event ARRPODS is unavailable. Effect: The engagement team was unable to obtain sufficient appropriate audit evidence regarding compliance with five of six direct-and-material requirements for a contract representing approximately 79% of the dollar volume and 64% of the invoices tested within ALN 93.566. Because AIRS invoices ADES across all four ALN 93.566 contracts on a combined, purpose-code basis, this evidence gap could not be isolated to a separable population of transactions and is pervasive to the program as a whole, resulting in a disclaimer of opinion on compliance for ALN 93.566. Because CTR061924 revenue is recognized on the same unit-earned basis for financial reporting purposes, the same evidence gap also contributed to the qualified opinion on the basic financial statements taken as a whole (see the Independent Auditor’s Report).Questioned Costs: Undeterminable due to the scope limitation. An estimated $600,000–$650,000 of ALN 93.566 revenue and the related receivable could not be substantiated (applying the approximate 79% sample proportion to total program revenue of approximately $800,000 on a pre-adjustment, cash basis). Following the GAAP accrual-basis correction described in Finding 2024-002, total ALN 93.566 program revenue increased to $1,122,212, as reflected in the Schedule of Expenditures of Federal Awards; the $600,000–$650,000 estimate reflects the pre-adjustment base and was not recalculated on the adjusted amount. This amount is not characterized as a questioned cost in the 2 CFR 200.516 sense because it reflects an inability to test, rather than an identified instance of noncompliance or unallowable cost. Repeat Finding from Prior Year: No — new condition for FY2024. (ALN 93.566 received an unmodified compliance opinion in FY2023; the qualified opinion issued for FY2023 pertained to the separate ALN 93.567 program’s matching requirement, Finding 2023-006.) Recommendation: AIRS should coordinate with ADES on restoring ARRPODS access and evaluate whether independently maintained case-management task logs or client files could substitute for ARRPODS extracts in future periods, so that a similar scope limitation does not recur for FY2025. Views of Responsible Officials: Management concurs with this audit finding Corrective Action Plan: See corrective action plan

Criteria: As required under the Uniform Guidance, the single audit and data collection reporting package are required to be submitted to the Federal Audit Clearinghouse within 9 months after the end of the audit period. Condition: For the years ended September 30, 2022, September 30, 2023, and September 30, 2024 the financial statement audit and single audit were not scheduled or completed in a timely manner. As a result, the single audit and data collection reporting package were not completed or submitted to Federal Audit Clearinghouse in accordance with the requirements for Reporting under the Uniform Guidance.Cause: The commencement of the 2022 and 2023 audit of the Organization was delayed primarily due to budgetary constraints, difficulty in identifying and engaging an audit firm capable of completing the single audit and due to the fact that the 2021 audit and 2022 audit were required to be completed before the 2023 audit could commence. The audit for 2023 was not completed and issued until November 20, 2024, As a result, the audit firm was not engaged until December 19, 2024 to complete the financial statement and single audit for the year ended September 30, 2023. The Organization was not fully prepared for the audit until mid-April 2024, and due to other previously scheduled client engagements and other scheduling difficulties, the audit firm was unable to fully complete work on the 2023 audit until October 2025. Effect: The financial statements and single audit were not completed in a timely manner and AIRS is not in compliance with the required timing of submission of the single audit and data collection package to the Federal Audit Clearinghouse as required under the Uniform Guidance for years ended September 30, 2023 and September 30, 2024. Questioned Costs: None reported Repeat Finding from Prior Year: Yes. Recommendation: AIRS should improve its financial reporting process and procedures to ensure that it completes financial statement and single audits in a timely and efficient manner and ensure that its financial statements, single audit and data collection package are completed and properly submitted to the Federal Audit Clearinghouse within the required 9 months after fiscal year end as required by the Uniform Guidance.

Criteria: A non-federal entity is required to have certain written policies and procedure in compliance with Uniform Guidance and must comply with the procurement standards as described in 2 CFR 200.318 through 2 CFR 200.327. Condition: AIRS does not appear to have created written purchasing or procurement policies and procedures as required by 2 CFR 200.318(a). Since AIRS is an affiliate organization of the Ethiopian Community Development Council (ECDC), it appears that the relationship between AIRS and ECDC meets the “affiliate” requirement under 2 CFR 200.318 (c) (2). It does appear that AIRS has created written standards of conduct covering organizational conflicts of interest. Cause: Management has not created or maintained certain written policies and procedures as required under 2 CFR 200.318. Effect: AIRS is not in compliance with certain written policies and procedures as required under 2 CFR 200.318. Questioned Costs: None reported. Repeat Finding from Prior Year: Yes. Recommendation: In response to Finding 2021-006 during the audit for the year ended September 30, 2021, management has started the process of creating, updating and revising its written policies and procedures. I commend management for their efforts. However, I strongly recommend that management and board complete the written procurement policies and procedures and written standards of conduct covering organizational conflicts of interest prior to start of the 2024 audit. Views of Responsible Officials: Management concurs with this audit finding.

Federal Financial Assistance Listing Number: 93.567. Questioned costs: $895,814. Criteria: The federal program requirements for the Refugee and Entrant Assistance Voluntary Agency Programs (FFA Listing No. 93.567) and the subaward agreement with the Ethiopian Community Development Council, Inc. (ECDC) requires a match of $1 of value through non-federal cash, in-kind donations and volunteer time for each $2 of grant award received (50% match). Condition: AIRS does not appear received sufficient non-federal cash, in-kind donations and volunteer time to satisfy the matching requirement for the year ended September 30, 2023. AIRS submitted repotting to ECDC documenting a total match amount received during the year ended September 30, 2023 of $217,048. However, the total award received and expended during 2023 was $895,814. Thus, the required match amount for year ended September 30, 2023 is $447,907. In addition, certain amounts included in the $217,048 match amount reported to ECDC, of approximately $135,000, did not appear to be properly supported or valued. Finally, AIRS also failed to properly record certain of the in-kind matching amounts to its financial statements during the year ended September 30, 2024 (See Finding 2023-002). Cause: AIRS did not receive or record sufficient matching amounts in order to satisfy the matching requirements of the federal award program. Effect: AIRS is not in compliance with the matching compliance requirement for the federal award. Questioned Costs: $895,814. Repeat Finding from Prior Year: No. Recommendation: I strongly recommend that management engage in discussions with both program oversight personnel at ECDC and at the US Department of Health and Human Services to determine any further actions required related to this federal program award. Views of Responsible Officials: Management concurs with this audit finding.