Catholic Charities of the Texas Panhandle, Inc.

Finding 2023-001 - Eligibility Requirements for Refugee and Entrant Assistance, Federal Assistance Listing Number 93.566 for 2023 issued by the US Department of Health and Human Services (Repeat)

Criteria: Per the Texas Refugee Program, Eligibility requires certain documentation requirements by the Organization.

Condition and Context: Of the 112 files reviewed, 7 did not contain all required documentation for Eligibility including sufficient Eligibility documents, Right and Responsibilities in the client’s language, Confidentiality Policy, consent for release of information, barrier removal efforts, dates and services provided, referrals, interpretation services provided, intake/enrollment documents, Self-Sufficiency Plan and Employment Services Plan. Of the 112 files reviewed, 28 files also did not have documentation of internal control over Eligibility, relating to no evidence of an independent review and approval of the required documentation prior to release of funds to recipient clients.

Cause: During the year the Organization’s executive management implemented tools and resources they believed necessary to meet all refugee program requirements including Eligibility; however, grant supervisors did not always properly monitor and document their review of the gathering and maintaining of all necessary Eligibility documentation and other related requirements noted in the Condition above. Organization executive management also cites a tremendous increase in refugee caseload during its most recent fiscal year along with continued turnover in the Organization’s refugee programs, which added conditions also added to this repeat audit finding from the prior fiscal year. Coupled with these factors, it was further noted the Organization had improvement from the prior year both in a reduced number of files missing Eligibility compliance documentation and a reduced number of files missing properly documented and operating internal control over compliance for Eligibility.

Effect or Potential Effect: During the fiscal year ended June 30, 2023, the Organization served over 1,490 individuals and families for which 7 out of 112 files selected by us did not include all Eligibility documentation requirements and other requirements noted above and 28 of the 112 files selected also did not include sufficient documentation of internal control over Eligibility.

Recommendation: We noted improvement from the prior year both in a reduced number of files missing Eligibility compliance documentation and a reduced number of files missing properly documented and operating internal control over compliance for Eligibility. We noted improvement attributed to the Organization’s executive management implementing tools and resources they believed necessary to meet all refugee program requirements including Eligibility. We recommend that staff continue to receive regular, ongoing training on required Eligibility documentation for all federal programs and that Eligibility checklists and other related requirements noted above are reviewed, approved and signed by a supervisor prior to the release of funds to recipient clients to ensure internal control over Eligibility compliance is maintained. We recommend the Organization complete regular and ongoing internal reviews over compliance requirements and internal controls over compliance requirements.

Management’s Response: The Organization will require regular ongoing training for all federal programs. All files will be reviewed by a supervisor to ensure Eligibility checklists have been used and completed, and that all required Eligibility documentation and other requirements noted above are contained in the files. The Organization has hired an employee who is responsible for reviewing compliance with federal grants and will report directly to executive management of the Organization on any identified exceptions, including omissions of Eligibility documents and lack of properly operating internal controls over compliance.