INTERFAITH MINISTRIES FOR GREATER HOUSTON

Finding #2025-001 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Assistance Listing #14.218, Passed through Harris County, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Grants Cluster, Contract #’s: C2023-006G, C2024-006H, and C2020-050G, Contract years: 10/23-09/24, 10/24-09/25, and 03/24-09/24. Assistance Listing #14.218, Passed through City of Houston, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Grants Cluster, Contract #: 4600016648, Contract year: 05/25-06/25. U. S. Department of Health and Human Services, Assistance Listing #93.576, Passed through Episcopal Migration Ministries, Refugee and Entrant Assistance Discretionary Grants, Contract #’s: 90RP0117‐01-00, 90RP0117-02-00, 90RP0117-03-00, and 90RP0117-04-00, Contract years: 10/23-09/24 and 10/24-09/25. Applicable state program: Texas Department of Agriculture, Home-Delivered Meal Grant Program, Contract #’s: HDM2024029-070-071 and HDM2025052-053, Contract years: 02/24-01/25 and 02/25-01/26. Criteria: Procurement – Nonprofit organizations are required to adopt policies in accordance with the Uniform Guidance §200.318 and the Texas Grant Management Standards. Additionally, nonprofit organizations must maintain records sufficient to detail the history of procurement including the rationale for the procurement method, vendor selection or rejection, and the basis for the contracted price. Condition and context: During our testing of 24 expenditures requiring procurement, we identified one instance of expenditures in Home-Delivered Meal Grant Program greater than the simplified acquisition threshold of $10,000 where simplified acquisition procedures in accordance with Interfaith Ministries’ policy were not followed. Cause: The finding occurred due to failure to follow established procurement policies and procedures. Effect: Failure to follow procurement procedures may result in Interfaith Ministries purchasing goods or services for more than would be necessary if required procurement procedures had been followed. Recommendation: Emphasize adherence to established policies and procedures to ensure procurement is performed according to the procurement policy, and that proper procurement documentation is maintained. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.566, Passed through Texas Office for Refugees, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Contract #’s: FFY2024-27947V-CMA and FFY2025-27947V-CMA, Contract years: 10/23-09/24 and 10/24-09/25. Criteria: Allowable Costs – Interfaith Ministries is responsible for having internal control procedures to ensure the completeness of required documents in the client files. Condition and context: Interfaith Ministries’ policies and procedures for verifying the completeness of documentation includes ensuring the acknowledgement of receipt of a debit card by the client is maintained in the client file. In a sample of 33 client files tested for refugee cash assistance program, we noted one client who received a debit card in February 2025 did not have the acknowledgement receipt in the client file. Cause: The finding occurred as a result of Interfaith Ministries not following its internal control procedures to ensure that client files are complete including the client acknowledgement of receipt of a debit card. Effect: Failure to follow internal control procedures could result in incomplete client files, and noncompliance with procedures required by the Texas Office for Refugees (TXOR). Recommendation: Emphasize adherence to established policies and procedures to ensure acknowledgement of receipt of a debit card by the client is maintained in the client file. Views of responsible officials and planned corrective action: Management agrees with the finding. See Corrective Action Plan.

Finding #2023-001 – Significant Deficiency and Other Noncompliance. Applicable Federal Program: Department of the Treasury, Passed through Texas Department of Agriculture, COVID-19 – Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing #: 21.027, Contract #: HDM2022007-129-131, Contract year: 02/22-01/23. Applicable State Program: Texas Department of Agriculture, Home-Delivered Meal Grant Program, Contract #’s: HDM2022007-129-131 and HDM2023062-098-099, Contract years: 02/22-01/23 and 02/23-01/24. Criteria: Eligibility – The Texas Administrative Code – Home-Delivered Meal Grant Program, Title 4 Agriculture, Part 1 Department of Agriculture, Chapter 1 General Procedures, Subchapter O Home-Delivered Meal Grant Program, Rule §1.959 Eligibility of Persons Served, requires that each Grantee using grant for the preparation or delivery of a Home-delivered meal must document that persons receiving a meal funded are Homebound Elderly persons or Homebound persons with a Disability as defined in §1.951. Additionally, Rule §1.961 Recordkeeping and Record Retention, requires (a) Grantees to maintain documentation as required by the Department to verify that individuals who receive meals paid for or delivered in part with grant funds received qualify as a Homebound Elderly person or Homebound person with a Disability. Interfaith Ministries’ policies and procedures require an annual re-assessment of the continued eligibility of participants served meals funded under the Home-Delivered Meal Grant Program. If an annual re-assessment has not been performed, the meals provided to the participant should be funded by other funders. Condition and context: During our testing of 60 participants for proper eligibility, we noted 2 participants were not re-assessed for eligibility by their annual anniversary and continued to receive meals funded under the Home-Delivered Meal Grant Program. Cause: Interfaith Ministries’ staff did not follow policies and procedures to change the funding source until the annual re-assessment could be performed. Effect: The two participants continued to receive approximately 79 meals funded by the Home-Delivered Meal Grant Program after the expiration of the annual eligibility date. Recommendation: Provide additional training to personnel responsible for determining eligibility for monitoring the annual reassessment and changing the funder until the reassessment can be performed. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See Corrective Action Plan.