The Unaccompanied Alien Children ProgramThe UAC Program funds temporary shelter care and other related services for children in ORR custody. For project periods with services beginning during FYs 2014 and 2015, ORR awarded grants totaling $2.1 billion to providers for the care and placement of children. The UAC Program is separate from State-run child welfare and traditional foster care systems. Applicable Federal RequirementsFederal regulations establish uniform administrative requirements for awards to nonprofit organizations. For grant awards made on or after December 26, 2014, 45 CFR part 75 establishes uniform administrative requirements, cost principles, and audit requirements for Federal awards to non-Federal entities. Southwest Key had three cooperative agreements—90ZU0148, 90ZU0149, and 90ZU0153—that were in effect from October 1, 2014, through September 30, 2017. However, our audit period included awards made after December 26, 2014, to which Part 75 applied. Southwest Key Programs Southwest Key is a nonprofit organization based in Austin, Texas. For nearly 20 years, Southwest Key has participated in the UAC Program. In FY 2016, Southwest Key was awarded approximately $236 million in grants for residential services for children in the UAC Program and claimed approximately $231 million in Federal funds to care for children in its custody, which included approximately 25,000 children who were released directly to parents, family members, or other adults who are able to provide for their care; aged out of the program; ran away; or transferred to another facility. During FY 2016 Southwest Key operated a total of 26 residential shelter programs in Arizona (8), California (3), and Texas (15).
Open Recommendations
| Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
|---|---|---|---|---|---|
| 269423 | No | $0 | $0 | ||
| We recommend that Southwest Key Programs implement procedures to review leases and ensure that any ancillary costs claimed comply with Federal regulations. | |||||
| 269424 | No | $0 | $0 | ||
| We recommend that Southwest Key Programs maintain supporting documentation that shows employees who receive a bonus qualify for the bonus and that bonuses paid comply with Southwest Key’s bonus policy and Federal regulations. | |||||
| 269425 | No | $0 | $0 | ||
| We recommend that Southwest Key Programs revise the bonus policy to establish a maximum percentage when calculating bonuses paid with Federal funds and to ensure that all bonuses are reasonable. | |||||
| 269426 | No | $0 | $0 | ||
| We recommend that Southwest Key Programs ensure that no Federal funding, direct or indirect, is used for future compensation that exceeds the statutorily allowed rate for executive compensation. | |||||
| 269427 | No | $0 | $0 | ||
| We recommend that Southwest Key Programs develop a quality control procedure to ensure that costs claimed are accurate, adequately supported, and benefit the award. | |||||
| 269428 | No | $0 | $0 | ||
| We recommend that Southwest Key Programs maintain documentation to support the FFRs. | |||||
| 269430 | No | $0 | $0 | ||
| We recommend that the Office of Refugee Resettlement review Southwest Key’s remaining UAC facility leases to determine whether they qualify as capital leases, and recover any unallowable costs. | |||||
| 269431 | No | $0 | $0 | ||
| We recommend that the Office of Refugee Resettlement review the capital leases identified in our audit to determine the amount of unallowable costs associated with the leases since their inception and after our review, and recover any unallowable costs. | |||||
| 269432 | No | $0 | $0 | ||
| We recommend that the Office of Refugee Resettlement review UAC facility leases since their inception and after our review to ensure the leases meet Federal requirements and include only allowable costs, and recover any unallowable costs. | |||||
| 269433 | No | $0 | $0 | ||
| We recommend that the Office of Refugee Resettlement ensure that Southwest Key adheres to the statutorily allowed rate for executive compensation. | |||||
| 269434 | No | $0 | $0 | ||
| We recommend that the Office of Refugee Resettlement review Southwest Key’s bonus policy to ensure that it meets Federal requirements. | |||||
| 269436 | No | $0 | $0 | ||
| We recommend that the Office of Refugee Resettlement provide guidance to Southwest Key related to allowable renovation costs and when prior approval for renovations is required. | |||||
