Open Recommendations

We recommend that Essence identify, for the diagnoses included in this report, instances of noncompliance in the enrollee-years that occurred (1) during our audit period, but were not included in our judgmental sample, and (2) before and after our audit period, and refund any resulting overpayments to the Federal Government.

Determine the allowability of $518,700 in questioned costs ($27,047
ineligible and $491,653 unsupported) identified on page 25, and further detailed on pages 26-27 of the audit report, and recover any amount that is unallowable.

We recommend that Children’s Village review its claimed expenditures for FYs 2016 and 2017 (the second and third years of the grant awards) to determine whether they were claimed in accordance with Federal requirements and refund to the Federal Government any unallowable amount.

We recommend that Children’s Village determine whether resources are aligned as needed to ensure that all required documentation is maintained in UAC case files and that ORR policies and procedures are followed when releasing UAC to sponsors.

We recommend that Children’s Village take corrective action to ensure that its facility is free from potentially harmful conditions.

We recommend that Children’s Village refund to the Federal Government $2,623,785 in unallowable grant expenditures.

We recommend that Children’s Village implement financial management system procedures to ensure Federal funds are drawn down only when needed, all related obligations are paid timely, and grant funds are separately identified and segregated.

We recommend that Children’s Village ensure that all medical exams and educational assessments are documented and performed as required by ORR.

We recommend that Children’s Village ensure that costs are properly approved, allocated, and adequately supported.

We recommend that Children’s Village ensure that all employee requirements pertaining to background investigations and experience are met and documented.

Support that $3,136,798 in HOME funds disbursed was reasonable and supported in accordance with Federal requirements or repay from non-Federal funds any amount that cannot be supported.

Support that the City properly administered the HOME program and earned $130,667 in HOME administrative fees or repay from non-Federal funds any amount that cannot be supported

Reallocate the $487,483 in unspent funds to ensure that they will be put to their intended use or, if the activities remain open, maintain support to show that the HOME funds disbursed were reasonable and Reallocate the $487,483 in unspent funds to ensure that they will be put to their intended use or, if the activities remain open, maintain support to show that the HOME funds disbursed were reasonable and supported in accordance with Federal requirements.

Identify, review, and approve a CHDO to work with the City to ensure that $254,215 in CHDO funds will be properly committed to avoid being deobligated.

Establish underwriting policies and procedures to ensure that HOME activities are consistent and meet Federal requirements.

Develop and implement adequate environmental policies and procedures to ensure that environmental reviews are properly documented and supported and that HUD and Federal environmental requirements have been followed before committing HOME funds to an activity.

Develop and implement adequate policies and procedures to ensure that fixed HOME units are identified and adequate documentation is maintained to support tenant eligibility and compliance with HOME rental limits for the entire affordability period.

Develop and implement tools to improve record-keeping practices to support the eligibility, necessity, and reasonableness of the HOME activities.

Provide technical assistance to the City to ensure that responsible staff receives necessary environmental, underwriting, and overall program administration training.

We recommend that the Office of the Director ensure that the CIO has adequate involvement and approval in all phases of annual and multi-year planning, programming, budgeting, and execution decisions in line with FITARA and OMB Circular A-130 requirements.

We recommend the Bureau of Fiscal Operations develop or update, and implement comprehensive written policies and step by step procedures for all write-off and waiver processes, to include day to day operations, documentation and approvals, roles and responsibilities, and threshold requirements, to ensure consistency and compliance with applicable laws, regulations, and guidance.

We recommend the Bureau of Fiscal Operations develop and implement controls to ensure debt balances that can be collected are not forfeited due to automatic $25 write-off or $100 waiver thresholds.

We recommend the Bureau of Fiscal Operations conduct training on new policies and procedures to ensure that decision making is consistent.

We recommend the Bureau of Fiscal Operations update Management Control Review documentation to reflect the new policies and procedures and changes in write-off and waiver processing which resulted from the migration to Financial Management Integrated System.

Embassy Bogota should remove the KACTUS database from the dedicated internet network and conduct a risk assessment based on the National Institute of Standards and Technology’s Risk Management Framework.