Department of Health and Human Services 
OFFICE OF INSPECTOR GENERAL 

OFFICE OF REFUGEE RESETTLEMENT 
UNACCOMPANIED ALIEN CHILDREN 
GRANTEE REVIEW—HIS HOUSE 
Inquiries about this report may be addressed to the Office of Public Affairs at 
Public.Affairs@oig.hhs.gov. 
Gloria L. Jarmon Deputy Inspector General for Audit Services 
December 2017 A-04-16-03566 
 

 Office of Inspector General https://oig.hhs.gov 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as amended, is 
to protect the integrity of the Department of Health and Human Services (HHS) programs, as well as the 
health and welfare of beneficiaries served by those programs. This statutory mission is carried out through 
a nationwide network of audits, investigations, and inspections conducted by the following operating 
components: 

Office of Audit Services 
The Office of Audit Services (OAS) provides auditing services for HHS, either by conducting audits with 
its own audit resources or by overseeing audit work done by others. Audits examine the performance of 
HHS programs and/or its grantees and contractors in carrying out their respective responsibilities and are 
intended to provide independent assessments of HHS programs and operations. These assessments help 
reduce waste, abuse, and mismanagement and promote economy and efficiency throughout HHS. 

Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide HHS, Congress, 
and the public with timely, useful, and reliable information on significant issues. These evaluations focus 
on preventing fraud, waste, or abuse and promoting economy, efficiency, and effectiveness of 
departmental programs. To promote impact, OEI reports also present practical recommendations for 
improving program operations. 

Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations of fraud and 
misconduct related to HHS programs, operations, and beneficiaries. With investigators working in all 50 
States and the District of Columbia, OI utilizes its resources by actively coordinating with the Department 
of Justice and other Federal, State, and local law enforcement authorities. The investigative efforts of OI 
often lead to criminal convictions, administrative sanctions, and/or civil monetary penalties. 

Office of Counsel to the Inspector General 
The Office of Counsel to the Inspector General (OCIG) provides general legal services to OIG, rendering 
advice and opinions on HHS programs and operations and providing all legal support for OIG’s internal 
operations. OCIG represents OIG in all civil and administrative fraud and abuse cases involving HHS 
programs, including False Claims Act, program exclusion, and civil monetary penalty cases. In 
connection with these cases, OCIG also negotiates and monitors corporate integrity agreements. OCIG 
renders advisory opinions, issues compliance program guidance, publishes fraud alerts, and provides 
other guidance to the health care industry concerning the anti-kickback statute and other OIG enforcement 
authorities. 
 

 Notices 
THIS REPORT IS AVAILABLE TO THE PUBLIC 
at https://oig.hhs.gov 
Section 8M of the Inspector General Act, 5 U.S.C. App., requires that OIG post its publicly 
available reports on the OIG website. 

OFFICE OF AUDIT SERVICES FINDINGS AND OPINIONS 
The designation of financial or management practices as questionable, a recommendation for the 
disallowance of costs incurred or claimed, and any other conclusions and recommendations in 
this report represent the findings and opinions of OAS. Authorized officials of the HHS 
operating divisions will make final determination on these matters. 
 

 Report in Brief Date: December 2017 Report No. A-04-16-03566 
Why OIG Did This Review The Unaccompanied Alien Children (UAC) program served between 7,000 
and 8,000 children annually from fiscal year (FY) 2005 through FY 2011. In FY 2012, the number of 
children in the program began to increase. By the end of FY 2012, the UAC program, under the 
Department of Health and Human Services, Office of Refugee Resettlement (ORR), served approximately 
13,625 children. In FY 2014, referred to as the “surge” year, ORR served 57,496 children. 
Funding for the program also increased. From FY 2009 through FY 2014, funding for the UAC program 
totaled more than $2 billion, an increase of $707 million during this same period. 
We selected for audit His House Children’s Home, Inc. (His House), a UAC grantee responsible for 
caring for children in ORR custody, because a former employee was convicted of extortion, and we were 
interested in assessing whether there were other vulnerabilities. 
Our objectives were to determine whether His House (1) met applicable safety standards for the care and 
release of children in its custody and (2) claimed only allowable expenditures in accordance with 
applicable laws, regulations, and departmental guidance. 
How OIG Did This Review Our review covered October 1, 2013, through September 30, 2014. We 
reviewed UAC case files, personnel records, financial transactions, and policies and procedures. Also, we 
inspected shelter care cottages. 

Office of Refugee Resettlement Unaccompanied Alien Children 
Grantee Review—His House 
What OIG Found Generally, His House met safety standards for the care and release of children in its 
custody. However, some UAC case files were missing evidence of sponsor background checks and other 
required documentation. 
His House claimed only allowable expenditures. However, we identified areas in which His House lacked 
an efficient and effective system of internal controls when administering UAC program funds. 
As a result, His House (1) might not have followed ORR policies for 652 children regarding sponsor 
background checks, prompt medical care, provision of appropriate clothing, sponsor placement decisions, 
post-release services, or the notification of the Department of Homeland Security of the child’s release to 
a sponsor and (2) might have placed Federal funds totaling $9 million at risk of mismanagement or 
misappropriation. 
What OIG Recommends and His House Comments We recommend that His House (1) develop a policy 
for maintaining UAC case file documentation that would ensure ORR policies and procedures were 
followed when releasing a child to a sponsor, (2) increase oversight of its reviewing process for UAC case 
files to ensure that all required documentation is maintained in the file, and (3) implement a financial 
management system that requires adequate identification of the source and application of Federal funds 
and effective accountability of property and other assets. We also made procedural recommendations 
aimed at addressing internal control deficiencies we identified. 
His House did not agree with the OIG’s findings; however, it concurred with our recommendations and 
described steps that it had taken or planned to take to address our findings and recommendations. 

 The full report can be found at 

TABLE OF CONTENTS 
INTRODUCTION.............................................................................................................................
1 
WHY WE DID THIS REVIEW ...............................................................................................1 
OBJECTIVES .......................................................................................................................1 
BACKGROUND...................................................................................................................2  Care 
Process..........................................................................................................3  Family  Reunification 
Process 
................................................................................3 
His 
House 
..............................................................................................................4 
HOW WE CONDUCTED THIS REVIEW................................................................................5 
FINDINGS...........................................................................................................................5 
Some Documents Were Missing From His House Case Files............................................6 
Some Case Files Lacked Evidence of Background Investigations 
on Sponsors.......................................................................................................6 Some Case 
Files Had Other Documentation Errors..............................................7 
Although Transactions Were Allowable, His House Had Deficiencies 
Within Its Financial Management and Property Control Systems................................8 
His House Lacked Documentation and a Methodology for Payment 
Management System Drawdowns ....................................................................8 His House’s 
Financial Accounting System Was Not Able To Specifically 
Identify Expenditures for Its Shelter Care Cooperative Agreement .................9 His House Had 
Inadequate and Improperly Implemented Segregation 
of Duties ............................................................................................................9 His House Had 
Inaccurate and Delayed Recording of Accounting 
Transactions ....................................................................................................10 His House Had 
Inadequate Physical Control Over Vulnerable Assets................10 
RECOMMENDATIONS 
.................................................................................................................11 
HIS HOUSE COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE...............................11 
APPENDICES 
A: Audit Scope and Methodology...................................................................................13 

 B: Office of Refugee Resettlement Requirements..........................................................15 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 
 

 C: Selected Requirements for Office of Refugee Resettlement Provider Care 
Facilities During Our Audit Period ..........................................................................20 
D: Statistical Sampling Methodologies ...........................................................................22 
E: Sample Results and Estimates—UAC Case Files .........................................................25 
F: Definitions ...................................................................................................................26 
G: His House Comments .................................................................................................28 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 
 

 INTRODUCTION 
WHY WE DID THIS REVIEW 
The Office of Refugee Resettlement (ORR) within the Department of Health and Human 
Services’ (HHS) Administration for Children and Families (ACF) manages the Unaccompanied 
Alien Children (UAC) program. The UAC program served between 7,000 and 8,000 children 
annually from fiscal year (FY) 2005 through FY 2011. In FY 2012, however, the number of 
children entering the program began to increase, and by the end of FY 2012, the UAC program 
served approximately 13,625 children. In FY 2013, the program served 24,668 children, and in 
FY 2014, referred to as the “surge” year, ORR served 57,496 children. 
As the number of children increased, so did the funding for the program. From FY 2009 through 
FY 2014, ORR’s funding for its UAC program totaled more than $2 billion, with about $912 
million (44 percent) of the funding occurring during FY 2014 alone (Figure 1). 
Figure 1: UAC Program Funding FY2009–FY2014 
1B 
912M 
900M 
800M 
700M 

s r a l l o D 
600M 
500M 
400M 
376M 
300M 
205M 
267M 
200M 
149M 149M 
100M 
0 
FY2009 FY2010 FY2011 FY2012 FY2013 FY2014 Fiscal Year 

Because of the rapid increase of vulnerable children entering ORR care, the significant increases 
in program funding, and the multiple changes to ORR policies during FY 2014, we are 
conducting a series of reviews of ORR care providers across the Nation. We selected His House 
Children’s Home, Inc. (His House), as the first ORR care provider for review because a former 
employee was convicted of extortion, and this led us to believe that vulnerabilities may exist. 

 OBJECTIVES 
The objectives of this review were to determine whether His House (1) met applicable safety 
standards for the care and release of children in its custody and (2) claimed only allowable 
expenditures in accordance with applicable laws, regulations, and departmental guidance. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 1 
 

 BACKGROUND 
Within HHS, ORR manages the UAC program. The UAC program funds temporary shelter 
care1 and other related services for unaccompanied children in ORR custody. In FY 2014, ORR 
awarded grants totaling $1.1 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. 
By law, HHS must provide for the custody and care of a UAC, defined as a child who has no 
lawful immigration status in the United States; has not attained 18 years of age; and, with respect 
to whom there is no parent or legal guardian in the United States, or no parent or legal guardian 
in the United States available to provide care and physical custody (6 U.S.C. § 279(g)(2)). The 
Flores Settlement Agreement established a nationwide policy for the detention, treatment, and 
release of UAC and recognized the particular vulnerability of UAC while detained without a 
parent or legal guardian present (Flores v. Meese—Stipulated Settlement Agreement (U.S. 
District Court, Central District of California, 1997) (Flores Settlement Agreement)). 
Under the Homeland Security Act of 2002, Congress transferred the care and custody of UACs 
to HHS from the former Immigration and Naturalization Service to move toward a child- 
welfare-based model of care and away from the adult detention model. In the Trafficking 
Victims Protection Reauthorization Act of 2008, which expanded and redefined HHS’s statutory 
responsibilities, Congress directed that each child must “be promptly placed in the least 
restrictive setting that is in the best interest of the child” (8 U.S.C. § 1232(b)(2)). 
During our audit period (FY 2014), ORR looked to the 2006 Draft Division of Unaccompanied 
Children’s Services Policies and Procedures Manual (P&P Manual) for applicable policies and 
procedures.2 Additionally, ORR used the ORR UAC Program Operations Manual, which was 
originally issued in April 2012 and updated in December 2012 (Ops Manual 2012), November 
2013 (Ops Manual 2013), and April 2014 (Ops Manual 2014). The Ops Manuals covered only 
certain areas of program management; where there was no Ops Manual guidance, ORR referred 
to the P&P Manual. ORR made changes to both the P&P Manual and the Ops Manual on an ad 
hoc basis. The P&P Manual and the Ops Manuals together constitute the policies and procedures 
in effect during our audit period (October 2013 through September 2014). In this report, we cite 
the provisions in effect during the audit period. The content of the provisions and applicable 
dates are included in Appendix B. 
Subsequent to our audit period, ORR issued the ORR Guide: Children Entering the United States 
Unaccompanied (Policy Guide), effective January 2015, and the ORR UAC Program Operations 
Manual (Operations Manual), effective September 2015, to replace the previous draft versions. 
ORR updates these documents on an ad hoc basis and records the most recent effective date next 
to each policy provision. 
1 Shelter Care is a residential care provider facility in which all of the programmatic components are administered 
onsite in the least restrictive environment. The goal of shelter care is to provide the least restrictive setting that is in 

 the best interests of the child, taking into consideration potential flight risk and danger to the child and others. 
2 Although the P&P Manual was marked “[D]raft,” it included policies and procedures that should be followed. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 2 
 

 45 CFR part 74 establishes uniform administrative requirements for awards to nonprofit 
organizations.3 
Care Process 
ORR funds care providers through cooperative agreements to provide temporary housing and 
other services to children in ORR custody at State-licensed facilities. These facilities must meet 
ORR requirements to ensure a high-level quality of care. 
Federal Field Specialists (FFSs) are Federal employees who oversee the care providers and 
ensure that they are following ORR requirements. FFSs are ORR’s field staff who are assigned 
to a group of care providers within a region. An FFS’s authority includes approving or denying 
all child transfer and release decisions, overseeing care providers, implementing policies and 
procedures, and serving as a liaison to local stakeholders. FFSs also provide guidance, direction, 
and technical assistance to care providers. 
Case Managers are employees of the care provider whose responsibilities include: 
• coordinating child assessments to include completing individual service plans, 
• assessing potential child sponsors, 
• making transfer and release recommendations, and 
• coordinating the release of a child to a sponsor. 
ORR contracts with Case Coordinators who act as local ORR liaisons with care providers. Case 
Coordinators serve as third-party reviewers of each Case Manager’s family reunification process. 
After reviewing the Case Managers’ decisions, Case Coordinators make transfer and release 
recommendations to the FFSs. 
ORR policy requires that children receive certain care and services while in care provider 
facilities. See Appendix C for a chart of some of these services. 
Family Reunification Process 
In addition to caring for children, the care providers facilitate the release of the child to family 
members or other sponsors, known as the “family reunification process,” according to the 
following preferences: (1) a parent, (2) a legal guardian, (3) an adult relative, (4) an adult 
individual or entity designated by the child’s parent or legal guardian, (5) a licensed program 
willing to accept legal custody, or (6) an adult or entity approved by ORR. ORR has grouped 
these sponsors into three categories: 
• Category 1 – Parents and legal guardians; 
3 45 CFR part 74 was superseded by 45 CFR part 75 for awards made on or after December 26, 2014. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 3 
 

 • Category 2 – Other immediate adult relatives, such as a brother, sister, aunt, uncle, or 
grandparent; and 
• Category 3 – Distant relatives and unrelated adults. 
In making placement decisions, Case Managers facilitate background investigations on the 
sponsor. As detailed in Appendix F, the level of the background check depends on the 
relationship between the sponsor and the child. 
During the family reunification process, Case Managers are responsible for conducting a 
suitability assessment of the sponsor. This assessment includes investigating the background of 
the sponsor, but Case Managers must also confirm the familial relationship of the sponsor to the 
child. Furthermore, current ORR policy requires the sponsor to complete a sponsor care plan if 
the sponsor is unlawfully present in the United States. ORR requires a sponsor care plan to 
ensure that each child has a caregiver, regardless of any complications that could arise from a 
sponsor’s immigration status. 
The FFS, Case Manager, and Case Coordinator each play a role in the decision to release a UAC 
to a sponsor. The Case Manager makes a recommendation to the Case Coordinator regarding the 
release. The Case Coordinator conducts a third-party review of the proposed release and makes a 
recommendation to the FFS on the release of the UAC to a particular sponsor. If the Case 
Manager and Case Coordinator are unable to agree on a particular recommendation, they may 
refer the case directly to an FFS for guidance. Once the Case Manager and Case Coordinator 
present a recommendation to the FFS, the FFS reviews the recommendation and makes a release 
decision in consideration of these recommendations. 
His House 
His House is an ORR-funded, faith-based, shelter care provider in Miami, Florida. Since 2008, 
His House has participated in the UAC program and served more than 5,000 children. In FY 
2014, His House spent approximately $9 million in Federal funds for the care and placement of 
approximately 1,900 children. 
Of the approximately 1,900 children at His House during 2014: 
• 81 percent were males and 19 percent were females, 
• 48 percent were between the ages of 13 and 16, and 
• 65 percent were released to category 1 sponsors. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 4 
 

 HOW WE CONDUCTED THIS REVIEW 
To ensure that His House met applicable safety standards, we (1) inspected 3 of 10 cottages that 
provided shelter care, (2) reviewed His House licensing documents and inspection results, (3) 
reviewed a judgmental sample of His House personnel records, and (4) reviewed a statistical 
sample of case files for those children who had been released to a sponsor during FY 2014. 
To ensure that His House claimed only allowable expenditures, we (1) reviewed a stratified 
statistical sample of financial transactions and (2) reviewed His House accounting policies, 
procedures, and organizational structure. 
Our review covered October 1, 2013, through September 30, 2014 (audit period). 
We conducted this performance audit in accordance with generally accepted government 
auditing standards. Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 
based on our audit objectives. We believe that the evidence obtained provides a reasonable basis 
for our findings and conclusions based on our audit objectives. 
Appendix A contains the details of our audit scope and methodology, Appendices D and E 
contain the details of our sampling methodology and estimates, and Appendix F contains 
selected definitions. 
FINDINGS 
His House generally met applicable safety standards for the care and release of children in its 
custody and claimed only allowable expenditures. However, His House did not have some 
documentation required to verify that it had met certain safety standards, and it had some 
deficiencies within its financial management system. 
Although His House generally met safety standards for the care and release of children in its 
custody, some UAC case files were missing evidence of sponsor background checks and other 
required documentation. 
These documentation deficiencies occurred because His House lacked oversight by its own staff 
to ensure that all ORR-required documentation was maintained in the UAC case files. 
On the basis of our UAC case file sample results, we estimated that His House did not properly 
document the care and release of approximately 36 percent of all children released to sponsors in 
FY 2014. Without adequate documentation in the case files, ORR could not be assured that, for 
652 children, His House had followed ORR policies regarding sponsor background checks, 
prompt medical care, provision of appropriate clothing, sponsor placement decisions, post- 
release services, or the notification of the Department of Homeland Security (DHS) of the child’s 
release to a sponsor. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 5 

 Although His House claimed only allowable expenditures, it had some deficiencies within its 
financial management system, such as a lack of documentation and segregation of duties. The 
deficiencies within the financial management system occurred because His House lacked an 
efficient and effective system of internal controls when administering UAC program funds. 
Without an efficient and effective internal control system, Federal funds totaling $8,994,814 
were at risk of mismanagement or misappropriation. 
SOME DOCUMENTS WERE MISSING FROM HIS HOUSE CASE FILES 
Of the 1,810 children4 that His House released to sponsors during our audit period, we estimated 
that 36 percent of the associated case files contained errors (3 percent sponsor- 
background-check-related and 35 percent “other” documentation errors).5 
Some Case Files Lacked Evidence of Background Investigations on Sponsors 
All potential sponsors must undergo background checks (Ops Manual 2012 § 4.401; Ops 
Manuals 2013 and 2014, § 4.402). However, His House could not provide evidence that it 
conducted all required background checks when vetting sponsors. From our statistical sample of 
75 UAC case files, 2 did not contain documentation to indicate that His House had conducted 
background checks on the sponsors. Specifically, one case file for a child His House released to a 
category 1 sponsor contained no evidence that a public records check was conducted on the 
sponsor. The second case file was missing documentation to indicate that His House conducted a 
criminal history fingerprint check on a category 2 sponsor. 
Vulnerability in Background Investigation Process 
During our audit period, ORR policy did not require that all adult household members residing in 
a potential sponsor’s home undergo background checks, except in cases referred for a home 
study. ORR policy did require a sponsor unlawfully present in the United States to complete a 
sponsor care agreement indicating the sponsor’s plan for care for the UAC should immigration 
issues arise for the sponsor. However, the sponsor care agreement during the period of our audit 
did not require individuals named as potential caregivers to undergo background checks. 
In FY 2014, His House released to category 1 sponsors approximately 65 percent of the children 
in its care. Of the children that His House released to category 1 sponsors, approximately 83 
percent of those sponsors were unlawfully present in the United States. During our review of the 
75 sampled case files, we noted vulnerabilities in ORR’s policy related to children released to 
category 1 sponsors. Not requiring a background investigation on all adults in the household put 
the safety of each child released to a category 1 sponsor at risk by virtue of the shared living 
space. 
4 His House cared for approximately 1,900 children during FY 2014. Our review covered only those children who 
had been released directly to a sponsor. 
5 The individual error percentages do not sum to 36 percent because some case files had both background-check- 

 related errors and “other” documentation errors. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 6 
 

 For example, one case file we reviewed, where the child was released to his mother, 
demonstrates the vulnerability that exists when household members do not undergo background 
checks. In this instance, if the mother were deported or experienced other immigration issues, the 
child’s stepfather (an unrelated adult) could have become the child’s caretaker. ORR 
subsequently changed its policy on background investigations to require certain types of 
background checks on all adults in a sponsor’s household and on all adults in the sponsor care 
agreement. This is an important step to help ensure children are released into safe households, 
especially if complications arise from a sponsor’s immigration status. 
Missing Documentation Because of Lack of Oversight 
His House stated that it did not document in the two UAC case file the background investigations 
required for these sponsor files because of a lack of oversight on its part to ensure that case files 
contained all required documentation. 
Unaccompanied Children’s Safety Potentially at Risk Upon Release 
On the basis of our sample results, we estimated that His House did not have evidence that it had 
conducted background investigations in 3 percent of the cases in which it released children to 
sponsors in FY 2014. Without documentation in the UAC case files to demonstrate that His 
House conducted background investigations, ORR was not always sure that His House was 
releasing children to sponsors who had been properly vetted. As a result, children may have been 
at risk of being released to sponsors with significant criminal backgrounds, placing children in 
danger, including of human trafficking. 
Some Case Files Had Other Documentation Errors 
Of the 75 UAC case files in our sample, 26 files had other documentation errors, and 4 of these 
had more than 1 error. On the basis of our sample results, we estimated that His House did not 
properly document the care or notify DHS of release of approximately 35 percent of all children 
released to sponsors in FY 2014. As a result, ORR could not be assured that His House followed 
ORR policies regarding prompt medical care, provision of appropriate clothing, sponsor 
placement decisions, post-release services, or notification of DHS of the child’s release to a 
sponsor. The documentation errors we identified are described below. 
Information Not Gathered Within Required Time 
According to ORR policy, a care provider must use an “Initial Intakes Assessment” form to 
interview the child within 24 hours of arrival at the ORR facility. For 10 of the 26 sample files, 
the “Initial Intakes Assessment” form contained errors. For example, 5 of these 10 sample files 
indicated that the required intake procedures were not completed within 24 hours. In addition, 2 
of the 10 sample files did not document the date that the child arrived at the ORR care provider 
facility or the date the intake assessment was completed. Other discrepancies included missing 
intake assessment forms for three sample files. 

 Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 7 
 

 Some Case Files Missing Documents To Support Clean Clothing Distribution 
Care providers are required to issue clothing to each child upon admission (P&P Manual, § 
3.01). For 17 of the 26 sample files, His House did not document that it gave the child clothing 
upon admission. 
Some Case Files Missing Documentation To Prove Discharge Notification Forms Were Sent to 
the Department of Homeland Security 
Upon release of a child to a sponsor, the care provider is required to complete a discharge 
notification form within 24 hours and email the forms to DHS and other stakeholders (Ops 
Manual 2012 § 4.500; Ops Manuals 2013 and 2014, § 4.501). For 3 of the 26 sample files, no 
documentation in the case file supported that His House notified DHS that it had released a child 
to a sponsor. 
Missing Documentation Because of Lack of Oversight 
His House stated that the file discrepancies and documentation missing from the UAC case files 
were caused by a lack of oversight by His House staff responsible for conducting quality 
assurance reviews of the case files. 
ALTHOUGH TRANSACTIONS WERE ALLOWABLE, HIS HOUSE HAD 
DEFICIENCIES WITHIN ITS FINANCIAL MANAGEMENT AND PROPERTY 
CONTROL SYSTEMS 
His House recorded $8,994,814 in expenditures during FY 2014. Of these expenditures, we 
statistically selected 105 financial transactions totaling $1,935,250 for review. All 105 
transactions were allowable. However, His House had several deficiencies within its financial 
management system that, collectively, put at risk almost $9 million in Federal funds for potential 
mismanagement or misappropriation. 
His House Lacked Documentation and a Methodology for Payment Management System 
Drawdowns 
Recipients’ financial management systems must provide accounting records that are supported 
by source documentation (45 CFR § 74.21(b)(7)), and cash advances to a recipient organization 
must be limited to the minimum amounts needed and be timed to be in accordance with the 
actual, immediate cash requirements of the grantee in carrying out the program (45 CFR § 
74.22(b)(ii)(2)). His House made 15 drawdowns from the payment management system (PMS)6 
totaling approximately $8.2 million during FY 2014 but had no documentation to support the use 
of the funds drawn. Additionally, although His House representatives asserted that they drew 
funds on an as-needed basis, they could not explain the methodology used to calculate the 
amounts drawn. 
6 PMS is a centralized payment and cash-management system that accomplishes all payment-related activities from 
the time of award through closeout. 

 Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 8 
 

 His House’s Financial Accounting System Was Not Able To Specifically Identify 
Expenditures for Its Shelter Care Cooperative Agreement 
Recipients’ financial management systems must provide records that adequately identify the 
source and application of funds for HHS-sponsored projects or programs (45 CFR § 
74.21(b)(2)). His House’s financial accounting system was not able to specifically identify 
expenditures for its ORR-funded shelter care (residential services) cooperative agreement. For 
example, His House’s accounting system did not use an indicator to distinguish between 
expenditures associated with a different cooperative agreement. Therefore, we statistically 
selected and reviewed expenditure transactions for both His House’s ORR-funded Residential 
Services cooperative agreement and its Home Study7 cooperative agreement. 
The current His House staff stated that during FY 2014, both of the ORR-funded cooperative 
agreements (Residential Services and Home Study) were combined under one account in PMS. 
They believed that combining the cooperative agreement accounts in PMS created some 
confusion for the previous His House staff regarding how the cooperative agreements should 
have been recorded within the financial system. 
His House Had Inadequate and Improperly Implemented Segregation of Duties 
Recipients’ financial management systems must provide effective control over and 
accountability for all funds (45 CFR § 74.21(b)(3)). His House payroll personnel had unlimited 
direct online access to change employee data in His House’s human resource (HR) and payroll 
systems with limited managerial oversight. During the audit period, His House used one system 
for HR data (PayChex) and another system for processing time and attendance (QQest). The 
PayChex system maintained employee demographic data such as name, address, date of hire, 
date of birth, Social Security number, position title, etc. His House HR personnel were 
responsible for entering employee data into the PayChex system. The QQest system recorded 
time and attendance for His House employees. His House payroll personnel uploaded time and 
attendance data from QQest into PayChex to process payroll. 
Payroll personnel had unlimited access to make changes in both PayChex and QQest with 
limited managerial oversight. His House has continued this process with its current system, 
SimplePay. 
His House stated that payroll personnel had access to employee input fields; however, an 
approved Personnel Action Request form was required prior to the payroll personnel making a 
change in PayChex. Nevertheless, His House did not establish effective controls over HR and 
payroll responsibilities so that no single employee had unlimited access to both systems. Access 
to both systems gives an employee the ability to enter changes, such as salary and wage 
increases, in both the HR and payroll systems. His House had policies and procedures that were 
not implemented in a way that achieved adequate segregation of duties and managerial oversight. 
7 The Office of Refugee Resettlement/Division of Children's Services conducts home studies for certain children 

 prior to their release from ORR custody. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 9 
 

 His House Had Inaccurate and Delayed Recording of Accounting Transactions 
Recipients’ financial management systems must provide for accurate, current, and complete 
disclosure of the financial results of each HHS-sponsored project or program (45 CFR § 
74.21(b)(1)). Moreover, management designs appropriate control activities for the entity’s 
internal control system such as accurately and timely recording transactions to maintain their 
relevance and value to management.8 In cash management situations, organizations rely on 
timely and accurate recording to draw Federal funds based on actual cash needs. Throughout the 
fiscal year, His House made numerous adjustments to payroll expenditures. Additionally, His 
House did not efficiently manage its credit card payments. 
Instead of recording payroll to its proper account within the financial accounting system when 
payroll was processed, His House initially recorded payroll to a miscellaneous expense account. 
After it processed payroll, His House would allocate payroll to proper accounting codes on the 
basis of the labor distribution reports. Payroll transactions totaling $122,308 that were not 
promptly recorded lost their relevance and value to management’s control of operations and 
decision making. 
Additionally, His House did not match payments on its corporate credit card with current 
expenditures. Therefore, we could not associate payments to specific grant expenditures that His 
House made with the credit card. As a result, we have no assurance that His House’s credit card 
purchases and payments were for expenditures it incurred during the credit card billing period. 
His House Had Inadequate Physical Control Over Vulnerable Assets 
Recipients’ financial management systems must provide effective control over and 
accountability for all funds, property, and other assets (45 CFR § 74.21(b)(3)). His House did not 
maintain an inventory of assets. For example, His House had equipment items that it used to 
perform routine maintenance on UAC shelters. These items were not documented or maintained 
in its inventory. Likewise, although property tags were placed on computer equipment, His 
House had no system for tracking the equipment and did no inventory verification. As a result, 
His House did not know the location or condition of the assets and equipment that it owned. 
8 Principle 10.03, Standards for Internal Control in the Federal Government (GAO-14-704G), issued by GAO 
September 2014. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 10 
 

 RECOMMENDATIONS 
We recommend that His House: 
• develop a policy for maintaining UAC case file documentation that would ensure ORR policies 
and procedures were followed when releasing a child to a sponsor; 
• increase oversight of its reviewing process for UAC case files to ensure that all required 
documentation is maintained in the file; 
• update or develop policies and procedures pertaining to: 
o maintaining adequate documentation to support its drawdowns of Federal funds 
and to support that its drawdowns are based on actual expenditures, 
o achieving the segregation of duties such as ensuring limited access to employee 
data maintained in its HR and payroll systems and improved managerial oversight, and 
o recording financial transactions accurately and timely; and 
• implement a financial management system that requires adequate identification of the source 
and application of Federal funds and effective accountability of property and other assets. 
HIS HOUSE COMMENTS AND OFFICE OF INSPECTOR GENERAL RESPONSE 
His House concurred with our recommendations and described steps it had taken or planned to 
take to address our findings and recommendations. His House also provided additional 
documentation to support some of the items we determined to be in error in our draft report. 
Additionally, His House provided policies and procedures that it developed in response to our 
review. We revised our findings, as appropriate, to reflect our review of the additional 
documentation His House provided. 
With respect to our review of UAC case files, His House provided documentation to support 19 
sample items that we had determined to contain errors. We accepted this documentation for three 
sample items and adjusted our sample results accordingly. Although our error count changed, our 
findings and recommendations did not change. We included these changes in the body of the 
report, as well as in Appendix E. 
With respect to our review of financial transactions, His House disagreed with the OIG’s 
findings but concurred with our recommendations. Although His House disagreed with our 
findings, it developed new policies and procedures related to its financial management system to 
address our findings and recommendations. These addressed: 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 11 
 

 • maintaining adequate documentation to support its drawdowns of Federal funds, 
• maintaining adequate documentation to support that its drawdowns are based on actual 
expenditures, 
• segregating duties to ensure limited access to employee data maintained on its HR and payroll 
systems, 
• improving managerial oversight over access to employee data, 
• recording financial transactions accurately and timely, 
• implementing a financial management system that requires adequate identification of source 
and application of Federal funds, and 
• implementing effective accountability of property and other assets. 
After reviewing His House’s comments and additional documentation, we maintain that our 
findings and recommendations are correct. 
His House’s written comments are included in their entirety as Appendix G. However, we did 
not include the attached exhibits because they were too voluminous. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 12 
 

 APPENDIX A: SCOPE AND METHODOLOGY 
SCOPE 
We reviewed His House’s health and safety controls to ensure that the care provider met 
applicable safety standards for the care of children in its custody. Additionally, we reviewed 
documentation related to grant expenditures claimed for reimbursement and His House 
accounting policies, procedures, and organizational structure to ensure His House met applicable 
Federal and State grant requirements in administering its UAC grant. 
We performed our fieldwork at His House in Miami Gardens, Florida, from November 2016 
through July 2017. Our review covered from October 1, 2013, through September 30, 2014 
(audit period). 
Our objective did not require an understanding of all of His House’s internal controls. We 
limited our assessment to His House’s controls pertaining to the selected health and safety 
factors we reviewed. We also reviewed His House’s internal controls related to its financial 
management system. 
METHODOLOGY 
To accomplish our objective, we: 
• reviewed applicable Federal laws, regulations, and guidance; 
• reviewed grant documents and policies and procedures maintained at His House; 
• interviewed His House officials and ORR’s Federal Field Specialist assigned to His House; 
• toured the His House site; 
• conducted a review of selected health and safety factors at the site and noted any deficiencies; 
• selected a statistical sample of UAC case files for children released to sponsors during FY 2014 
(Appendix D); 
• reviewed and documented any deficiencies within these sampled UAC case files; 
• selected and reviewed a judgmental sample of employee files by: 
o sorting the list of employees into two groups: part-time and full-time, 
o numbering the list sequentially, and 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 13 
 

 o selecting every 10th full-time employee and every 6th part-time employee; 
• selected a stratified statistical sample of financial transactions that His House charged to the 
grant during FY 2014 (Appendix D); 
• reviewed supporting documentation for each sampled transaction (including payments to 
subcontractors, if applicable); 
• reviewed His House’s Federal grant reports—financial and programmatic—for the audit 
period; 
• estimated results of statistical samples, as applicable (Appendix E); and 
• discussed our findings with His House officials. 
We conducted this performance audit in accordance with generally accepted government 
auditing standards. Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 
based on our audit objectives. We believe that the evidence obtained provides a reasonable basis 
for our findings and conclusions based on our audit objectives. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 14 
 

 APPENDIX B: OFFICE OF REFUGEE RESETTLEMENT REQUIREMENTS (Effective 
10/2013–9/2014) 
Unless otherwise noted, Manual provisions are effective as of the following dates: 
Ops Manual 2012—12/21/12 Ops Manual 2013—11/25/13 Ops Manual 2014—4/4/14 P&P 
Manual—8/21/06 
Background Checks for Sponsors To meet the requirement of an independent finding that the 
sponsor does not have a history that would place a UAC’s safety at risk, in collaboration with the 
U.S. Department of Health and Human Services, Office of Security and Strategic Information, 
Division of Personnel Security, care providers shall conduct criminal history, child abuse/neglect 
checks and immigration background checks as follows: 
Ops Manual 2012 § 4.401 National (FBI) Criminal History Check (digital fingerprint) 
• All sponsors 
• All adult household members for cases referred for a home study 
• May be conducted on any adult household member where a case of special concern is identified 
Immigration Status Check 
• All sponsors 
Child Abuse and Neglect check 
• The sponsor, for all home study cases 
• May be conducted on any adult household member where a case of special concern is identified 
Criminal Public Record Check (Internet) 
• All sponsors 
• May be conducted on any adult household member where a case of special concern is identified 
State Criminal History Repository Check and/or Local Police Check 
• For sponsors or household members, may be conducted in special circumstance only for 
unresolved criminal arrest or issue 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 15 
 

 Ops Manuals 2013 § 4.402 National (FBI) Criminal History Check (digital fingerprint)9 
• Category 2 and Category 3 sponsors 
• Category 1 sponsors where there is a documented risk to the safety of the UAC, the UAC is 
especially vulnerable, or the case is being referred for a mandatory home study 
• All adult household members for home study cases 
• May be conducted on any adult household member where a case of special concern is identified 
Immigration Status Check 
• All sponsors 
Child Abuse and Neglect Check 
• The sponsor, for all home study cases 
• May be conducted on any adult household member where a case of special concern is identified 
Criminal Public Record Check (Internet) 
• All sponsors 
• May be conducted on any adult household member where a case of special concern is identified 
State Criminal History Repository Check and/or Local Police Check 
• May be conducted on sponsors or household members in special circumstances only for 
unresolved criminal arrest or issue 
Ops Manuals 2014 § 4.402 (issued 1/1/14) National (FBI) Criminal History Check (digital 
fingerprint) 
• Category 2 and Category 3 sponsors 
• Category 1 sponsors where there is a documented risk to the safety of the UAC, the UAC is 
especially vulnerable, or the case is being referred for a mandatory home study 
• All adult household members for home study cases 
• May be conducted on any adult household member where a case of special concern is identified 
Immigration Status Check 
• All sponsors that require a national (FBI) criminal history check 
Child Abuse and Neglect check 
• The sponsor, for all home study cases 
9 During the first 2 months of the audit period of this review (October and November 2013), ORR required all 
categories of sponsors to undergo a National (FBI) Criminal History Check. Effective November 25, 2013, this 
requirement no longer applied to Category 1 sponsors. Additionally, for approximately 1 month during our audit 
period (May 20, 2014, through June 16, 2014), ORR did not require fingerprint background checks on any category 

 of sponsor if certain conditions were met. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 16 
 

 • May be conducted on any adult household member where a case of special concern is identified 
Criminal Public Record Check (internet) 
• All sponsors 
• May be conducted on any adult household member where a case of special concern is identified 
State Criminal History Repository Check or Local Police Check 
• May be conducted on sponsors or household members in special circumstances only 
Other Documentation P&P Manual § 3.01 Admission staff shall be responsible for ensuring that: 
• an Initial Intake form is completed within 24 hours of each UAC’s arrival, 
• the UAC receives clean clothing (if needed), and 
• the UAC receives a medical examination within 48 hours of admission or the first workday 
after admission. 
Ops Manual 2012 § 4.402; Manuals 2013 and 2014, § 4.401 and § 4.403 When making a release 
recommendation, the care provider conducts an assessment of the UAC and the potential 
sponsor. 
Upon completion of the assessment process, the Case Manager makes a release recommendation 
to the Case Coordinator. The Case Coordinator conducts a third-party review of the proposed 
release and submits the release recommendation to the FFS. The FFS considers the release 
recommendation and makes the final decision on the UACs release. 
Ops  Manual  2012  §  4.500;  Ops  Manuals  2013  and  2014,  §  4.403  and  §  4.501 (issued 11/25/13) 
The  Department  of  Homeland  Security  (DHS)  shall be provided notice, by email, of the pending 
release  of  a  UAC.  In  order  to  provide  DHS  sufficient time to comment on the release of a UAC, 
the  care  provider  shall  not  release  the  UAC  until  24  hours  have  elapsed  from  the  time  the  care 
provider emails notification of the pending release to DHS. 
Case File Management P&P Manual 1.02 ORR’s policy is to ensure that UAC case files are 
comprehensive, complete, accurate and up-to-date, and that confidentiality and security is 
maintained. Care providers shall develop, maintain, and safeguard individual UAC case files and 
develop an internal policy on staff access and use. This policy shall include a system of 
accountability that ensures completeness and accuracy of files, preserves the confidentiality of 
client information, and protects the records from unauthorized use or disclosure. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 17 
 

 Each UAC case file shall contain the following information: Personal Identifying 
Information 
• Name/Alien Number 
• Initial Intake Form 
• Placement and Medical Authorization Forms 
• Photographs 
• Cover Sheet which highlights dates of key services provided (admission date, mental health 
assessments, counseling sessions, medical treatments, transfers, and family reunification/release) 
• Case Information/History from Referral Source 
• Case Notes/Log Legal Information 
• 1-770 Notice of Rights 
• Authority to Accept Child 
• Case Information Referral 
• Case History 
• G-28 (if applicable) 
• DHS Documents 
• Court Documents 
• Signed Release of Information (if applicable) Medical and Mental Health 
• Admission Assessment Form 
• Psycho-Social Summary and Individual Service Plan (ISP) 
• Updates of Psycho-Social Summary and ISP at 90-day intervals 
• Trafficking Addendum 
• Staff-Secure/Secure Addendum 
• Medical Exam (within 48 hours) 
• Medical Records 
• Immunization Records 
• Individual Counseling Notes 
• Group Counseling Log 
• Progress Notes Related to Medical or Mental Health Services 
• Signed Release of Information 

 • Copies of Referrals to Medical Providers and Results of Outpatient Consultations Care 
Provider Information 
• Acknowledgement of Orientation Program Rules/Policies/Grievance 
• Acknowledgement of Rights and Responsibilities (signed by child in client’s language) 
• Incidents Reports (Internal and ORR) 
• Telephone Log 
• Inventory and Receipts of Cash and Personal Property 
• Stipend Log 
• Clothing and Supplies Distribution Log 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 18 
 

 Education, Training, and Recreation 
• Educational Assessment 
• Education Records 
• Training Records 
• Recreational Activity Log Exit Information 
• Family Reunification Packet 
• Transfer Forms 
• Exit Letter 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 19 
 

 APPENDIX C: SELECTED REQUIREMENTS FOR OFFICE OF REFUGEE 
RESETTLEMENT PROVIDER CARE FACILITIES DURING OUR AUDIT PERIOD10 
Care/Service Requirement Initial Intakes Assessment Within 24 hours of receiving a child, 
facility staff conduct an assessment to gather information on family members, medical and 
mental health concerns, medications taken, and personal safety concerns. Orientation Within 48 
hours of admission, facility 
staff provide an orientation to the child, including providing information on the care provider’s 
rules, regulations, and procedures; the child’s rights and responsibilities; and grievance policies 
and procedures. Medical Services Within 48 hours of arrival, children 
receive an initial medical examination, unless the child has been transferred from another ORR 
care provider and has documentation showing that the initial examination has already occurred. 
Academic Educational Services Within 72 hours of admission, the 
provider must conduct an educational assessment. Facilities must provide 6 hours of education 
per day, Monday- Friday, throughout the calendar year in basic educational areas (including 
English as a second language, if applicable). Proper Physical Care Children are provided suitable 
living accommodations, food, appropriate clothing, and personal grooming items. Individual 
Child Assessment Care providers must conduct 
intake/admission assessments and develop ISPs for UAC to ensure that their needs are accurately 
assessed and addressed. 
10 P&P Manual, sections 2 and 3. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 20 
 

 Care/Service Requirement Recreational and Leisure Services Children are to engage in at least 1 
hour 
of large muscle activity each day and 1 hour per day of structured leisure activity, per a 
recreational and leisure services plan. Individual and Group Counseling Services Children are 
provided at least one 
individual counseling session with a trained social worker and two group counseling sessions per 
week. Legal Services Information Children are provided information on legal rights and the 
availability of free legal services. Reunification Services Staff are required to identify sponsors 
and evaluate the suitability of the sponsor. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 21 
 

 APPENDIX D: STATISTICAL SAMPLING METHODOLOGIES 
HEALTH AND SAFETY 
Target Population 
The population consisted of all children that His House released to sponsors during FY 2014. 
Sampling Frame 
We received an Excel file from His House that listed 1,873 children whom it had discharged 
during FY 2014. From this list, we removed those children who had been transferred. We also 
removed children who were 18 or over at the time of their admission to His House. The 
remaining 1,810 children, whom His House directly released to a sponsor, constitute our 
sampling frame. 
Sample Unit 
The sample unit was a child whom His House released to a sponsor during FY 2014. 
Sample Design 
We used a simple random sample. 
Sample Size 
We selected 75 children. 
Source of Random Numbers 
We used the Office of Inspector General, Office of Audit Services (OIG/OAS), statistical 
software to generate the random numbers. 
Method of Selecting Sample Items 
We consecutively numbered the lines in the sampling frame from 1 to 1,810. After generating 
the random numbers, we selected the corresponding frame items. 
Estimation Methodology 
Using the OIG/OAS statistical software, we estimated the number and percentage of children 
whom His House released to sponsors during FY 2014 without following ORR policies and 
procedures. For this same timeframe, we also estimated the percentage and number of Category I 
sponsors and sponsors unlawfully present in the United States. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 22 
 

 FINANCIAL TRANSACTIONS 
Target Population 
The population consisted of all expenditure transactions on His House’s general ledger for its 
“residential” and “home study”11 grants during FY 2014. 
Sampling Frame 
We received an Excel file from His House that listed 6,953 transactions totaling $8,994,814 that 
His House had recorded as expenditures during FY 2014 for both its residential and home study 
grants. We manually matched expenditure transactions in the general ledger by verifying 
accounting system identifiers to remove all transactions that netted to zero. We also removed all 
transactions less than $100 (both debits and credits). The resulting Excel spreadsheet of 3,838 
transactions totaling $8,959,645 was our sample frame. 
Sample Unit 
The sample unit was a general ledger expenditure transaction. 
Sample Design and Sample Size 
We used a stratified random sample. The sampling frame was divided into four strata based on 
dollar value, as outlined in Table 1. 
Table 1: Sample Design 
Stratum # 
Frame Count Frame Total 
Strata Values From 
Strata Values 
To Sample 1 3,086 $2,060,483 $100.00 $3,782.48 30 2 367 3,551,804 3,799.04 26,226.64 30 3 
63 3,555,708 27,972.50 210,255.13 30 4 322 (208,350) (19,745.47) (100.00) 15 Totals 3,838 
$8,959,645 105 
11 ORR provides temporary shelter care and other related services to children in its custody through residential 
grants. A home study is an indepth investigation of the potential sponsor’s ability to ensure the child’s safety and 
well-being. A home study is conducted for any case in which the safety and well-being of the unaccompanied child 
is in question and on any case that meets the mandatory Trafficking Victims Protection Reauthorization Act of 2008 
home study categories. ORR provides separate funding for the conduct of home studies. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 23 
 

 Source of Random Numbers 
We used the OIG/OAS statistical software to generate the random numbers. 
Method of Selecting Sample Items: 
We consecutively numbered the transactions in each stratum. After generating the random 
numbers, we selected the corresponding frame items. 
Estimation Methodology 
We planned to estimate the total amount of any expenditures that were unallowable. However, 
we identified no errors in the sample of financial transactions, so we calculated no estimate. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 24 
 

 APPENDIX E: SAMPLE RESULTS AND ESTIMATES—UAC CASE FILES 
Table 2: Sample Results 
Inadequate Background Documentation Sample Frame Sample Investigation Errors 
1,810 75 2 26 
Table 3: Statistical Estimates (Limits Calculated at the 90-Percent Confidence Level) 
Percent Number 
Estimate Description 
Lower 
Point 
Upper 
Lower 
Point Limit 
Estimate 
Limit 
Limit 
Estimate 
Upper Limit Case files with background errors 
.5 3 8 9 48 145 
Case files with other documentation errors 
26 35 44 466 627 805 
Case files with at least one error 
27 36 46 488 65212 830 
Case files associated with category 1 sponsors 
56 65 74 1,005 1,183 1,344 
Case files associated with sponsors unlawfully present in the U.S. 
74 83 89 1,341 1,496 1,616 
SAMPLE RESULTS AND ESTIMATES—FINANCIAL TRANSACTIONS 
We did not identify any unallowable transactions in the 105 statistically valid sample items that 
we reviewed. 
12 The number and percentage of case files with at least one error is less than the sum of the individual error 

 estimates because one sampled case file had both documentation errors and inadequate background investigations. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 25 
 

 APPENDIX F: DEFINITIONS13 
Care Provider—A care provider is any ORR-funded program that is licensed, certified, or 
accredited by an appropriate State agency to provide residential care for children, including 
shelter, group, foster care, staff-secure, secure, therapeutic, or residential treatment care. 
Case Manager—The Case Manager is the care provider staff member who coordinates 
assessments of unaccompanied children, individual service plans, and efforts to release 
unaccompanied children from ORR custody, which includes conducting sponsor background 
investigations. Case Managers also maintain case files for unaccompanied children and ensure 
that all services for children are documented. 
Case Coordinators—Case Coordinators are ORR nongovernmental contractor field staff who act 
as local ORR liaisons with care providers and stakeholders and who are responsible for making 
transfer and release recommendations. 
Child Sponsor—A sponsor is an individual (in the majority of cases a parent or other relative) or 
entity to which ORR releases an unaccompanied child out of Federal custody. 
Clinician—The Clinician is the care provider staff that provides clinical and/or counseling 
services for unaccompanied children and provides oversight for the unaccompanied child’s 
mental and emotional health. 
Family Reunification Packet—The family reunification packet is an application and supporting 
documentation completed by potential sponsors who wish to have an unaccompanied child 
released from ORR into their care. ORR uses the application and supporting documentation, as 
well as other procedures, to determine the sponsor’s ability to provide for the unaccompanied 
child’s physical and mental well-being. 
Legal Guardian—A legal guardian is a person who was appointed to charge or custody of a child 
in a court order recognized by U.S. courts. 
Federal  Field  Specialist  (FFS)—Field  staff  who  act  as  the local ORR liaison with care providers 
and  stakeholders.  An  FFS  is  assigned  to  multiple  care  providers  within  a  specific  region  and 
serves  as  the  regional  approval  authority  for  unaccompanied  children  transfer  and  release 
decisions. 
Placements—The  term  “placements”  includes  initial  placement  of  an  unaccompanied  child  into 
an  ORR  care  provider  facility,  as well as the transfer of an unaccompanied child within the ORR 
network of care. 
13 Definitions compiled from various ORR sources. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 26 
 

 Release—A release is the ORR-approved release of an unaccompanied child from the care and 
custody of ORR to the care of a sponsor. 
Office of Refugee Resettlement Unaccompanied Children Grantee Review—His House (A-04-16-03566) 27 
 

 APPENDIX G: HIS HOUSE COMMENTS 

Flus 
www.hhch.org 

HOUSE 
CHILDREN'S HOME 

October 3, 2017 

Report Number A-04-16-03566 
Lori S. Pilcher Regional Inspector General 
For Audit Services Office of Inspector General 

Audit Services, Region IV 61 Forsythe Street, SW, Suite 3T41 Atlanta, GA 30303 
Dear Ms. Pilcher: 

Please find His House Children's Home (His House) response to the U.S. Department of Health 
and Human Services, Office of Inspector General's (OIG), report dated August 2017 entitled 
“Office of Refugee Resettlement Unaccompanied Alien Children Grantee Review - His House." 
As noted in the OIG report, 2014 was the "surge” year for the Federal program. During 2014, 
His House similarly experienced a significant increase in the number of children placed and 
cared for at His House from previous years. In order to efficiently process and accommodate the 
higher number of children in Federal care, ORR made several changes to the DUCS Policies and 
Procedures Manual and the ORR UAC Program Operations Manual during this period. This was 
a difficult period of adjustment for all the care providers across the nation who accommodated 
the care and processing of children in their facilities during a high period of influx. The analogy 
can be made with that of “changing the tires on a moving school bus." 
In the report OIG made two findings. The first finding was that His House might not have 
followed ORR policies for 724 children regarding "sponsor background checks, prompt medical 
care, provision of appropriate clothing, sponsor placement decisions, post-release services, 
and/or the notification of Department of Homeland Security of the child's release to a sponsor.” 
The second finding was that His House might have placed Federal funds totaling 9 million 
dollars at risk of mismanagement or misappropriation. 

20000 N.W. 47th Avenue, Miami, FL 33055 (T) 305.430.00 85 
Office of Refugee Resettlement Unaccompanied Children Grantee Review-His House (A-04-16-03566) 
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 Office of Inspector General Note—The deleted text has been redacted because it is personally 
identifiable information. 
 

 where a chest x-ray was done and lab work was ordered. This is documented in the file with the 
following documentations; “UAC Doctor's Visit Report", an electronic copy of the doctor's chart, 
the "Florida Certification of Immunization" record that documents on the second page that the 
child was seen on February 3, 2014 for a "complete physical exam", and a prescription for lab 
work dated February 3, 2014 showing the same date for the "collection” of sample for testing. 
(See, Exhibit “C”.) 
Provision of Appropriate Clothing: OIG found that in 17 of the 29 sample files, His House did 
not document that it gave the children clothing upon admission to His House. His House 
acknowledges that there are 3 files that were missing supporting documentation that clothing was 
provided to the children upon arrival. The 3 cases are OIG Samples #20, #49 and #53. However, 
the remaining samples all had the "His House Children's Home – UAC INVENTORY LOG 
(Minor's Belongings Upon Arrival)” in addition to the “His House Children's Home - UAC 
INVENTORY LOG (DISCHARGE)." This documentation was previously provided to the OIG 
investigators in July of 2016. (The supporting documentation for the 14 cases is attached as 
Exhibit “D”). Of the 29 sample files, 13 of the files sole issue during the OIG audit was the lack 
of evidence in the case file to support the child was given clothing upon arrival. Assuming 
arguendo that OIG concurs with His House that the clothing" documentation is acceptable, then 
the number of files with documentation errors is reduced to 16 files (as opposed to 29), and 
approximately 21% of the children (as opposed to 39%). This will also reduce the total number 
of children from approximately 724 to 398. Similarly this number can be further reduced, if OIG 
gives His House credit on other supporting documentation provided by His House in this 
response. 
Sponsor Placement Decisions: OIG found that in 3 of the 29 sample files, release 
recommendations maintained in the UAC case file were incomplete. One of the examples 
provided in the OIG report (OIG Sample #9) states that the His House Case Manager and the 
Case Coordinator offered different release recommendations to the FFS when they recommended 
that the child be released to a sponsor. The recommendation of the Case Manager and the Case 
Coordinator to the FFS was the same person, “the grandfather's nephew.” In the section titled 
"Provide Details on Relationship including Official Documentation" the Case Manager clearly 
refers to the sponsor as the "grandfather's nephew." Unfortunately, the Case Manager makes a 
mistake in the “Comment" section under her name and writes "his biological sister", however 
when reviewing the entire file with all of the supporting documentation, it is clear that the 
sponsor was the grandfather's nephew and the recommendation by both the Case Manager and 
the Case Coordinator to the FFS was the same. 
The second sample (OIG Sample #49) provided in the report was the lack of documentation in the case 
file to indicate that post-release services were provided to a sponsor once the child was released from His 
House. The 

 20000 N.W. 47th Avenue, Miami, FL 33055 (T) 305.430.0085 
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(A-04-16-03566) 
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 Office of Inspector General Note—The deleted text has been redacted because it is personally 
identifiable information. 
 

 files on a monthly basis. These steps will be incorporated into the above referenced policy and 
procedure. 

FINDING #2 ALTHOUGH TRANSACTIONS WERE ALLOWABLE, HIS 
HOUSE HAD DEFICIENCIES WITHIN ITS FINANCIAL MANAGEMENT 
AND PROPERTY CONTROL SYSTEMS. 
His House disagrees with the OIG findings that Federal funds were at risk for potential 
mismanagement or misappropriations. His House had an independent audit conducted by 
the accounting firm of Shariff, Wittmer, Kurtz, Jackson & Diaz, for fiscal year 2013 - 
2014. The audit report did not identify any material weaknesses, or any significant 
deficiencies that could be considered material weaknesses. 
1.) His House lacked documentation and a methodology for payment 
management system drawdowns. 

a. His House was drawing down funds based on expenses obtained 
through expense reports on a monthly basis. Cash was drawn down when there were enough 
expenses incurred to justify the drawdown. For fiscal year 2013-14, there were a few instances 
where we recorded the invoice with a date subsequent to the drawdown within the actual month. 
However, the expenses at this point were already incurred and paid for. 
b. At present, each month is undergoing a month-end closing procedure 
where drawdowns are executed only after all the analysis is performed. This usually occurs 
somewhere between 10th and 15th day of the next month. Indirect cost expenses are usually 
drawn down after the 15th of the month. 

2.) His House's financial accounting system was not able to specifically 
identify expenditures for its shelter care cooperative agreement. 
At present, the UAC grants and other cooperative agreements are classified with their own department as 
well as their own project code to differentiate revenues and expenses from other organization funds. 

3.) His House had inadequate and improperly implemented segregation of 
duties. 

a. At present, the Finance Department's job is only to process payroll. 
b. Access and changes to employee fields are performed by the HR 
Department. 

20000 N.W. 47th Avenue, Miami, FL 33055 (T) 305.430.00 85 
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c. His House has one employee for each of the following positions: 
accounts receivable, accounts payable, and payroll. There is also a manager to oversee and post 
transactions on daily basis, and another person to help with the handling of petty cash and other minor 
accounts. 

d. Internal control procedures have been revised by the annual auditing 
company and there have been no findings as of today. 

4.) His House had inaccurate and delayed recording of accounting 
transactions 
a. Presently, payroll is processed by ADP. It is completely revised by a 

payroll manager before submittal. 
b. Thereafter, ADP generates a report where all the proper accounts and 

project codes are used to label each employee payroll transaction. 
The report is downloaded and imported into our accounting system, thus eliminating the 
need to record the entry to a miscellaneous account 

d. Credit card transactions are currently segregated by 
employee/department. Credit card expenses are preapproved by a manager before they are 
incurred. UAC employees can only incur UAC related expenses. Each credit card receipt is 
collected and matched to the monthly credit card statement and reviewed by the corresponding 
manager/director for accuracy. 

e. Once the month period is closed, no other transactions are posted to it. 

f. His House has implemented new policies and procedures approved by 
our board members addressing all expense transactions. 
5.) His House had inadequate physical control over vulnerable assets. 

a. Presently, His House has added the fixed assets module to its 
accounting  system  "Financial  Edge”.  A  complete  inventory  of  fixed  assets  has  been  performed 
and adjustments have been made. All assets are properly depreciated on a monthly basis. 

b. His House has implemented new policies and procedures approved by 
our board members addressing the fixed assets. The new policies are in alignment with ORR standards 
(45 CFR 74.21(b)(3)). 

20000 N.W. 47th Avenue, Miami, FL 33055 (T) 305.430.0085 
Office of Refugee Resettlement Unaccompanied Children Grantee Review–His House (A-04-16-03566) 

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Pursuant to OIG Finding #2, the following recommendations were made to His House. 

1.) 
His House to update or develop policies and procedures pertaining 
to: 
Maintaining adequate documentation to support its drawdowns of Federal funds and 
to support that its drawdowns are based on actual expenditures. His House CONCURS with this 
recommendation. In August of 2016, His House developed a policy and procedure titled 
Payment Management System, policy number 2-060. The policy was amended in August of 
2017 to allow the Executive Director or the designee to authorize the drawing down of UAC 
funds. 
b. Achieving the segregation of duties such as ensuring limited access to employee data 
maintained in its HR and payroll systems and improved managerial oversight. His House 
CONCURS with this recommendation. In October of 2017, His House amended its Payroll 
policy and procedures (policy number 2-010) to reflect changes addressed in the response above. 
C. Recording financial transactions accurately and timely. His House CONCURS with this 
recommendation. In October of 2017, His House amended its Financial Reporting policy and 
procedures (policy number 2-003) to reflect the changes made in our accounting practices. 
d. Implementing a financial management system that requires adequate identification of 
source and application of Federal funds and effective accountability of property and other assets. 
His House CONCURS with this response, His House amended the following two policies and 
procedures (Fixed Assets (2-008) and Purchasing of Goods and Services (2-017)) to reflect the 
changes made in our accounting practices. 
Sincerely, 

Silvia Smith-Torres 
Silvia Smith-Torres, Executive Director of His House Children's Home 
Enclosure 

20000 N.W. 47th Avenue, Miami, FL 33055 (T) 305.430.0085 
Office of Refugee Resettlement Unaccompanied Children Grantee Review-His House (A-04-16-03566) 
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