Florence Crittenton Services of Orange County, Inc., Did Not Always Claim Expenditures in Accordance With Federal Requirements

Florence Crittenton Services of Orange County, Inc. (Crittenton), an Unaccompanied Alien Children (UAC) program grantee located in Fullerton, California, did not always claim expenditures in accordance with applicable Federal requirements. Of the 135 sampled expenditure transactions that Crittenton claimed during fiscal years (FYs) 2014 and 2015, 90'transactions were allowable; however, 28 contained deficiencies, resulting in unallowable expenditures of $259,671 for employee-related and other costs. In addition to our sample results, we found that Crittenton claimed unallowable expenditures of $53,470 for equipment. In total, Crittenton claimed unallowable expenditures of $342,263, including $29,122 of unallowable indirect costs.

For the remaining 17 of the 135 sampled transactions, Crittenton did not identify and claim actual expenditures incurred for certain services and shelter care provided to UAC. Instead, Crittenton used rates that the Office of Refugee Resettlement (ORR) had not approved to calculate the amount to claim these expenditures. We have set aside all of the expenditures claimed for these services and shelter care, totaling $3.2 million (including $276,625 of indirect costs), for resolution by ORR and Crittenton.

We recommended that Crittenton (1) refund to the Federal Government $342,263 for unallowable expenditures claimed; (2) work with ORR to determine what portion of the $3.2 million claimed was unallowable and refund to the Federal Government the unallowable amount; (3) review its claimed expenditures for FY 2016 (the third year of the grant awards) to determine whether they were claimed in accordance with Federal requirements and refund to the Federal Government any unallowable amount; (4) strengthen its oversight, through additional supervisory review, of expenditures charged to grant awards to ensure that they are claimed in accordance with Federal requirements; and (5) implement adequate policies and procedures to ensure that it identifies and claims actual expenditures incurred for services and shelter care provided to UAC.

In written comments on our draft report, Crittenton stated that it largely disagreed with our methodology, findings, and recommendations. Crittenton provided information on actions that it had taken or planned to take to address our third, fourth, and fifth recommendations. After reviewing Crittenton's comments, we maintain that our findings and recommendations are valid.