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Audit of the Office for Refugees and Immigrants Objectives, Scope, and Methodology

An overview of the purpose and process of auditing the Office for Refugees and Immigrants.

Table of Contents

Overview

In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of certain activities of the Office for Refugees and Immigrants (ORI) for the period July 1, 2020 through June 30, 2022.

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.

Below is a list of our audit objectives, indicating each question we intended our audit to answer; the conclusion we reached regarding each objective; and, if applicable, where each objective is discussed in the audit findings.

ObjectiveConclusion
  1. To what extent did ORI monitor the Refugee Health Assessment Program (RHAP) as required by Section 207 of Chapter 6 of the General Laws and its fiscal year 2021 and 2022 interdepartmental service agreements with the Department of Public Health (DPH)?
To some extent; see Finding 1
  1. To what extent did ORI ensure that health assessment services were available in languages that refugees and immigrants could understand as required by Section 207 of Chapter 6 of the General Laws?
To some extent; see Finding 2
  1. To what extent did ORI monitor the Citizenship for New Americans Program (CNAP) as required by Section 207 of Chapter 6 of the General Laws?
To some extent; see Finding 3

To accomplish our audit objectives, we gained an understanding of the aspects of the internal controls relevant to our objectives by reviewing ORI’s applicable policies and procedures and by interviewing ORI staff members and management. To obtain sufficient, appropriate evidence to address our audit objectives, we performed the procedures described below.

RHAP

To determine to what extent ORI monitored the RHAP as required by Section 207 of Chapter 6 of the General Laws and its fiscal year 2021 and 2022 interdepartmental service agreements with DPH, we took the following actions:

  • We interviewed ORI management.
  • We obtained a list of RHAP providers from ORI. We then cross-referenced this list with DPH’s RHAP Annual Reports for fiscal years 2021 and 2022 to identify all seven RHAP providers that were under contract with ORI during the audit period.
  • We requested documentation of ORI’s reviews of DPH’s Trimester and Annual Reports of the RHAP to determine whether ORI completed these reviews.
  • We obtained and reviewed ORI’s site visit reports of RHAP providers to determine whether ORI held site visits with all seven RHAP providers during each fiscal year within the audit period.
  • We requested ORI’s site visit reports of DPH to determine whether ORI monitored DPH’s duties regarding the RHAP.

Based on the results of our testing, we determined that, during the audit period, ORI did not always conduct monitoring activities over the RHAP. For more information, see Finding 1.

Health Assessment Services

To determine to what extent ORI ensured that health assessment services were available in languages that refugees and immigrants could understand as required by Section 207 of Chapter 6 of the General Laws, we took the following actions. We selected a random, nonstatistical2 sample of 73 RHAP health assessment forms from a population of 2,072 health assessment forms that were completed during the audit period and determined whether interpretation services were provided to refugees.

Based on the results of our testing, we determined that, during the audit period, ORI did not always ensure that health assessments were available in languages that refugees could understand. For more information, see Finding 2.

CNAP

To determine to what extent ORI monitored the CNAP as required by Section 207 of Chapter 6 of the General Laws, we took the following actions:

  • We interviewed ORI management.
  • We obtained a list of CNAP providers from ORI. We then cross-referenced this list with ORI’s Community Partners Directory, which documents all ORI programs and providers of those programs, to identify all 17 CNAP providers that were under contract with ORI during the audit period.
  • We requested documentation of ORI’s kickoff conference calls with CNAP providers.
  • We reviewed ORI’s desk review reports of CNAP providers.
  • We reviewed ORI’s site visit reports of CNAP providers.
  • We requested documentation of ORI’s fiscal year close conference calls with CNAP providers.

Based on the results of our testing, we determined that, during the audit period, ORI did not always monitor the CNAP as required by Section 207 of Chapter 6 of the General Laws. For more information, see Finding 3.

We used nonstatistical sampling methods for testing and therefore did not project the results of our testing to any population. 

Data Reliability Assessment

ORI provided us with the [Office of Refugee Resettlement (ORR)]-5 Refugee Data Submission System for Formula Fund Allocations reports3 that ORI submitted during the audit period, which include information such as each refugee’s name, identification numbers (which ORR-5 reports refer to as alien numbers), each refugee’s date of birth, and the date of each refugee’s health assessment(s). We performed validity and integrity tests on all ORR‑5 information, including (1) scanning for duplicate records, (2) testing for blank fields, (3) testing for data validity errors (i.e., that fields are formatted correctly), and (4) looking for dates outside of the audit period. To determine the completeness and accuracy of the information, we selected a judgmental sample of 30 refugee records from ORR-5 reports and vouched4 certain fields, including identification numbers, dates of birth, arrival dates, and health assessment dates, to the fields in corresponding health assessment forms. We found that 7 out of 30 refugee records from ORR-5 reports did not have matching identification numbers, dates of birth, and/or arrival dates as listed on the corresponding health assessment form.

We also selected a judgmental sample of 20 health assessment forms and traced certain fields, including identification numbers, dates of birth, arrival dates, and health assessment dates, to corresponding records in the ORR-5 reports. We found that 13 out of 20 health assessment forms did not have matching identification numbers, dates of birth, arrival dates, and/or health assessment dates as listed in the ORR‑5 reports. The ORR-5 reports were the only source of data to identify the population of RHAP participants.

Based on the results of the data reliability assessment procedures described above, we determined that the information we obtained, except for the issues noted above (which were discussed with ORI), was sufficiently reliable for the purposes of our audit.

2.    Auditors use nonstatistical sampling to select items for audit testing when a population is very small, the population items are not similar enough, or there are specific items in the population that the auditors want to review.

3.    ORI annually submits these reports to the federal ORR, which provides oversight for federal and state refugee programs. The purpose of these reports is to track information such as how many people participate in the RHAP, how many health assessments participants received, and how many health assessments were completed within 90 days of each participant’s entry into the United States.

4.    Vouching is the inspection of supporting documentation to corroborate data.

Date published: November 14, 2024

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