Seattle Refugee Services: ORR Compliance Software

Seattle is one of the long-established refugee resettlement markets in the United States, with multiple affiliates of the nine national resettlement agencies operating in the metro region. Federal funding for refugee services arrives through two distinct channels with different compliance regimes operating in parallel: State Department PRM through Reception and Placement cooperative agreements (national-agency-to-affiliate), and HHS ORR through programs administered partly directly and partly through Washington State DSHS Office of Refugee and Immigrant Assistance.

For a Seattle agency running a typical mix - R&P, Matching Grant, an RSS contract through DSHS, possibly Preferred Communities, plus foundation and individual support - the compliance work is per-client, time-bounded, and dense.

R&P: per-capita and per-client by design

State Department PRM awards R&P cooperative agreements to the nine national agencies. Each agency operates a network of local affiliates that handle case-level service delivery. Funds flow per-capita: a defined per-refugee amount that the receiving agency must use to deliver core pre-arrival and post-arrival services within 90 days of arrival.

The 90-day service window is the central R&P compliance feature. Costs charged to the R&P grant for a specific refugee must be incurred during that refugee’s 90-day window. Services delivered must be documented with the refugee’s case file. The case manager’s time, the housing setup costs, the orientation services, the cash assistance - all must be tracked at the client level.

Aggregate fund balances at the affiliate level are not sufficient. PRM monitoring will sample arrivals, walk through their case files, and reconcile services delivered to the per-capita grant. Affiliates that maintain financial records aggregated by program - without a path to the individual client - cannot produce the reconciliation that monitoring requires.

The R&P per-capita amount has changed over time as PRM has updated the cooperative agreement structure and as Congress has appropriated different levels of refugee assistance. Affiliates should rely on the current cooperative agreement and applicable PRM guidance for the actual per-capita rate, which is set by PRM and not by the affiliate.

Matching Grant: outcome-driven employment focus

ORR’s Matching Grant program is a time-limited employment-focused alternative to public cash assistance. The federal funds are matched by non-federal resources at specified ratios. Participants must achieve self-sufficiency - employment with earnings at or above federal poverty guidelines - within 120 to 180 days of enrollment depending on the iteration of the program guidance.

Compliance under MG is per-participant: enrollment documentation, services delivered, job placements, employment verification (with employer name, hire date, hours, wage, and reason for any termination), and the federal-non-federal match record. ORR reports outcomes through its online reporting system, and agencies must maintain underlying records that support the reported outcomes.

The match documentation is operationally challenging. In-kind contributions (donated furniture, donated services, volunteer labor) must be documented at fair market value as they are received and delivered. Match records assembled retroactively at the end of a participant’s enrollment frequently fall short of the documentation standard.

RSS, RCA, and RMA through Washington DSHS

Washington State administers federal refugee assistance through the DSHS Office of Refugee and Immigrant Assistance (ORIA). RSS funds employment services, English language training, case management, and related services through subgrants to provider organizations. RCA is a cash assistance program for refugees not categorically eligible for TANF, administered as a benefit through DSHS. RMA is medical assistance for refugees, administered through the state Medicaid agency.

For Seattle providers, RSS contracts are typical: an annual or multi-year contract from DSHS to deliver specified services to a contracted client volume, with cost reimbursement or unit-rate billing and quarterly performance reporting. The federal regulations at 45 CFR Part 400 cascade through the DSHS contract. Subrecipients are subject to 2 CFR 200 Subpart E cost principles and the HHS adoption at 45 CFR Part 75 for the federal portion.

Match and cost-share for RSS, where required, follows the same eligibility rules as other federal awards: non-federal sources only, documented contemporaneously, tied to project activity. Cost allocation across RSS and other refugee programs (R&P, MG, Preferred Communities) requires care: a service delivered to a refugee under RSS funding cannot be double-charged to R&P or MG.

The 45 CFR Part 75 cost framework and time and effort

The Uniform Guidance at 2 CFR 200 is adopted by HHS at 45 CFR Part 75 with HHS-specific provisions. For refugee resettlement nonprofits, this means the standard federal cost framework: allowability, allocability, reasonableness, consistent treatment.

For staff working across multiple funding streams (a case manager who serves R&P clients in their first 90 days and then continues with the same clients under Matching Grant or RSS), personnel cost allocation requires contemporaneous time and effort documentation under 2 CFR 200.430(i) (or the parallel HHS adoption). The allocation can be by client, by service activity, or by program - but it must be supported by records that reflect actual work performed and reconciled to the percentages used for payroll allocation.

For non-personnel shared costs (rent for the office, utilities, IT, supplies), the cost allocation methodology must be written, applied consistently, and grounded in drivers consistent with Subpart E of 2 CFR 200.

Single Audit and the federal threshold

Seattle refugee resettlement affiliates expending $1,000,000 or more in federal awards in a fiscal year (effective for fiscal years ending on or after October 1, 2024) are subject to Single Audit under 2 CFR 200 Subpart F. For most affiliates running R&P, MG, and an RSS contract, this threshold is regularly met.

The Single Audit will identify major federal programs through risk assessment and test compliance with cost principles, allowability, period of performance, performance reporting, eligibility, special tests and provisions specific to the program, and other requirements specified in the OMB Compliance Supplement for refugee programs. The R&P 90-day service window and the Matching Grant employment outcomes show up in audit testing as program-specific compliance requirements, not generic federal grant requirements.

The audit prep checklist is a useful structure for finance teams.

Volume volatility and the Presidential Determination

Refugee admissions volume is set annually through the Presidential Determination on refugee admissions, which establishes the ceiling for the federal fiscal year. Actual arrivals depend on case processing, security clearances, country conditions, and operational capacity, and can vary substantially year to year - and within a given year, by quarter.

For Seattle agencies, this means revenue from R&P (which is per-capita) is volatile. Staffing decisions made on prior-year arrival assumptions can leave agencies over-resourced when arrivals slow or under-resourced when arrivals surge. Multi-year arrival data, conservative forecasting, and contingency planning are operational necessities. The financial system needs to support cohort-level analysis - what was the per-capita revenue and per-capita cost for the FY2024 arrival cohort versus the FY2023 cohort - because the per-capita unit economics drive sustainability.

Software profile for a Seattle refugee services agency

The realistic stack is a refugee-specific case management system (or a configurable nonprofit case management system) for client-level intake, services, and outcomes, plus a grants management and accounting system for fund accounting, cost allocation, contract reporting, and financial compliance. The bridge is the per-client, per-program reconciliation: services delivered to a client tracked in case management, with associated costs traced through the financial system to the appropriate funding source.

For Seattle-area private and foundation funder relationships that supplement federal funding, the community foundation grants guide covers the broader funder universe, and the federal awards software shortlist is a starting point for the financial layer.