Finding 2023-002 - Internal Control over Eligibility
Federal Agency: Department of Health and Human Services
Pass-through Agency: Pennsylvania Department of Human Services
Programs: Foster Care Title IV-E – ALN #93.658 and Adoption Assistance Title IV-E – ALN #93.659
Condition: The County’s procedures for determining eligibility does not include an independent review of the files to ensure all required documentation is included and that the determination was performed properly.
Criteria: In accordance with the federal compliance requirements for Foster Care – Title IV-E and Adoption Assistance – Title IV-E, benefits may be paid on behalf of a child only if certain requirements are met. Accordingly, funds may be expended for maintenance payments on behalf of eligible children.
Cause: The County’s process for determining eligibility did not include an independent review of the eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility.
Effect: The deficiency in internal control over eligibility could result in unallowed payments.
Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the County implement procedures to include an independent review of eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility. Such documentation could include the readoption of the previously performed procedure which included the completion and sign off of a checklist of the reviewed documents.
Questioned Costs: None
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2023-002 - Internal Control over Eligibility
Federal Agency: Department of Health and Human Services
Pass-through Agency: Pennsylvania Department of Human Services
Programs: Foster Care Title IV-E – ALN #93.658 and Adoption Assistance Title IV-E – ALN #93.659
Condition: The County’s procedures for determining eligibility does not include an independent review of the files to ensure all required documentation is included and that the determination was performed properly.
Criteria: In accordance with the federal compliance requirements for Foster Care – Title IV-E and Adoption Assistance – Title IV-E, benefits may be paid on behalf of a child only if certain requirements are met. Accordingly, funds may be expended for maintenance payments on behalf of eligible children.
Cause: The County’s process for determining eligibility did not include an independent review of the eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility.
Effect: The deficiency in internal control over eligibility could result in unallowed payments.
Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the County implement procedures to include an independent review of eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility. Such documentation could include the readoption of the previously performed procedure which included the completion and sign off of a checklist of the reviewed documents.
Questioned Costs: None
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2023-002 - Internal Control over Eligibility
Federal Agency: Department of Health and Human Services
Pass-through Agency: Pennsylvania Department of Human Services
Programs: Foster Care Title IV-E – ALN #93.658 and Adoption Assistance Title IV-E – ALN #93.659
Condition: The County’s procedures for determining eligibility does not include an independent review of the files to ensure all required documentation is included and that the determination was performed properly.
Criteria: In accordance with the federal compliance requirements for Foster Care – Title IV-E and Adoption Assistance – Title IV-E, benefits may be paid on behalf of a child only if certain requirements are met. Accordingly, funds may be expended for maintenance payments on behalf of eligible children.
Cause: The County’s process for determining eligibility did not include an independent review of the eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility.
Effect: The deficiency in internal control over eligibility could result in unallowed payments.
Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the County implement procedures to include an independent review of eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility. Such documentation could include the readoption of the previously performed procedure which included the completion and sign off of a checklist of the reviewed documents.
Questioned Costs: None
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2023-002 - Internal Control over Eligibility
Federal Agency: Department of Health and Human Services
Pass-through Agency: Pennsylvania Department of Human Services
Programs: Foster Care Title IV-E – ALN #93.658 and Adoption Assistance Title IV-E – ALN #93.659
Condition: The County’s procedures for determining eligibility does not include an independent review of the files to ensure all required documentation is included and that the determination was performed properly.
Criteria: In accordance with the federal compliance requirements for Foster Care – Title IV-E and Adoption Assistance – Title IV-E, benefits may be paid on behalf of a child only if certain requirements are met. Accordingly, funds may be expended for maintenance payments on behalf of eligible children.
Cause: The County’s process for determining eligibility did not include an independent review of the eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility.
Effect: The deficiency in internal control over eligibility could result in unallowed payments.
Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the County implement procedures to include an independent review of eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility. Such documentation could include the readoption of the previously performed procedure which included the completion and sign off of a checklist of the reviewed documents.
Questioned Costs: None
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring
Federal Agency: Department of Treasury
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – ALN #21.027
Condition: The County did not have a documented risk assessment process for evaluating the subrecipient’s risk of non-compliance. As part of the monitoring process, the County also did not have controls in place to obtain and review the annual audit reports of all subrecipients.
Criteria: 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients.
Cause: There were no procedures in place to document the County’s assessment of risk for subrecipients and the County does not have procedures in place to adequately review the subrecipient audits received.
Effect: The deficiencies in subrecipient monitoring could result in the County not identifying unallowable expenditures being incurred by County subrecipients.
Repeat Finding: This is a repeat finding of 2022-001.
Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the County should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable.
Questioned Costs: Unknown
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate correction action plan.
Finding 2023-001 – Subrecipient Monitoring
Federal Agency: Department of Treasury
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – ALN #21.027
Condition: The County did not have a documented risk assessment process for evaluating the subrecipient’s risk of non-compliance. As part of the monitoring process, the County also did not have controls in place to obtain and review the annual audit reports of all subrecipients.
Criteria: 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients.
Cause: There were no procedures in place to document the County’s assessment of risk for subrecipients and the County does not have procedures in place to adequately review the subrecipient audits received.
Effect: The deficiencies in subrecipient monitoring could result in the County not identifying unallowable expenditures being incurred by County subrecipients.
Repeat Finding: This is a repeat finding of 2022-001.
Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the County should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable.
Questioned Costs: Unknown
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate correction action plan.
Finding 2023-002 - Internal Control over Eligibility
Federal Agency: Department of Health and Human Services
Pass-through Agency: Pennsylvania Department of Human Services
Programs: Foster Care Title IV-E – ALN #93.658 and Adoption Assistance Title IV-E – ALN #93.659
Condition: The County’s procedures for determining eligibility does not include an independent review of the files to ensure all required documentation is included and that the determination was performed properly.
Criteria: In accordance with the federal compliance requirements for Foster Care – Title IV-E and Adoption Assistance – Title IV-E, benefits may be paid on behalf of a child only if certain requirements are met. Accordingly, funds may be expended for maintenance payments on behalf of eligible children.
Cause: The County’s process for determining eligibility did not include an independent review of the eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility.
Effect: The deficiency in internal control over eligibility could result in unallowed payments.
Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the County implement procedures to include an independent review of eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility. Such documentation could include the readoption of the previously performed procedure which included the completion and sign off of a checklist of the reviewed documents.
Questioned Costs: None
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2023-002 - Internal Control over Eligibility
Federal Agency: Department of Health and Human Services
Pass-through Agency: Pennsylvania Department of Human Services
Programs: Foster Care Title IV-E – ALN #93.658 and Adoption Assistance Title IV-E – ALN #93.659
Condition: The County’s procedures for determining eligibility does not include an independent review of the files to ensure all required documentation is included and that the determination was performed properly.
Criteria: In accordance with the federal compliance requirements for Foster Care – Title IV-E and Adoption Assistance – Title IV-E, benefits may be paid on behalf of a child only if certain requirements are met. Accordingly, funds may be expended for maintenance payments on behalf of eligible children.
Cause: The County’s process for determining eligibility did not include an independent review of the eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility.
Effect: The deficiency in internal control over eligibility could result in unallowed payments.
Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the County implement procedures to include an independent review of eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility. Such documentation could include the readoption of the previously performed procedure which included the completion and sign off of a checklist of the reviewed documents.
Questioned Costs: None
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2023-002 - Internal Control over Eligibility
Federal Agency: Department of Health and Human Services
Pass-through Agency: Pennsylvania Department of Human Services
Programs: Foster Care Title IV-E – ALN #93.658 and Adoption Assistance Title IV-E – ALN #93.659
Condition: The County’s procedures for determining eligibility does not include an independent review of the files to ensure all required documentation is included and that the determination was performed properly.
Criteria: In accordance with the federal compliance requirements for Foster Care – Title IV-E and Adoption Assistance – Title IV-E, benefits may be paid on behalf of a child only if certain requirements are met. Accordingly, funds may be expended for maintenance payments on behalf of eligible children.
Cause: The County’s process for determining eligibility did not include an independent review of the eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility.
Effect: The deficiency in internal control over eligibility could result in unallowed payments.
Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the County implement procedures to include an independent review of eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility. Such documentation could include the readoption of the previously performed procedure which included the completion and sign off of a checklist of the reviewed documents.
Questioned Costs: None
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2023-002 - Internal Control over Eligibility
Federal Agency: Department of Health and Human Services
Pass-through Agency: Pennsylvania Department of Human Services
Programs: Foster Care Title IV-E – ALN #93.658 and Adoption Assistance Title IV-E – ALN #93.659
Condition: The County’s procedures for determining eligibility does not include an independent review of the files to ensure all required documentation is included and that the determination was performed properly.
Criteria: In accordance with the federal compliance requirements for Foster Care – Title IV-E and Adoption Assistance – Title IV-E, benefits may be paid on behalf of a child only if certain requirements are met. Accordingly, funds may be expended for maintenance payments on behalf of eligible children.
Cause: The County’s process for determining eligibility did not include an independent review of the eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility.
Effect: The deficiency in internal control over eligibility could result in unallowed payments.
Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the County implement procedures to include an independent review of eligibility files by someone other than the person performing the determination to ensure that the determination was done properly and all required documentation was maintained in the files to support eligibility. Such documentation could include the readoption of the previously performed procedure which included the completion and sign off of a checklist of the reviewed documents.
Questioned Costs: None
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring
Federal Agency: Department of Treasury
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – ALN #21.027
Condition: The County did not have a documented risk assessment process for evaluating the subrecipient’s risk of non-compliance. As part of the monitoring process, the County also did not have controls in place to obtain and review the annual audit reports of all subrecipients.
Criteria: 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients.
Cause: There were no procedures in place to document the County’s assessment of risk for subrecipients and the County does not have procedures in place to adequately review the subrecipient audits received.
Effect: The deficiencies in subrecipient monitoring could result in the County not identifying unallowable expenditures being incurred by County subrecipients.
Repeat Finding: This is a repeat finding of 2022-001.
Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the County should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable.
Questioned Costs: Unknown
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate correction action plan.
Finding 2023-001 – Subrecipient Monitoring
Federal Agency: Department of Treasury
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – ALN #21.027
Condition: The County did not have a documented risk assessment process for evaluating the subrecipient’s risk of non-compliance. As part of the monitoring process, the County also did not have controls in place to obtain and review the annual audit reports of all subrecipients.
Criteria: 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients.
Cause: There were no procedures in place to document the County’s assessment of risk for subrecipients and the County does not have procedures in place to adequately review the subrecipient audits received.
Effect: The deficiencies in subrecipient monitoring could result in the County not identifying unallowable expenditures being incurred by County subrecipients.
Repeat Finding: This is a repeat finding of 2022-001.
Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the County should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable.
Questioned Costs: Unknown
Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate correction action plan.