Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-005
Compliance Requirement: Subrecipient Monitoring
Criteria: The Uniform Guidance outlines various requirements for pass-through entities in Section 200.331, including the following items:
a) ensuring all subawards are clearly identify to the subrecipient as a subaward and include certain required information;
b) evaluate each subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring;
c) consider imposing specific subaward conditions upon a subrecipient, if appropriate;
d) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations and the terms and conditions of the subaward;
e) depending on the pass-through entity's assessment of risk posed by the subrecipient, perform appropriate monitoring of the subrecipient;
f) verify that every subrecipient is audited as required by Subpart F of the Uniform Guidance;
g) consider whether the results of the subrecipient's audits, on-site reviews or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records, and;
h) consider taking enforcement actions against noncompliance subrecipients as described in Uniform Guidance section 200.338.
Condition/Context: The County does not have a formal risk assessment process, subrecipient monitoring policy or oversight program in place to monitor its subrecipients as required under the Uniform Guidance.
Questioned Costs: N/A
Effect: The County cannot be assured that the subrecipient complied with the program requirements, nor can it determine whether there should be adjustments to the County's records.
Cause: The County does not have the required written policies and procedures required by the Uniform Guidance related to subrecipient monitoring and as such, the County personnel overseeing subrecipients did not understand their responsibilities in regards to monitoring subrecipients.
Recommendation: We recommend that the County revise its existing subrecipient agreement to include all of the required data elements under Uniform Guidance section 200.331. Further, we recommend that the County develop and implement the necessary written policies and procedures related to subrecipient monitoring to provide guidance and a formal process for employees to follow when monitoring subrecipients.
Views of Responsible Officials and Planned Corrective Actions: The County understands and will seek to implement the necessary steps on a prospective basis.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-006
Criteria: Title 2 Code of Federal Regulations, Part 200, The Uniform Administrative Guidance, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), requires entities that receive and expend federal financial assistance to have written policies and procedures in place related to certain compliance requirements. Compliance requirements that are affected include allowable costs, cash management and subrecipient monitoring.
Condition/Context: The County has not prepared and implemented these formal, written policies and procedures to align with the requirements of the Uniform Guidance.
Effect: The County is not in compliance with the Uniform Guidance as related to the above mentioned written policies and procedures.
Questioned Costs: None noted.
Cause: The County has not prioritized the preparation and implementation of formal written policies and procedures to align with the Uniform Guidance.
Recommendation: We recommend that the County document, and where applicable, implement policies and procedures that are aligned with the Uniform Guidance to limit the risk for noncompliance with the terms and conditions of its federal award programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-007
Criteria: Pursuant to the provisions of the Uniform Guidance, under section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within 9 months of the end of its fiscal period (September 30) of the following year.
Condition/Context: The County's Single Audit and reporting package was delayed for the year ended December 31, 2022, as a result of turnover within the County, beyond the 9-month due date.
Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements.
Questioned Costs: None noted.
Cause: As a result of turnover within the County, the completion and filing of its December 31, 2022 Single Audit and reporting package was not prioritized.
Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Repeat Finding: N/A
Criteria: The Emergency Rental Assistance Program (ERAP) Reporting Guidance, the Coronavirus Statement and Local Fiscal Recovery Funds (ARPA) Interim Final Rule and Title 2, Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, require that as a condition of receiving federal awards, nonfederal entities agree to maintain internal control processes to provide reasonable assurance of compliance with the requirements. The Reporting Guidance requires periodic reporting at the end of each calendar quarter with a specified reporting due date after the end of the calendar quarter.
Condition/Context: The County's required ERAP report for the quarter ended March 31, 2023 was due to be filed by April 17, 2023. The County filed its report on June 14, 2023, 58 days after the required due date.
The County’s required ARPA report for the quarter ended September 30, 2023 was due to be filed by October 31, 2023. The County filed its report on November 2, 2023, two days after the required due date.
Effect: The County did not comply with its reporting requirements, which may impact future awards.
Questioned Costs: None noted.
Cause: The County did not file its reports within the required due dates.
Recommendation: We recommend that the County revisit its policies and procedures related to reporting to ensure future reports are completed and submitted within the appropriate time period.
Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted within the required time frames.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-006
Criteria: Title 2 Code of Federal Regulations, Part 200, The Uniform Administrative Guidance, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), requires entities that receive and expend federal financial assistance to have written policies and procedures in place related to certain compliance requirements. Compliance requirements that are affected include allowable costs, cash management and subrecipient monitoring.
Condition/Context: The County has not prepared and implemented these formal, written policies and procedures to align with the requirements of the Uniform Guidance.
Effect: The County is not in compliance with the Uniform Guidance as related to the above mentioned written policies and procedures.
Questioned Costs: None noted.
Cause: The County has not prioritized the preparation and implementation of formal written policies and procedures to align with the Uniform Guidance.
Recommendation: We recommend that the County document, and where applicable, implement policies and procedures that are aligned with the Uniform Guidance to limit the risk for noncompliance with the terms and conditions of its federal award programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-007
Criteria: Pursuant to the provisions of the Uniform Guidance, under section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within 9 months of the end of its fiscal period (September 30) of the following year.
Condition/Context: The County's Single Audit and reporting package was delayed for the year ended December 31, 2022, as a result of turnover within the County, beyond the 9-month due date.
Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements.
Questioned Costs: None noted.
Cause: As a result of turnover within the County, the completion and filing of its December 31, 2022 Single Audit and reporting package was not prioritized.
Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-006
Criteria: Title 2 Code of Federal Regulations, Part 200, The Uniform Administrative Guidance, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), requires entities that receive and expend federal financial assistance to have written policies and procedures in place related to certain compliance requirements. Compliance requirements that are affected include allowable costs, cash management and subrecipient monitoring.
Condition/Context: The County has not prepared and implemented these formal, written policies and procedures to align with the requirements of the Uniform Guidance.
Effect: The County is not in compliance with the Uniform Guidance as related to the above mentioned written policies and procedures.
Questioned Costs: None noted.
Cause: The County has not prioritized the preparation and implementation of formal written policies and procedures to align with the Uniform Guidance.
Recommendation: We recommend that the County document, and where applicable, implement policies and procedures that are aligned with the Uniform Guidance to limit the risk for noncompliance with the terms and conditions of its federal award programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-007
Criteria: Pursuant to the provisions of the Uniform Guidance, under section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within 9 months of the end of its fiscal period (September 30) of the following year.
Condition/Context: The County's Single Audit and reporting package was delayed for the year ended December 31, 2022, as a result of turnover within the County, beyond the 9-month due date.
Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements.
Questioned Costs: None noted.
Cause: As a result of turnover within the County, the completion and filing of its December 31, 2022 Single Audit and reporting package was not prioritized.
Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-006
Criteria: Title 2 Code of Federal Regulations, Part 200, The Uniform Administrative Guidance, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), requires entities that receive and expend federal financial assistance to have written policies and procedures in place related to certain compliance requirements. Compliance requirements that are affected include allowable costs, cash management and subrecipient monitoring.
Condition/Context: The County has not prepared and implemented these formal, written policies and procedures to align with the requirements of the Uniform Guidance.
Effect: The County is not in compliance with the Uniform Guidance as related to the above mentioned written policies and procedures.
Questioned Costs: None noted.
Cause: The County has not prioritized the preparation and implementation of formal written policies and procedures to align with the Uniform Guidance.
Recommendation: We recommend that the County document, and where applicable, implement policies and procedures that are aligned with the Uniform Guidance to limit the risk for noncompliance with the terms and conditions of its federal award programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-007
Criteria: Pursuant to the provisions of the Uniform Guidance, under section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within 9 months of the end of its fiscal period (September 30) of the following year.
Condition/Context: The County's Single Audit and reporting package was delayed for the year ended December 31, 2022, as a result of turnover within the County, beyond the 9-month due date.
Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements.
Questioned Costs: None noted.
Cause: As a result of turnover within the County, the completion and filing of its December 31, 2022 Single Audit and reporting package was not prioritized.
Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Repeat Finding: N/A
Criteria: The Emergency Rental Assistance Program (ERAP) Reporting Guidance, the Coronavirus Statement and Local Fiscal Recovery Funds (ARPA) Interim Final Rule and Title 2, Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, require that as a condition of receiving federal awards, nonfederal entities agree to maintain internal control processes to provide reasonable assurance of compliance with the requirements. The Reporting Guidance requires periodic reporting at the end of each calendar quarter with a specified reporting due date after the end of the calendar quarter.
Condition/Context: The County's required ERAP report for the quarter ended March 31, 2023 was due to be filed by April 17, 2023. The County filed its report on June 14, 2023, 58 days after the required due date.
The County’s required ARPA report for the quarter ended September 30, 2023 was due to be filed by October 31, 2023. The County filed its report on November 2, 2023, two days after the required due date.
Effect: The County did not comply with its reporting requirements, which may impact future awards.
Questioned Costs: None noted.
Cause: The County did not file its reports within the required due dates.
Recommendation: We recommend that the County revisit its policies and procedures related to reporting to ensure future reports are completed and submitted within the appropriate time period.
Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted within the required time frames.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Repeat Finding: N/A
Criteria: The Emergency Rental Assistance Program (ERAP) Reporting Guidance, the Coronavirus Statement and Local Fiscal Recovery Funds (ARPA) Interim Final Rule and Title 2, Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, require that as a condition of receiving federal awards, nonfederal entities agree to maintain internal control processes to provide reasonable assurance of compliance with the requirements. The Reporting Guidance requires periodic reporting at the end of each calendar quarter with a specified reporting due date after the end of the calendar quarter.
Condition/Context: The County's required ERAP report for the quarter ended March 31, 2023 was due to be filed by April 17, 2023. The County filed its report on June 14, 2023, 58 days after the required due date.
The County’s required ARPA report for the quarter ended September 30, 2023 was due to be filed by October 31, 2023. The County filed its report on November 2, 2023, two days after the required due date.
Effect: The County did not comply with its reporting requirements, which may impact future awards.
Questioned Costs: None noted.
Cause: The County did not file its reports within the required due dates.
Recommendation: We recommend that the County revisit its policies and procedures related to reporting to ensure future reports are completed and submitted within the appropriate time period.
Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted within the required time frames.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Repeat Finding: N/A
Criteria: The Emergency Rental Assistance Program (ERAP) Reporting Guidance, the Coronavirus Statement and Local Fiscal Recovery Funds (ARPA) Interim Final Rule and Title 2, Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, require that as a condition of receiving federal awards, nonfederal entities agree to maintain internal control processes to provide reasonable assurance of compliance with the requirements. The Reporting Guidance requires periodic reporting at the end of each calendar quarter with a specified reporting due date after the end of the calendar quarter.
Condition/Context: The County's required ERAP report for the quarter ended March 31, 2023 was due to be filed by April 17, 2023. The County filed its report on June 14, 2023, 58 days after the required due date.
The County’s required ARPA report for the quarter ended September 30, 2023 was due to be filed by October 31, 2023. The County filed its report on November 2, 2023, two days after the required due date.
Effect: The County did not comply with its reporting requirements, which may impact future awards.
Questioned Costs: None noted.
Cause: The County did not file its reports within the required due dates.
Recommendation: We recommend that the County revisit its policies and procedures related to reporting to ensure future reports are completed and submitted within the appropriate time period.
Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted within the required time frames.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-005
Compliance Requirement: Subrecipient Monitoring
Criteria: The Uniform Guidance outlines various requirements for pass-through entities in Section 200.331, including the following items:
a) ensuring all subawards are clearly identify to the subrecipient as a subaward and include certain required information;
b) evaluate each subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring;
c) consider imposing specific subaward conditions upon a subrecipient, if appropriate;
d) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations and the terms and conditions of the subaward;
e) depending on the pass-through entity's assessment of risk posed by the subrecipient, perform appropriate monitoring of the subrecipient;
f) verify that every subrecipient is audited as required by Subpart F of the Uniform Guidance;
g) consider whether the results of the subrecipient's audits, on-site reviews or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records, and;
h) consider taking enforcement actions against noncompliance subrecipients as described in Uniform Guidance section 200.338.
Condition/Context: The County does not have a formal risk assessment process, subrecipient monitoring policy or oversight program in place to monitor its subrecipients as required under the Uniform Guidance.
Questioned Costs: N/A
Effect: The County cannot be assured that the subrecipient complied with the program requirements, nor can it determine whether there should be adjustments to the County's records.
Cause: The County does not have the required written policies and procedures required by the Uniform Guidance related to subrecipient monitoring and as such, the County personnel overseeing subrecipients did not understand their responsibilities in regards to monitoring subrecipients.
Recommendation: We recommend that the County revise its existing subrecipient agreement to include all of the required data elements under Uniform Guidance section 200.331. Further, we recommend that the County develop and implement the necessary written policies and procedures related to subrecipient monitoring to provide guidance and a formal process for employees to follow when monitoring subrecipients.
Views of Responsible Officials and Planned Corrective Actions: The County understands and will seek to implement the necessary steps on a prospective basis.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-006
Criteria: Title 2 Code of Federal Regulations, Part 200, The Uniform Administrative Guidance, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), requires entities that receive and expend federal financial assistance to have written policies and procedures in place related to certain compliance requirements. Compliance requirements that are affected include allowable costs, cash management and subrecipient monitoring.
Condition/Context: The County has not prepared and implemented these formal, written policies and procedures to align with the requirements of the Uniform Guidance.
Effect: The County is not in compliance with the Uniform Guidance as related to the above mentioned written policies and procedures.
Questioned Costs: None noted.
Cause: The County has not prioritized the preparation and implementation of formal written policies and procedures to align with the Uniform Guidance.
Recommendation: We recommend that the County document, and where applicable, implement policies and procedures that are aligned with the Uniform Guidance to limit the risk for noncompliance with the terms and conditions of its federal award programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-007
Criteria: Pursuant to the provisions of the Uniform Guidance, under section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within 9 months of the end of its fiscal period (September 30) of the following year.
Condition/Context: The County's Single Audit and reporting package was delayed for the year ended December 31, 2022, as a result of turnover within the County, beyond the 9-month due date.
Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements.
Questioned Costs: None noted.
Cause: As a result of turnover within the County, the completion and filing of its December 31, 2022 Single Audit and reporting package was not prioritized.
Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Repeat Finding: N/A
Criteria: The Emergency Rental Assistance Program (ERAP) Reporting Guidance, the Coronavirus Statement and Local Fiscal Recovery Funds (ARPA) Interim Final Rule and Title 2, Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, require that as a condition of receiving federal awards, nonfederal entities agree to maintain internal control processes to provide reasonable assurance of compliance with the requirements. The Reporting Guidance requires periodic reporting at the end of each calendar quarter with a specified reporting due date after the end of the calendar quarter.
Condition/Context: The County's required ERAP report for the quarter ended March 31, 2023 was due to be filed by April 17, 2023. The County filed its report on June 14, 2023, 58 days after the required due date.
The County’s required ARPA report for the quarter ended September 30, 2023 was due to be filed by October 31, 2023. The County filed its report on November 2, 2023, two days after the required due date.
Effect: The County did not comply with its reporting requirements, which may impact future awards.
Questioned Costs: None noted.
Cause: The County did not file its reports within the required due dates.
Recommendation: We recommend that the County revisit its policies and procedures related to reporting to ensure future reports are completed and submitted within the appropriate time period.
Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted within the required time frames.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-006
Criteria: Title 2 Code of Federal Regulations, Part 200, The Uniform Administrative Guidance, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), requires entities that receive and expend federal financial assistance to have written policies and procedures in place related to certain compliance requirements. Compliance requirements that are affected include allowable costs, cash management and subrecipient monitoring.
Condition/Context: The County has not prepared and implemented these formal, written policies and procedures to align with the requirements of the Uniform Guidance.
Effect: The County is not in compliance with the Uniform Guidance as related to the above mentioned written policies and procedures.
Questioned Costs: None noted.
Cause: The County has not prioritized the preparation and implementation of formal written policies and procedures to align with the Uniform Guidance.
Recommendation: We recommend that the County document, and where applicable, implement policies and procedures that are aligned with the Uniform Guidance to limit the risk for noncompliance with the terms and conditions of its federal award programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-007
Criteria: Pursuant to the provisions of the Uniform Guidance, under section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within 9 months of the end of its fiscal period (September 30) of the following year.
Condition/Context: The County's Single Audit and reporting package was delayed for the year ended December 31, 2022, as a result of turnover within the County, beyond the 9-month due date.
Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements.
Questioned Costs: None noted.
Cause: As a result of turnover within the County, the completion and filing of its December 31, 2022 Single Audit and reporting package was not prioritized.
Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-006
Criteria: Title 2 Code of Federal Regulations, Part 200, The Uniform Administrative Guidance, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), requires entities that receive and expend federal financial assistance to have written policies and procedures in place related to certain compliance requirements. Compliance requirements that are affected include allowable costs, cash management and subrecipient monitoring.
Condition/Context: The County has not prepared and implemented these formal, written policies and procedures to align with the requirements of the Uniform Guidance.
Effect: The County is not in compliance with the Uniform Guidance as related to the above mentioned written policies and procedures.
Questioned Costs: None noted.
Cause: The County has not prioritized the preparation and implementation of formal written policies and procedures to align with the Uniform Guidance.
Recommendation: We recommend that the County document, and where applicable, implement policies and procedures that are aligned with the Uniform Guidance to limit the risk for noncompliance with the terms and conditions of its federal award programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-007
Criteria: Pursuant to the provisions of the Uniform Guidance, under section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within 9 months of the end of its fiscal period (September 30) of the following year.
Condition/Context: The County's Single Audit and reporting package was delayed for the year ended December 31, 2022, as a result of turnover within the County, beyond the 9-month due date.
Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements.
Questioned Costs: None noted.
Cause: As a result of turnover within the County, the completion and filing of its December 31, 2022 Single Audit and reporting package was not prioritized.
Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-006
Criteria: Title 2 Code of Federal Regulations, Part 200, The Uniform Administrative Guidance, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), requires entities that receive and expend federal financial assistance to have written policies and procedures in place related to certain compliance requirements. Compliance requirements that are affected include allowable costs, cash management and subrecipient monitoring.
Condition/Context: The County has not prepared and implemented these formal, written policies and procedures to align with the requirements of the Uniform Guidance.
Effect: The County is not in compliance with the Uniform Guidance as related to the above mentioned written policies and procedures.
Questioned Costs: None noted.
Cause: The County has not prioritized the preparation and implementation of formal written policies and procedures to align with the Uniform Guidance.
Recommendation: We recommend that the County document, and where applicable, implement policies and procedures that are aligned with the Uniform Guidance to limit the risk for noncompliance with the terms and conditions of its federal award programs.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2022-007
Criteria: Pursuant to the provisions of the Uniform Guidance, under section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within 9 months of the end of its fiscal period (September 30) of the following year.
Condition/Context: The County's Single Audit and reporting package was delayed for the year ended December 31, 2022, as a result of turnover within the County, beyond the 9-month due date.
Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements.
Questioned Costs: None noted.
Cause: As a result of turnover within the County, the completion and filing of its December 31, 2022 Single Audit and reporting package was not prioritized.
Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes.
Views of Responsible Officials and Planned Corrective Actions: Management agrees and will look to address in 2024. See the County's full response in its corrective action plan.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Repeat Finding: N/A
Criteria: The Emergency Rental Assistance Program (ERAP) Reporting Guidance, the Coronavirus Statement and Local Fiscal Recovery Funds (ARPA) Interim Final Rule and Title 2, Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, require that as a condition of receiving federal awards, nonfederal entities agree to maintain internal control processes to provide reasonable assurance of compliance with the requirements. The Reporting Guidance requires periodic reporting at the end of each calendar quarter with a specified reporting due date after the end of the calendar quarter.
Condition/Context: The County's required ERAP report for the quarter ended March 31, 2023 was due to be filed by April 17, 2023. The County filed its report on June 14, 2023, 58 days after the required due date.
The County’s required ARPA report for the quarter ended September 30, 2023 was due to be filed by October 31, 2023. The County filed its report on November 2, 2023, two days after the required due date.
Effect: The County did not comply with its reporting requirements, which may impact future awards.
Questioned Costs: None noted.
Cause: The County did not file its reports within the required due dates.
Recommendation: We recommend that the County revisit its policies and procedures related to reporting to ensure future reports are completed and submitted within the appropriate time period.
Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted within the required time frames.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Repeat Finding: N/A
Criteria: The Emergency Rental Assistance Program (ERAP) Reporting Guidance, the Coronavirus Statement and Local Fiscal Recovery Funds (ARPA) Interim Final Rule and Title 2, Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, require that as a condition of receiving federal awards, nonfederal entities agree to maintain internal control processes to provide reasonable assurance of compliance with the requirements. The Reporting Guidance requires periodic reporting at the end of each calendar quarter with a specified reporting due date after the end of the calendar quarter.
Condition/Context: The County's required ERAP report for the quarter ended March 31, 2023 was due to be filed by April 17, 2023. The County filed its report on June 14, 2023, 58 days after the required due date.
The County’s required ARPA report for the quarter ended September 30, 2023 was due to be filed by October 31, 2023. The County filed its report on November 2, 2023, two days after the required due date.
Effect: The County did not comply with its reporting requirements, which may impact future awards.
Questioned Costs: None noted.
Cause: The County did not file its reports within the required due dates.
Recommendation: We recommend that the County revisit its policies and procedures related to reporting to ensure future reports are completed and submitted within the appropriate time period.
Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted within the required time frames.
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
U.S. Department of Treasury, Assistance Listing # 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Repeat Finding: N/A
Criteria: The Emergency Rental Assistance Program (ERAP) Reporting Guidance, the Coronavirus Statement and Local Fiscal Recovery Funds (ARPA) Interim Final Rule and Title 2, Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, require that as a condition of receiving federal awards, nonfederal entities agree to maintain internal control processes to provide reasonable assurance of compliance with the requirements. The Reporting Guidance requires periodic reporting at the end of each calendar quarter with a specified reporting due date after the end of the calendar quarter.
Condition/Context: The County's required ERAP report for the quarter ended March 31, 2023 was due to be filed by April 17, 2023. The County filed its report on June 14, 2023, 58 days after the required due date.
The County’s required ARPA report for the quarter ended September 30, 2023 was due to be filed by October 31, 2023. The County filed its report on November 2, 2023, two days after the required due date.
Effect: The County did not comply with its reporting requirements, which may impact future awards.
Questioned Costs: None noted.
Cause: The County did not file its reports within the required due dates.
Recommendation: We recommend that the County revisit its policies and procedures related to reporting to ensure future reports are completed and submitted within the appropriate time period.
Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted within the required time frames.