2024-001 - Uniform Guidance Written Policies/Procedures - Material Weakness/Noncompliance
Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758
Prior Year Finding Number: N/A
Criteria: The Uniform Guidance requires written policies and/or procedures in the areas of allowability of costs, cash management, procurement, travel, conflict of interest and subrecipient monitoring.
Condition/Context: While the Organization has informal policies and procedures surrounding the administration of its federal programs, these policies and procedures have not been formally documented to ensure compliance with the areas of allowability of costs, cash management, procurement, travel, conflict of interest or subrecipient monitoring as required under the Uniform Guidance.
Questioned Costs: N/A
Cause: The Organization has not yet prepared its written policies/procedures required by the Uniform Guidance.
Effect: The Organization is not in compliance with certain requirements of the Uniform Guidance and as such, employees do not currently have the benefit of these written policies and/or procedures to assist in managing and directing its federal award programs.
Recommendation: We recommend that Organization management prepare the required written policies/procedures related to allowability of costs, cash management, procurement, travel, conflict of interest and subrecipient monitoring outlined with the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to formally document the required elements of its policies and procedures pursuant to
the Uniform Guidance.
2024-002 - Subrecipient Monitoring - Material Weakness/Noncompliance
Federal Program: Assistance Listing #16.812 Second Chance Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758
Prior Year Finding Number: N/A
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: While the Organization has informal procedures surrounding the oversight of subrecipients, it does not have a formal risk assessment process in place to determine the extent of subrecipient programmatic oversight as required under the Uniform Guidance, including ensuring that financial information reconciles between the underlying expenditure reports and the subrecipient/Organization audit reports.
Questioned Costs: N/A
Cause: The Organization has not prepared or adopted the written policies / procedures required by Uniform Guidance and as such, the Organization personnel overseeing subrecipients did not understand their responsibilities in regard to monitoring subrecipients.
Effect: The Organization cannot be assured that subrecipients are appropriately understanding and complying with the requirements of the funding stream passed through to them.
Recommendation: We recommend that the Organization revisit its policies and procedures related to subrecipient monitoring and ensure that there are formal subaward agreements with all subrecipients, prepare a formal, initial, risk assessment of each potential subrecipient and document its monitoring activities of each subrecipient.
Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to implement these policies, procedures and activities on a prospective basis.
2024-003 - Reporting - Significant Deficiency
Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758
Prior Year Finding Number: N/A
Criteria: A system of internal control should be in place and operating to ensure that expenditures associated with each program are reliably captured and included on the appropriate quarterly expenditure report, as required by the grantor agency.
Condition/Context: The Organization identified during the preparation of its second quarter 2024 expenditure report approximately $25,000 in costs incurred during November 2022 that had not previously been included in a submitted expenditure report to PCCD. In order to bring its financial reporting of grant activity current, the Organization included these expenditures in its second quarter 2024 expenditure report. While such costs were incurred during the overall program performance period and were allowable and attributable to the program, such costs were not timely identified and reported on the correct expenditure report.
Questioned Costs: N/A
Cause: The Organization originally misidentified the costs as having been associated with a different funding stream that should have been included within the 4th quarter 2022 expenditures report.
Effect: In accurate interim financial reporting, the Organization reported certain costs incurred during November 2022 within the 2nd quarter 2024 expenditures report.
Recommendation: We recommend that Organization management review and update its identification of expenditures by period to ensure the completeness and accuracy of expenditure reporting to grantors.
Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to strengthen its grant expenditure identification to ensure the completeness of required expenditure reports.
2024-001 - Uniform Guidance Written Policies/Procedures - Material Weakness/Noncompliance
Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758
Prior Year Finding Number: N/A
Criteria: The Uniform Guidance requires written policies and/or procedures in the areas of allowability of costs, cash management, procurement, travel, conflict of interest and subrecipient monitoring.
Condition/Context: While the Organization has informal policies and procedures surrounding the administration of its federal programs, these policies and procedures have not been formally documented to ensure compliance with the areas of allowability of costs, cash management, procurement, travel, conflict of interest or subrecipient monitoring as required under the Uniform Guidance.
Questioned Costs: N/A
Cause: The Organization has not yet prepared its written policies/procedures required by the Uniform Guidance.
Effect: The Organization is not in compliance with certain requirements of the Uniform Guidance and as such, employees do not currently have the benefit of these written policies and/or procedures to assist in managing and directing its federal award programs.
Recommendation: We recommend that Organization management prepare the required written policies/procedures related to allowability of costs, cash management, procurement, travel, conflict of interest and subrecipient monitoring outlined with the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to formally document the required elements of its policies and procedures pursuant to
the Uniform Guidance.
2024-002 - Subrecipient Monitoring - Material Weakness/Noncompliance
Federal Program: Assistance Listing #16.812 Second Chance Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758
Prior Year Finding Number: N/A
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: While the Organization has informal procedures surrounding the oversight of subrecipients, it does not have a formal risk assessment process in place to determine the extent of subrecipient programmatic oversight as required under the Uniform Guidance, including ensuring that financial information reconciles between the underlying expenditure reports and the subrecipient/Organization audit reports.
Questioned Costs: N/A
Cause: The Organization has not prepared or adopted the written policies / procedures required by Uniform Guidance and as such, the Organization personnel overseeing subrecipients did not understand their responsibilities in regard to monitoring subrecipients.
Effect: The Organization cannot be assured that subrecipients are appropriately understanding and complying with the requirements of the funding stream passed through to them.
Recommendation: We recommend that the Organization revisit its policies and procedures related to subrecipient monitoring and ensure that there are formal subaward agreements with all subrecipients, prepare a formal, initial, risk assessment of each potential subrecipient and document its monitoring activities of each subrecipient.
Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to implement these policies, procedures and activities on a prospective basis.
2024-003 - Reporting - Significant Deficiency
Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758
Prior Year Finding Number: N/A
Criteria: A system of internal control should be in place and operating to ensure that expenditures associated with each program are reliably captured and included on the appropriate quarterly expenditure report, as required by the grantor agency.
Condition/Context: The Organization identified during the preparation of its second quarter 2024 expenditure report approximately $25,000 in costs incurred during November 2022 that had not previously been included in a submitted expenditure report to PCCD. In order to bring its financial reporting of grant activity current, the Organization included these expenditures in its second quarter 2024 expenditure report. While such costs were incurred during the overall program performance period and were allowable and attributable to the program, such costs were not timely identified and reported on the correct expenditure report.
Questioned Costs: N/A
Cause: The Organization originally misidentified the costs as having been associated with a different funding stream that should have been included within the 4th quarter 2022 expenditures report.
Effect: In accurate interim financial reporting, the Organization reported certain costs incurred during November 2022 within the 2nd quarter 2024 expenditures report.
Recommendation: We recommend that Organization management review and update its identification of expenditures by period to ensure the completeness and accuracy of expenditure reporting to grantors.
Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to strengthen its grant expenditure identification to ensure the completeness of required expenditure reports.