Finding 2023-003: Reporting Federal Agencies - U.S. Department of Health and Human Services Passed through PA Department of Human Services Assistance Listing Number: 93.658 Criteria: PA Department of Human Services requires the quarterly Act 148 report be electronically filed within 45 days of the end of each calendar quarter. The County is required to have appropriate controls over the accuracy of preparation and timely filing of reports, including those under Act 148 and Uniform Guidance. Condition: The County, because of the conditions cited in Finding 2023-001, did not timely submit the quarterly reports or annual audits required by Uniform Guidance. Cause: The County Children and Youth Services did not file the Act 148 reports timely due to conditions cited in Finding 2023-001. Effect: Incomplete reporting or delinquent reporting could impact future availability of the program and could ultimately result in return of funds. Questioned Costs: None Repeat Finding: Yes, Finding 2022-03 Recommendation: We recommend the County develop a procedure to ensure the reports filed on their behalf are complete and are timely filed to meet program requirements. Management Response: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package.
Finding 2023-004: Special Tests and Provisions -Monitoring Federal Agencies - U.S. Department of Housing and Urban Development, U.S. Department of the Treasury, and U.S. Department of Health Passed through PA Department of Community and Economic Development and PA Department of Human Services Assistance Listing Number: 14.228, 14.239, 21.023, and 93.658 Criteria: The pass-through entity should monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Subaward monitoring must include reviewing financial and programmatic reports (performance and special) required by the Grantor. Condition: The County is to conduct such reviews and audits of its subrecipients as may be necessary or appropriate to determine whether the subrecipient has committed and expended the funds, as required by 24 CFR section 92.500, and has met program requirements particularly as they relate to eligible activities, eligibility, program income, and reporting. The County did not perform all necessary subrecipient monitoring in 2023. Cause: The County has contracted with the Redevelopment Authority of the County of Lebanon to operate the CDBG and HOME programs including use of funds, eligibility, program income, and preparation of reports. The County has contracted with the Housing Authority of the County of Lebanon to operate the ERAP program including use of funds, eligibility, and preparation of reports. The County has contracted with multiple providers to provide child welfare services to children and youth. The County was not performing all necessary monitoring activities of the Authorities and service providers. Effect: Improper use of funds could impact future availability of the programs and could ultimately result in return of funds. Questioned Costs: None Repeat Finding: No Recommendation: We recommend the County develop a policy to ensure the periodic monitoring of subrecipients is performed. Management Response: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package.
Finding 2023-005: Eligibility - Missing Participant Documentation Federal Agencies - U.S. Department of Health and Human Services Passed through PA Department of Human Services Assistance Listing Number: 93.658 Criteria: The applicable program requirements require recipients to maintain complete and accurate documentation to support participant qualification and allowability of grant-funded services and expenditures. Condition: During testing, it was noted that required eligibility documentation was missing or incomplete for five of the participants whose costs or services were charged to the grant. Files reviewed did not consistently contain documentation demonstrating that participants met eligibility requirements at the time services were provided. Cause: The issue resulted from inconsistent file review procedures, staff turnover, and a lack of standardized eligibility documentation checklists and supervisory review prior to service delivery or reimbursement requests. Effect: Missing eligibility documentation limits the ability to verify participant eligibility and increases the risk of questioned costs, repayment of grant funds, and noncompliance with grant requirements. Questioned Costs: None Repeat Finding: No Recommendation: We recommend the County develop a standardized documentation checklist to ensure proper documentation is retained for each participant. Management Response: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package.
Finding 2023-006: DHS Common Requirements – Subrecipient Monitoring Federal Agencies - U.S. Department of Health and Human Services Passed through PA Department of Human Services Assistance Listing Number: 93.658 Criteria: Common compliance requirements apply to all programs funded through the Pennsylvania Department of Human Services. The auditee is responsible for ensuring that its subrecipients/subcontractors are appropriately audited in accordance with Government Auditing Standards (the Yellow Book), applicable program requirements/contract provisions, and when appropriate, the Uniform Guidance, and the Single Audit Bulletin. Condition: During our audit, we found that the County’s Children and Youth Services did not obtain the audit report for 1 of the 8 providers tested. Cause: The County Children and Youth Services inadvertently did not obtain the required audit reports. Effect: Some contracts are not compliant with all required guidelines and violated Pennsylvania regulations by not submitting required audit reports timely. Questioned Costs: None Repeat Finding: No Recommendation: Management should provide for adequate review of audit reports being submitted by providers to ensure requirements are met. Management Response: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package.
Finding 2023-007: DHS Common Requirements – Drug-Free Workplace Act Federal Agencies - U.S. Department of Health and Human Services Passed through PA Department of Human Services Assistance Listing Number: 93.658 Criteria: Common compliance requirements apply to all programs funded through the Pennsylvania Department of Human Services. In accordance with the Drug-Free Work Place Act, the Commonwealth of Pennsylvania is prohibited from entering into a contract involving an expenditure of $25,000 or more of federal funding with a contractor or an individual who does not certify a drug-free workplace, and who does not establish several conditions and requirements that have to be met in order to certify a drug-free workplace. Condition: During our audit, we found that the County Children and Youth Services did not include the Drug-Free Workplace Act requirements in certain contracts. Cause: The County Children and Youth Services inadvertently did not include these requirements in their contracts. Effect: Some contracts and reports relating to Pennsylvania Department of Human Services are not compliant of all required guidelines and violated Pennsylvania regulations by omitting or entering contracts without all common requirements. Questioned Costs: None Repeat Finding: Yes, 2022-004 Recommendation: Management should provide for adequate review of contracts being submitted to ensure all necessary requirements are listed. Management Response: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package.
Finding 2023-008: DHS Special Tests - Licensure/Approval Federal Agencies - U.S. Department of Health and Human Services Passed through PA Department of Human Services Assistance Listing Number: 93.658 Criteria: PA Code, Title 55, Chapter 3130.09 states that “A service or facility used by the county agency to serve children must be licensed or approved by the appropriate state agency, if that service or facility is subject to licensure or approval.” Condition: During testing, it was noted that the required foster family home approval letter was missing for one of the participant files selected for testing. Cause: The County Children and Youth Services inadvertently did not retain the approval letter in the participant file. Effect: Children are inadvertently placed in facilities that are not properly licensed/approved. Questioned Costs: None Repeat Finding: No Recommendation: We recommend the County develop a procedure to ensure property documentation is retained. Management Response: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package
Finding 2023-009: DHS Special Tests – Individual Service Plan Federal Agencies - U.S. Department of Health and Human Services Passed through PA Department of Human Services Assistance Listing Number: 93.658 Criteria: PA Code, Title 55, Chapters 3680.42 and 3800.225 state that “The agency must develop and implement an ISP for each child within 30 days of admission. The ISP must identify the daily care and treatment that will be provided to the child. The provider agency’s administrator, or a designee, must sign the ISP and a copy of the plan must be maintained in the client’s file. The client’s ISP must be formally reviewed at least once every six months to determine progress in achieving the established goals and objectives. A report on the child’s progress must be submitted at least quarterly to the county children and youth agency.” Condition: The County shall ensure that, within 30 days of acceptance for service, an ISP is developed and implemented for a child. The ISP shall identify the daily care and treatment which will be provided to the child. A client’s ISP shall be formally reviewed at least once every 6 months to determine progress in achieving the established goals and objectives. The County did not have a review within the last six months for 1 of the 15 individuals selected for testing. Cause: The County does not have a uniform policy that outlines when the process should be initiated by the caseworkers in order to ensure meetings are scheduled and held with individuals to meet the requirements. Effect: The County may have been providing the wrong type of service to individuals. Questioned Costs: None Repeat Finding: No Recommendation: We recommend the County develop a uniform policy for all caseworkers to follow to ensure the process is initiated early enough to meet the requirements. Management Response: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package
Finding 2023-010: DHS Special Tests – Subrecipient Child Protective Services Law Monitoring Federal Agencies - U.S. Department of Health and Human Services Passed through PA Department of Human Services Assistance Listing Number: 93.658 Criteria: The Child Protective Services Law (CPSL) requires the conduct of criminal background checks and child abuse history clearances (certifications) for all employees and direct volunteers of the county children and youth agency (CCYA) as well as the employees and volunteers of the CCYA’s contracted service providers (including sub-recipients). The CCYA must monitor provider adherence to the CPSL background check requirements to assure the safety of children receiving prevention, reunification and aftercare services (services coded as in-home). Condition: During the audit, it was noted that the County did not monitor provider adherence to the CPSL background check requirements during 2023. Cause: The County does not have a uniform policy that outlines monitoring provider adherence to meet the requirements. Effect: The County may be using providers that do not have the required clearances to work with children. Questioned Costs: None Repeat Finding: No Recommendation: We recommend the County develop a policy to ensure the CPSL compliance requirement is performed. Management Response: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package.
Finding 2023-011: DHS Special Tests – Family Service Plan Federal Agencies - U.S. Department of Health and Human Services Passed through PA Department of Human Services Assistance Listing Number: 93.658 Criteria: PA Code Title 55, Section 3130.61 and 3130.63 states that “The county agency shall prepare, within 60 days of accepting a family for service, a written family service plan for each family receiving services through the county agency. The county agency shall review service plans at least every 6 months.” Condition: The County provides services under the Children and Youth grant to eligible families. As a result, the County is required to prepare a Family Service Plan (FSP) for a family accepted for services within 60 days of acceptance and review at least every 6 months. The County did not complete an FSP within 60 days for 3 of the 15 families selected for testing. Cause: The County does not have a tracking mechanism that alerts caseworkers as to when family services plans are due based on when a family is accepted for services. Effect: The County could have provided services to individuals that did not relate to the established FSP. Questioned Costs: None Repeat Finding: No Recommendation: We recommend the County develop a tracking mechanism that will alert caseworkers of initial FSP due dates to ensure that all initial FSP’s are completed within the 60-day required timeframe. Management Response: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package.
Finding 2023-002: Segregation of Duties over Reporting Federal Agency - U.S. Department of Health and Human Services Passed through PA Department of Drug and Alcohol Programs Assistance Listing Number: 93.959 & 93.788 Criteria: A significant deficiency is a deficiency, or combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance. Properly designed internal controls should provide for proper segregation of duties in financial reporting. Duties surrounding reports generated to report performance and financial information should be properly segregated between the persons preparing reports and the persons reviewing and approving reports for submission. Condition: During our audit, we found that the County does not have adequate segregation of duties over its grant reporting for certain programs. Cause: The county had staff losses in positions involved in the proper segregation of duties. Effect: Reports submitted by the County did not have reviews performed by personnel not also responsible for compiling data for and preparing the same reports. Context: County staff has lost its segregation of duties due to loss of staffing in programs support. We did not identify errors in the reporting to the various oversight agencies. Questioned Costs: None Repeat Finding: Yes, 2022-002 Recommendation: Management should provide for adequate review of cost reports being submitted. Management Response: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package.