Assistance Listing 21.023 Emergency Rental Assistance Program (ERAP)
Condition: The Department of Planning and Development’s Division of Housing and Community
Development (DHCD) and the Office of the Director of Finance’s Grants Office (Grants Office) were
unable to provide documentation to support expenditure amounts reported on the state January 2022 ERAP1
and ERAP2 monthly reports. Specifically, the January 2022 ERAP1 and ERAP2 reports included total
unsupported expenditures of $199,813 and $272,135, respectively. See Tables 6 and 7 below for a
breakdown by reporting category. The funding source for this program is the U.S. Department of the
Treasury (Treasury) and the Pennsylvania Department of Human Services. Criteria: Per the Treasury’s ERAP1 and ERAP2 grantee award terms, recipients shall maintain records
and financial documents sufficient to support compliance with applicable guidance regarding the eligible
uses of funds. Additionally, per the Treasury’s ERAP Reporting Guidance, ERAP recipients should gather
and maintain required information such as amounts paid directly or indirectly to tenants, landlords, and
utility/home energy providers; amounts obligated to subrecipients and contractors; and administrative
expenses. Recipients should also gather required information from their subrecipients and contractors, as applicable. In preparing monthly reports, ERAP recipients must review the information entered or
submitted to the online reporting forms for errors and completeness.
Effect: Failure to properly reconcile and support reported expenditures can result in questioned costs and
noncompliance for the program. The total unsupported expenditures of $471,948 are considered to be
known questioned costs. Also, federal grantors will not have complete and accurate information to make
fiscal decisions on future federal awards.
Cause: DHCD and the Grants Office did not maintain sufficient supporting records for certain expenditure
amounts included in the state January 2022 ERAP1 and ERAP2 monthly reports.
Recommendation: DHCD and the Grants Office should properly maintain records and financial
documents and ensure all reported expenditures are fully reconciled to supporting records as part of their
reporting process.
Views of the Responsible Officials and Corrective Action Plan: We disagree with the finding regarding
spending reported to the Commonwealth of Pennsylvania. Prior to April 2022, reporting to the state was
generated from a reporting dashboard within the Quickbase database. Internal controls checking these
reports against raw data revealed an issue with the programming of the dashboard, and beginning in April
2022, reports were generated using raw data downloaded from the portal. Once this issue was detected and
resolved, PHDC and the City sent updated and corrected reporting to the Commonwealth, along with a
statement detailing our shift in methodology. This shift, and the corrected reports, were accepted by the
Commonwealth, as shown in the email chains that were provided to the Controller’s Office. The data
underlying the original ERA1 and ERA2 January 2022 reports cited in the finding cannot be re-created
since the errors have now been permanently corrected.
Auditor’s Comments on Agency’s Response: Regarding the corrected reports provided via email chains
with the Commonwealth to our office, we have the following comment:
Only one email chain provided had an attached “updated historical check” for ERAP1, submitted
to the Commonwealth in July 2022. The historical check included a line item for the month in
question, January 2022, but was still reporting the amounts of $173,807 and $22,042 for the
Administrative Paid categories (See Table 6). These amounts remain unsubstantiated per our audit
testing. Additionally, no corrected reports or updated historical checks were provided via these
email chains to address the discrepancies noted for ERAP2 (See Table 7).
Contact Person: Dan Gasiewski, Chief Grants Compliance Officer, Grants Office, Office of the Director
of Finance
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
Assistance Listing 93.268 Immunization Cooperative Agreements
Assistance Listing 93.940 HIV Prevention Activities Health Department Based Condition: The city’s Department of Public Health (DPH) submitted special reports for the Federal
Funding Accountability and Transparency Act (FFATA) that were inaccurate for both the Immunization
Cooperative Agreements (Assistance Listing 93.268) and the HIV Prevention Activities Health Department
Based (Assistance Listing 93.940) programs. This condition was reported as finding number 2021-010 in
the prior year report. Please see Tables 3 and 4 below for details. Criteria: 2 CFR Part 170 specifies that recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act
Subaward Reporting System (FSRS). Effect: Federal grantors may not have complete and accurate information to make fiscal decisions on
federal awards. The public will not have the information on federal awards (federal financial assistance and
expenditures).
Cause: DPH did not have a systematic process in place to report subawards made under the federal program
in accordance with FFATA. Consequently, the responsible employees were not properly trained in how to
complete the FFATA reports. Also, DPH management indicated that the source documentation used to
prepare the reports did not contain all applicable subaward information.
Recommendation: DPH should strengthen its procedures to ensure that its FFATA reports are accurate
and timely submitted, and that the source documentation used in the preparation of the reports contains all
applicable subaward information.
Views of the Responsible Officials and Corrective Action Plan: The Department of Public Health will
strengthen procedures to ensure the accuracy and submission of FFATA reports. The Division of Disease
Control (DDC) acknowledges the discrepancy within the submitted FFATA report for Immunization
Cooperative Agreements Grant Program (ALN 93.268). DDC will implement appropriate review and
preparation for all FFATA reporting by querying the necessary systems to gather and identify all pertinent
information regarding contracts and amounts.
The Division of HIV Health’s FFATA reports were late due to employee turnover and attempts to obtain
information from providers. The Division of HIV Health is researching the fact that expenditure information
for the FFATA reports included only six month of awards and not the full twelve months, as well as the
fact that a subaward was not included in the source document used in preparation of the FFATA report.
Contact Person(s): Ryan Taylor, Chief Operating Officer and Deputy Commissioner, Philadelphia
Department of Public Health, 215-686-5207
Kathleen Brady, Director/ Medical Director, Division of HIV Health, Philadelphia Department of Public
Health, 215-685-4778
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
Assistance Listing 93.558 Temporary Assistance for Needy Families
Condition: Two out of two subrecipients selected for testing did not have one or more required elements
defined in §2CFR 200.332 (a)(1) & (2) in their subrecipient agreements with the Mayor’s Office of
Community Empowerment and Opportunity. For one subrecipient, the contract did not contain specific
language indicating the Federal assistance listing number or title. For the other subrecipient, the contract
did not have the federal compliance language to ensure subrecipient’s compliance with federal statutes,
regulations, and the terms of the federal award. The funding source for this program is the PA Department
of Human Services.
Criteria: §2CFR 200.332 (a)(1) & (2) state that the pass-through entity must ensure every subaward is
clearly identified to the subrecipient by including assistance listing numbers and titles, and the requirements
imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with
Federal statutes, regulations and the terms and conditions of the Federal award.
Effect: Failure to provide all the required subaward information may result in noncompliance at the
subrecipient level.
Cause: The Mayor’s Office of Community Empowerment and Opportunity failed to include the required
elements in the subrecipient agreements.
Recommendation: We recommend that management modify and/or strengthen its current policies and
procedures to ensure that all required award information and applicable requirements are communicated to
subrecipients at the time of subaward.
Views of the Responsible Officials and Corrective Action Plan: Management agrees with the finding and
recommendation. Starting from FY2024, MOCEO will include a Notice of Award document for all
subrecipients contracts. This document will contain the necessary OMB required information to clearly
identify award details for the subrecipient.
Contact Person: Allison Elliott, Director of Finance, Mayor’s Office of Community Empowerment and
Opportunity, 215-685-3626
Children and Youth Programs
Assistance Listing 93.558 Temporary Assistance for Needy Families
Assistance Listing 93.658 Foster Care – Title IV-E
Act 148 Pennsylvania Department of Human Services
Condition: For all 32 sampled Department of Human Services (DHS) subrecipients, the subaward letters
sent by DHS to its subrecipients did not identify either the federal program names or the assistance listing
numbers. The programs are funded through the Pennsylvania Department of Human Services.
Criteria: Per the OMB’s Uniform Guidance 2 CFR section 200.332 (a)(1), the pass-through entity must
ensure every subaward is clearly identified to the subrecipient as a subaward and includes certain required
information at the time of the subaward. Required information includes the federal award identification,
such as the assistance listing number and title, to ensure that the federal award is used in accordance with
federal statutes, regulations, and the terms and conditions of the federal award.
Effect: Failure to provide all required subaward information to subrecipients may result in noncompliance
at the subrecipient level.
Cause: DHS failed to include the required elements in the subaward letters sent to subrecipients.
Recommendation: DHS management should modify the subaward letters sent to subrecipients to include
the federal program names and assistance listing numbers so that all required award information is
communicated to subrecipients at the time of subaward.
Views of the Responsible Officials and Corrective Action Plan: Effective 10/13/23, DHS has been
preparing FY24 funding allocation letters that will be sent to provider agencies immediately. Going
forward, the funding allocation letters will go out at the beginning of the contract fiscal year.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
Children and Youth Programs
Assistance Listing 93.558 Temporary Assistance for Needy Families
Assistance Listing 93.658 Foster Care – Title IV-E
Act 148 Pennsylvania Department of Human Services
Condition: For all 32 sampled Department of Human Services (DHS) subrecipients, the subaward letters
sent by DHS to its subrecipients did not identify either the federal program names or the assistance listing
numbers. The programs are funded through the Pennsylvania Department of Human Services.
Criteria: Per the OMB’s Uniform Guidance 2 CFR section 200.332 (a)(1), the pass-through entity must
ensure every subaward is clearly identified to the subrecipient as a subaward and includes certain required
information at the time of the subaward. Required information includes the federal award identification,
such as the assistance listing number and title, to ensure that the federal award is used in accordance with
federal statutes, regulations, and the terms and conditions of the federal award.
Effect: Failure to provide all required subaward information to subrecipients may result in noncompliance
at the subrecipient level.
Cause: DHS failed to include the required elements in the subaward letters sent to subrecipients.
Recommendation: DHS management should modify the subaward letters sent to subrecipients to include
the federal program names and assistance listing numbers so that all required award information is
communicated to subrecipients at the time of subaward.
Views of the Responsible Officials and Corrective Action Plan: Effective 10/13/23, DHS has been
preparing FY24 funding allocation letters that will be sent to provider agencies immediately. Going
forward, the funding allocation letters will go out at the beginning of the contract fiscal year.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
Assistance Listing 93.268 Immunization Cooperative Agreements
Assistance Listing 93.940 HIV Prevention Activities Health Department Based Condition: The city’s Department of Public Health (DPH) submitted special reports for the Federal
Funding Accountability and Transparency Act (FFATA) that were inaccurate for both the Immunization
Cooperative Agreements (Assistance Listing 93.268) and the HIV Prevention Activities Health Department
Based (Assistance Listing 93.940) programs. This condition was reported as finding number 2021-010 in
the prior year report. Please see Tables 3 and 4 below for details. Criteria: 2 CFR Part 170 specifies that recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act
Subaward Reporting System (FSRS). Effect: Federal grantors may not have complete and accurate information to make fiscal decisions on
federal awards. The public will not have the information on federal awards (federal financial assistance and
expenditures).
Cause: DPH did not have a systematic process in place to report subawards made under the federal program
in accordance with FFATA. Consequently, the responsible employees were not properly trained in how to
complete the FFATA reports. Also, DPH management indicated that the source documentation used to
prepare the reports did not contain all applicable subaward information.
Recommendation: DPH should strengthen its procedures to ensure that its FFATA reports are accurate
and timely submitted, and that the source documentation used in the preparation of the reports contains all
applicable subaward information.
Views of the Responsible Officials and Corrective Action Plan: The Department of Public Health will
strengthen procedures to ensure the accuracy and submission of FFATA reports. The Division of Disease
Control (DDC) acknowledges the discrepancy within the submitted FFATA report for Immunization
Cooperative Agreements Grant Program (ALN 93.268). DDC will implement appropriate review and
preparation for all FFATA reporting by querying the necessary systems to gather and identify all pertinent
information regarding contracts and amounts.
The Division of HIV Health’s FFATA reports were late due to employee turnover and attempts to obtain
information from providers. The Division of HIV Health is researching the fact that expenditure information
for the FFATA reports included only six month of awards and not the full twelve months, as well as the
fact that a subaward was not included in the source document used in preparation of the FFATA report.
Contact Person(s): Ryan Taylor, Chief Operating Officer and Deputy Commissioner, Philadelphia
Department of Public Health, 215-686-5207
Kathleen Brady, Director/ Medical Director, Division of HIV Health, Philadelphia Department of Public
Health, 215-685-4778
Assistance Listing 21.023 Emergency Rental Assistance Program (ERAP)
Condition: The Department of Planning and Development’s Division of Housing and Community
Development (DHCD) and the Office of the Director of Finance’s Grants Office (Grants Office) were
unable to provide documentation to support expenditure amounts reported on the state January 2022 ERAP1
and ERAP2 monthly reports. Specifically, the January 2022 ERAP1 and ERAP2 reports included total
unsupported expenditures of $199,813 and $272,135, respectively. See Tables 6 and 7 below for a
breakdown by reporting category. The funding source for this program is the U.S. Department of the
Treasury (Treasury) and the Pennsylvania Department of Human Services. Criteria: Per the Treasury’s ERAP1 and ERAP2 grantee award terms, recipients shall maintain records
and financial documents sufficient to support compliance with applicable guidance regarding the eligible
uses of funds. Additionally, per the Treasury’s ERAP Reporting Guidance, ERAP recipients should gather
and maintain required information such as amounts paid directly or indirectly to tenants, landlords, and
utility/home energy providers; amounts obligated to subrecipients and contractors; and administrative
expenses. Recipients should also gather required information from their subrecipients and contractors, as applicable. In preparing monthly reports, ERAP recipients must review the information entered or
submitted to the online reporting forms for errors and completeness.
Effect: Failure to properly reconcile and support reported expenditures can result in questioned costs and
noncompliance for the program. The total unsupported expenditures of $471,948 are considered to be
known questioned costs. Also, federal grantors will not have complete and accurate information to make
fiscal decisions on future federal awards.
Cause: DHCD and the Grants Office did not maintain sufficient supporting records for certain expenditure
amounts included in the state January 2022 ERAP1 and ERAP2 monthly reports.
Recommendation: DHCD and the Grants Office should properly maintain records and financial
documents and ensure all reported expenditures are fully reconciled to supporting records as part of their
reporting process.
Views of the Responsible Officials and Corrective Action Plan: We disagree with the finding regarding
spending reported to the Commonwealth of Pennsylvania. Prior to April 2022, reporting to the state was
generated from a reporting dashboard within the Quickbase database. Internal controls checking these
reports against raw data revealed an issue with the programming of the dashboard, and beginning in April
2022, reports were generated using raw data downloaded from the portal. Once this issue was detected and
resolved, PHDC and the City sent updated and corrected reporting to the Commonwealth, along with a
statement detailing our shift in methodology. This shift, and the corrected reports, were accepted by the
Commonwealth, as shown in the email chains that were provided to the Controller’s Office. The data
underlying the original ERA1 and ERA2 January 2022 reports cited in the finding cannot be re-created
since the errors have now been permanently corrected.
Auditor’s Comments on Agency’s Response: Regarding the corrected reports provided via email chains
with the Commonwealth to our office, we have the following comment:
Only one email chain provided had an attached “updated historical check” for ERAP1, submitted
to the Commonwealth in July 2022. The historical check included a line item for the month in
question, January 2022, but was still reporting the amounts of $173,807 and $22,042 for the
Administrative Paid categories (See Table 6). These amounts remain unsubstantiated per our audit
testing. Additionally, no corrected reports or updated historical checks were provided via these
email chains to address the discrepancies noted for ERAP2 (See Table 7).
Contact Person: Dan Gasiewski, Chief Grants Compliance Officer, Grants Office, Office of the Director
of Finance
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
Assistance Listing 93.268 Immunization Cooperative Agreements
Assistance Listing 93.940 HIV Prevention Activities Health Department Based Condition: The city’s Department of Public Health (DPH) submitted special reports for the Federal
Funding Accountability and Transparency Act (FFATA) that were inaccurate for both the Immunization
Cooperative Agreements (Assistance Listing 93.268) and the HIV Prevention Activities Health Department
Based (Assistance Listing 93.940) programs. This condition was reported as finding number 2021-010 in
the prior year report. Please see Tables 3 and 4 below for details. Criteria: 2 CFR Part 170 specifies that recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act
Subaward Reporting System (FSRS). Effect: Federal grantors may not have complete and accurate information to make fiscal decisions on
federal awards. The public will not have the information on federal awards (federal financial assistance and
expenditures).
Cause: DPH did not have a systematic process in place to report subawards made under the federal program
in accordance with FFATA. Consequently, the responsible employees were not properly trained in how to
complete the FFATA reports. Also, DPH management indicated that the source documentation used to
prepare the reports did not contain all applicable subaward information.
Recommendation: DPH should strengthen its procedures to ensure that its FFATA reports are accurate
and timely submitted, and that the source documentation used in the preparation of the reports contains all
applicable subaward information.
Views of the Responsible Officials and Corrective Action Plan: The Department of Public Health will
strengthen procedures to ensure the accuracy and submission of FFATA reports. The Division of Disease
Control (DDC) acknowledges the discrepancy within the submitted FFATA report for Immunization
Cooperative Agreements Grant Program (ALN 93.268). DDC will implement appropriate review and
preparation for all FFATA reporting by querying the necessary systems to gather and identify all pertinent
information regarding contracts and amounts.
The Division of HIV Health’s FFATA reports were late due to employee turnover and attempts to obtain
information from providers. The Division of HIV Health is researching the fact that expenditure information
for the FFATA reports included only six month of awards and not the full twelve months, as well as the
fact that a subaward was not included in the source document used in preparation of the FFATA report.
Contact Person(s): Ryan Taylor, Chief Operating Officer and Deputy Commissioner, Philadelphia
Department of Public Health, 215-686-5207
Kathleen Brady, Director/ Medical Director, Division of HIV Health, Philadelphia Department of Public
Health, 215-685-4778
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
Assistance Listing 93.558 Temporary Assistance for Needy Families
Condition: Two out of two subrecipients selected for testing did not have one or more required elements
defined in §2CFR 200.332 (a)(1) & (2) in their subrecipient agreements with the Mayor’s Office of
Community Empowerment and Opportunity. For one subrecipient, the contract did not contain specific
language indicating the Federal assistance listing number or title. For the other subrecipient, the contract
did not have the federal compliance language to ensure subrecipient’s compliance with federal statutes,
regulations, and the terms of the federal award. The funding source for this program is the PA Department
of Human Services.
Criteria: §2CFR 200.332 (a)(1) & (2) state that the pass-through entity must ensure every subaward is
clearly identified to the subrecipient by including assistance listing numbers and titles, and the requirements
imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with
Federal statutes, regulations and the terms and conditions of the Federal award.
Effect: Failure to provide all the required subaward information may result in noncompliance at the
subrecipient level.
Cause: The Mayor’s Office of Community Empowerment and Opportunity failed to include the required
elements in the subrecipient agreements.
Recommendation: We recommend that management modify and/or strengthen its current policies and
procedures to ensure that all required award information and applicable requirements are communicated to
subrecipients at the time of subaward.
Views of the Responsible Officials and Corrective Action Plan: Management agrees with the finding and
recommendation. Starting from FY2024, MOCEO will include a Notice of Award document for all
subrecipients contracts. This document will contain the necessary OMB required information to clearly
identify award details for the subrecipient.
Contact Person: Allison Elliott, Director of Finance, Mayor’s Office of Community Empowerment and
Opportunity, 215-685-3626
Children and Youth Programs
Assistance Listing 93.558 Temporary Assistance for Needy Families
Assistance Listing 93.658 Foster Care – Title IV-E
Act 148 Pennsylvania Department of Human Services
Condition: For all 32 sampled Department of Human Services (DHS) subrecipients, the subaward letters
sent by DHS to its subrecipients did not identify either the federal program names or the assistance listing
numbers. The programs are funded through the Pennsylvania Department of Human Services.
Criteria: Per the OMB’s Uniform Guidance 2 CFR section 200.332 (a)(1), the pass-through entity must
ensure every subaward is clearly identified to the subrecipient as a subaward and includes certain required
information at the time of the subaward. Required information includes the federal award identification,
such as the assistance listing number and title, to ensure that the federal award is used in accordance with
federal statutes, regulations, and the terms and conditions of the federal award.
Effect: Failure to provide all required subaward information to subrecipients may result in noncompliance
at the subrecipient level.
Cause: DHS failed to include the required elements in the subaward letters sent to subrecipients.
Recommendation: DHS management should modify the subaward letters sent to subrecipients to include
the federal program names and assistance listing numbers so that all required award information is
communicated to subrecipients at the time of subaward.
Views of the Responsible Officials and Corrective Action Plan: Effective 10/13/23, DHS has been
preparing FY24 funding allocation letters that will be sent to provider agencies immediately. Going
forward, the funding allocation letters will go out at the beginning of the contract fiscal year.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
Children and Youth Programs
Assistance Listing 93.558 Temporary Assistance for Needy Families
Assistance Listing 93.658 Foster Care – Title IV-E
Act 148 Pennsylvania Department of Human Services
Condition: For all 32 sampled Department of Human Services (DHS) subrecipients, the subaward letters
sent by DHS to its subrecipients did not identify either the federal program names or the assistance listing
numbers. The programs are funded through the Pennsylvania Department of Human Services.
Criteria: Per the OMB’s Uniform Guidance 2 CFR section 200.332 (a)(1), the pass-through entity must
ensure every subaward is clearly identified to the subrecipient as a subaward and includes certain required
information at the time of the subaward. Required information includes the federal award identification,
such as the assistance listing number and title, to ensure that the federal award is used in accordance with
federal statutes, regulations, and the terms and conditions of the federal award.
Effect: Failure to provide all required subaward information to subrecipients may result in noncompliance
at the subrecipient level.
Cause: DHS failed to include the required elements in the subaward letters sent to subrecipients.
Recommendation: DHS management should modify the subaward letters sent to subrecipients to include
the federal program names and assistance listing numbers so that all required award information is
communicated to subrecipients at the time of subaward.
Views of the Responsible Officials and Corrective Action Plan: Effective 10/13/23, DHS has been
preparing FY24 funding allocation letters that will be sent to provider agencies immediately. Going
forward, the funding allocation letters will go out at the beginning of the contract fiscal year.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
2022-013 SPECIAL TESTS – COMPLIANCE FINDING
Children and Youth Programs
Assistance Listing 93.090 Guardianship Assistance
Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program
Assistance Listing 93.658 Foster Care Title IV-E
Assistance Listing 93.659 Adoption Assistance
Assistance Listing 93.778 Medical Assistance Program
Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program
Act 148 Pennsylvania Department of Human Services
Condition: The Department of Human Services (DHS) reported salaries and benefits costs that exceeded
maximum allowable amounts by $1,721,868 on its fiscal 2022 County Children and Youth Social Service
Programs’ Fiscal Summary. The programs are funded through the Pennsylvania Department of Human
Services (PA DHS).
Criteria: The PA Code, Title 55, Chapter 3170, section 3170.41 through 3170.43 provides for PA DHS to
reimburse salaries up to the limit of the county civil service personnel compensation plan, or where
applicable up to the limit of Commonwealth compensation levels. The Commonwealth will not participate
in costs which exceed the maximum salary levels.
Effect: The fiscal 2022 County Children and Youth Social Services Programs’ Fiscal Summary included
ineligible expenditures of $1,721,868. Because DHS is reimbursed a percentage of the expenditures it
reports to PA DHS, we determined that ineligible costs had resulted in excess reimbursement of $1,375,744.
This amount represents questioned costs distributed to the following programs listed in the Table 5 below: Cause: DHS does not have adequate procedures in place to ensure that salaries and benefits requested for
reimbursement do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Recommendation: DHS should revise its procedures to ensure that amounts requested for reimbursement
do not exceed the maximum allowable amount per the Commonwealth Compensation Plan.
Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA]
Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21
and FY22 were on file and under review. However, approval was pending. OCYF explained that the State
reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year.
Therefore, the possibility of overages can occur because of salary increases or other personnel changes.
The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a
waiver for the items in question.
Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.
Assistance Listing 93.268 Immunization Cooperative Agreements
Assistance Listing 93.940 HIV Prevention Activities Health Department Based Condition: The city’s Department of Public Health (DPH) submitted special reports for the Federal
Funding Accountability and Transparency Act (FFATA) that were inaccurate for both the Immunization
Cooperative Agreements (Assistance Listing 93.268) and the HIV Prevention Activities Health Department
Based (Assistance Listing 93.940) programs. This condition was reported as finding number 2021-010 in
the prior year report. Please see Tables 3 and 4 below for details. Criteria: 2 CFR Part 170 specifies that recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act
Subaward Reporting System (FSRS). Effect: Federal grantors may not have complete and accurate information to make fiscal decisions on
federal awards. The public will not have the information on federal awards (federal financial assistance and
expenditures).
Cause: DPH did not have a systematic process in place to report subawards made under the federal program
in accordance with FFATA. Consequently, the responsible employees were not properly trained in how to
complete the FFATA reports. Also, DPH management indicated that the source documentation used to
prepare the reports did not contain all applicable subaward information.
Recommendation: DPH should strengthen its procedures to ensure that its FFATA reports are accurate
and timely submitted, and that the source documentation used in the preparation of the reports contains all
applicable subaward information.
Views of the Responsible Officials and Corrective Action Plan: The Department of Public Health will
strengthen procedures to ensure the accuracy and submission of FFATA reports. The Division of Disease
Control (DDC) acknowledges the discrepancy within the submitted FFATA report for Immunization
Cooperative Agreements Grant Program (ALN 93.268). DDC will implement appropriate review and
preparation for all FFATA reporting by querying the necessary systems to gather and identify all pertinent
information regarding contracts and amounts.
The Division of HIV Health’s FFATA reports were late due to employee turnover and attempts to obtain
information from providers. The Division of HIV Health is researching the fact that expenditure information
for the FFATA reports included only six month of awards and not the full twelve months, as well as the
fact that a subaward was not included in the source document used in preparation of the FFATA report.
Contact Person(s): Ryan Taylor, Chief Operating Officer and Deputy Commissioner, Philadelphia
Department of Public Health, 215-686-5207
Kathleen Brady, Director/ Medical Director, Division of HIV Health, Philadelphia Department of Public
Health, 215-685-4778