PEMA Capital Project Reporting:
The PEMA Emergency Medical Services Recovery SLFRF Project (87374A) was reported to the federal government with $0 for capital expenditures because all recipients were beneficiaries. The SLFRF federal guidance states the following:
11. Subrecipient Monitoring. SLFRF...
PEMA Capital Project Reporting:
The PEMA Emergency Medical Services Recovery SLFRF Project (87374A) was reported to the federal government with $0 for capital expenditures because all recipients were beneficiaries. The SLFRF federal guidance states the following:
11. Subrecipient Monitoring. SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their subrecipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass-through entities.
First, your organization must clearly identify to the subrecipient: (1) that the award is a subaward of SLFRF funds; (2) any and all compliance requirements for use of SLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds.
Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. Part 200, Subpart F. U.S. Treasury, Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds, Version 5.14, December 14, 2023, Pages 12-13. (This is the current version)
Additionally, the U.S. Treasury states in their Quarterly Reporting User Guide Frequently Asked Questions (page 165 of the current edition):
1.20. Who are beneficiaries and are recipients required to report for them?
The terms and conditions of federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. Beneficiaries are not subject to the requirements placed on subrecipients in the Uniform Guidance, including audit pursuant to the Single Audit Act and 2 CFR Part 200, Subpart F or subrecipient reporting requirements.
OB-GBO interpreted this to mean that reporting was not necessary, but we are seeking clarification from U.S. Treasury. Meanwhile, we will collaborate with PEMA to review grant materials and address capital expenditure questions by July 31, 2024.
Capital Project In Excess Of $10M:
The Quarter 1 2023 Project and Expenditure Report submitted by the Commonwealth of Pennsylvania did not capture the DCNR State Parks and Outdoor Recreation Grants Program (87360B) as a capital project in excess of $10M. The federal reporting portal inaccurately recorded the submission, and unfortunately, we cannot verify if this was due to a technical issue (there have been several instances we found where information we entered into the portal was reported differently in the U.S. Treasury generated report summary and had to be corrected by the U.S. Treasury after submission) or human error since access to older reports is blocked, nor does the abridged PDF version of the submission from the U.S. Treasury portal contain that specific information. While the error was noted in the Quarter 1 2023 report, it had been corrected in the Quarter 2 report. Currently, there is no further action we can take regarding the Quarter 1 2023 report. We consider this issue resolved.
Capital Project Justification Did Not Include All Required Elements:
The DCNR State Parks and Outdoor Recreation Grants Program (87360B) has been reported as a capital project. OB-GBO acknowledges that the capital project justification did not include all the required elements below:
(i) Describe the harm or need to be addressed;
(ii) Explain why a capital expenditure is appropriate; and
(iii) Compare the proposed capital expenditure to at least two alternative capital expenditures and demonstrate why the proposed capital expenditure is superior.
OB-GBO plans to collaborate with DCNR to ensure future reports include all necessary elements by July 31, 2024.
Anticipated Completion Date: 07/31/2024
Contact Names: Michael Wood, Bureau Director, Bureau of Performance, Revenue, and Program Analysis, OB-GBO; Colleen Kling, Division Manager, Division of Programs and Performance, OB-GBO; Samantha Lockhart, Executive Budget Specialist, OB-GBO; Evelyn Madenford, Volunteer Loan Program Administrator, Office of State Fire Commissioner, PEMA; Mark Hansford, Division Manager, Division of Community and Conservation, DCNR