Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are to 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, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
Cluster name: WIOA Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award number and year: DI21-002285 A1, April 1, 2020 through June 30, 2022 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: $25,761 Condition?Contrary to federal regulations and grantor and County policies and procedures, the County?s Workforce Innovation and Opportunity Act (WIOA) Department (Department) spent $25,761 of WIOA program monies for unallowable purposes. Specifically, we found that the Department paid for unallowable purchases and invoices of a third-party nonprofit organization that the Department?s former director helped create while employed by the County and that the County had contracted with to increase the capacity of the local workforce system. Despite the contract between the County and the nonprofit organization not authorizing the nonprofit organization to obligate the County for its expenses or enter into agreements on the County?s behalf, both occurred. The $25,761 of unallowable purchases included: ? $25,431 for the nonprofit organization?s leased building ($18,700), electronic data services ($3,545), utilities invoices ($2,951), and a storage unit ($235). ? $260 for purchases made using County purchasing cards, consisting of gift cards, food and beverages, and board games, $245 of which were for the nonprofit organization?s program outreach activities but not allowed by the program?s requirements or the County?s purchasing card policies and procedures. ? $70 for other purchases made using County purchasing cards that the Department charged to the program but did not have documentation to support their allowability. Effect?The Department received federal reimbursement for $25,761 in unallowable charges it made to the program that it was not eligible to receive and, therefore, is at risk of having to return these monies to the pass-through grantor.1 Further, the Department made $25,761 of grant monies unavailable for their intended purpose. Cause?The County?s lack of internal controls and former WIOA director?s inadequate oversight of the WIOA program contributed to the Department?s spending of WIOA program monies for unallowable purposes. Specifically, the County?s policies and procedures did not include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. This, combined with the former WIOA director?s comingling of the nonprofit organization?s financial activities, contributed to the Department directly paying for purchases and invoices belonging to the nonprofit organization despite them not being invoiced to or addressed to the County. In addition, Department staff reported that they believed the nonprofit organization?s purchases and invoices were allowable for the County to pay for and charge to the program; however, they did not maintain documentation to support this justification. Further, the former WIOA director did not provide proper oversight and ensure that the Department followed federal regulations and grantor and County policies and procedures to incur and pay for or reimburse only authorized federal program costs and to maintain documentation to support that the County?s program costs were allowable. Criteria?Federal regulations require the Department to reimburse only those federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements (2 CFR 200.403). The grantor and County policies and procedures contain similar requirements and also require the Department to retain records and other documentation supporting the County?s administration of federal awards for at least 3 years (Navajo County. [2019]. Fiscal Policy Manual, Section 4.4 ).2 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Improve its accounts payable policies and procedures to include detailed instructions for departments to follow for initiating new vendors with the County and processing vendor invoices using its established accounts payable process through the Finance Department. 2. Follow federal regulations and grantor and County policies and procedures requiring it to: a. Incur and pay for or reimburse only authorized federal program costs that are necessary and reasonable for the federal award?s performance, adequately documented, and allowed by the federal program?s requirements. b. Maintain documentation to support that federal program costs it incurs and pays for or reimburses are allowable. 3. Verify all invoices belong to and are addressed to the County prior to payment. 4. Ensure that the Department establishes clear contractual arrangements with entities the Department plans to use to help administer the federal program that comply with County policies and procedures and the program?s requirements. 5. Coordinate with the pass-through grantor to adjust future federal reimbursements requests or repay the pass-through grantor for the unallowable costs the Department charged to the program. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Department of Economic Security. (n.d.). Workforce Innovation and Opportunity Act Policy Manual. Retrieved on 3/1/2023 from https://des.az.gov/services/employment/workforce-innovation-and-opportunity-act-wioa/title-i-b-policy-and-procedure 2 Federal Uniform Guidance requires the pass-through entities to follow up, issue management decisions, and resolve subrecipients single audit findings as part of their monitoring responsibilities for ensuring that subawards are used for authorized purposes, in compliance with federal laws and regulations and the award terms, and that the program?s performance goals are achieved (2 CFR ?200.332[d]).
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child and Adult Care Food program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 236 subrecipients receiving Federal grant agreements for the Child and Adult Care Food program. During 2021, there were 126 subrecipients and 110 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February of 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February of 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child and Adult Care Food program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not complete a risk assessment for any awards to subrecipients of the Supporting Effective Instruction program during the audit period. CRITERIA 2 CFR 200.332 ? states that all pass-through entities must: (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. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The Department of Public Instruction overlooked completing subrecipient risk assessments due to the continued response of the COVID-19 pandemic. EFFECT Department of Public Instruction is not able to verify that subrecipients are compliant with Federal statutes, regulations, and terms and conditions of the subaward because there was no risk assessment completed for subrecipients in order to determine appropriate monitoring. CONTEXT The Department of Public Instruction distributed approximately $19,000,000 in Federal funds under the Supporting Effective Instruction program to 168 different subrecipients. While these subrecipients did receive monitoring procedures, no adjustments were made to individual subrecipients based on the results of risk assessments. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Department of Public Instruction ensure subrecipient risk assessments are completed timely and used to determine the nature and extent of subrecipient monitoring for the Supporting Effective Instruction program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not complete any risk assessments for 3 of 5 subrecipients sampled and only completed a risk assessment once during our audit period for the other 2 sampled even though they received separate grants during each fiscal year. CRITERIA 2 CFR 200.332 (b) states "All pass-through entities must: 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 described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency)." Department of Public Instruction awarded grants to subrecipients annually under this program. As such, a risk assessment should be completed annually for each subrecipient in which a new grant was awarded to them. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The Department of Public Instruction did not complete risk assessments for subrecipients as the Comprehensive Literacy program had a high turnover of staff that were administering the program and the Department did not have this responsibility assigned to someone during parts of our audit period. EFFECT The Department of Public Instruction is not adjusting their subrecipient monitoring based on risk assessments completed for the subrecipients in compliance with Federal regulations. CONTEXT The Department of Public Instruction distributed approximately $23,250,000 in Federal funds under the Comprehensive Literacy program to 25 different local education agency subrecipients. While these subrecipients did receive monitoring procedures no adjustments were made to individual subrecipients based on results of risk assessments. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Department of Public Instruction ensure risk assessments are completed for each grant their subrecipients receive and adjust monitoring procedures as necessary based on the results of these assessments. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Comprehensive Literacy program as all grant templates used did not include the subaward budget period start and end date. CRITERIA 2 CFR 200.332 states required information that pass-through entities must disclose to subrecipients, including paragraph (a)(1)(vi) "Subaward Budget Period State and End Date" 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The Comprehensive Literacy Program did not update their grant templates to include a new requirement that was added to the relevant Federal codes and went into effect January 1, 2021. EFFECT Subrecipients may not have been made aware of all necessary grant information and requirements. CONTEXT The Comprehensively Literacy program grants subawards annually under each of the Federal grants it received under the program. During our audit period, there were 2 Federal awards granted out to subrecipients a total of 35 times each fiscal year. The grant agreements shared a template each year and it was found that all were missing a newly required piece of information after the relevant CFR was modified and an update went into effect on January 1, 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Department of Public Instruction ensure that subrecipients are made aware of all required grant award information. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Health did not ensure all required grant award information for Coronavirus Relief Funds (CRF) was provided to subrecipients. In addition, the Department's internal controls were insufficient to ensure that subrecipients received communication regarding the necessary items. Required information not communicated included: ? Subrecipient's unique entity identifier, ? Federal Award Identification Number, ? Total amount of Federal funds obligated to the subrecipient by the pass-through entity including the current financial obligation, ? Name of awarding agency, ? Assistance Listing Number; and, ? Indirect cost rate for Federal award including if the de minimis rate is charged. CRITERIA Federal regulation, 2 CFR 200.332(a), requires pass-through entities to communicate specific required information to subrecipients. Federal regulation, 2 CFR 200.303, requires non-Federal entities, in part, to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The Department of Health did not utilize its traditional grant template agreement to extend CRF dollars to ambulance, fire, school districts, and hospitals. Instead, the Department used a CARES Act Coronavirus Relief Fund Eligibility Certification form which did not contain all required items. EFFECT These required communications are intended to help subrecipients meet all their reporting requirements and to meet all award terms. Subrecipients subject to Single Audits also need this information for their audits. CONTEXT The Department of Health utilized its traditional grant template agreement for $31.7 million in grants provided to 28 local public health units which included the best information available to describe the Federal award and subaward. However, the Department did not utilize its traditional grant template agreement to extend up to $29.8 million of CRF dollars to 121 other entities, including ambulance, fire, and school districts and hospitals. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Department of Health: A) Communicate all required information of 2 CFR 200.332(a) to subrecipients. B) Develop procedures to ensure that all Coronavirus Relief Fund award information is communicated to subrecipients. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly Department of Health) agrees with the recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Health did not evaluate each subrecipient's risk of noncompliance. CRITERIA Federal regulation, 2 CFR 200.303, requires non-Federal entities, in part, to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.332, all pass-through entities must 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. All pass-through entities must 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, and that subaward performance goals are achieved. Per 2 CFR 200.332(d)(2), pass through entities are required to ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. CAUSE The Department of Health primarily relied on risk assessments previously conducted for entities that had entered into other traditional grant agreements with the agency. Risk assessments were not conducted on all entities that only received CRF dollars and had not entered into other traditional grant agreements. The Department of Health indicated that prior to COVID-19, all subrecipients were subjected to sampling for a desk review. However, during COVID-19, the Department focused monitoring efforts on the 28 local public health units and pulled one random month to review expenditures being charged. EFFECT Monitoring activities conducted during our audit period were not determined based on subrecipient risk of noncompliance. CONTEXT The Department of Health provided $61.5M of CRF dollars to 149 subrecipients as follows: ? $31.7M to 28 local public health units ? $25M to 7 hospitals and related organizations ? $4.8M to 114 other entities, primarily ambulance districts We tested 15 of the 149 subrecipients (13 randomly selected and 2 individually significant items). Based on our testing and information provided by the Department of Health, we identified the following: ? Department of Health performed adequate during the award monitoring on 6 of the 15 subrecipients selected. ? Department of Health monitored 4 subrecipients not required to have a Single Audit. Six subrecipients selected had Single Audits while the remaining five subrecipients, which received less than $100,000 in CRF funding, were not monitored nor had a Single Audit. ? Department of Health did not conduct risk assessments on 4 of the 15 subrecipients selected, mostly ambulance districts that only received CRF dollars. The Department of Health acknowledged subjecting the 28 local public health units to subrecipient monitoring sampling. The Department tested $919,816 out of $61,521,414 of CRF payments to subrecipients or 1.5%. In addition, we noted the Department had assigned a risk level to the local public health units and hospitals selected for testing, as well as 53 ambulance districts. Lastly, the subrecipients (local public health units, hospitals, and ambulance districts) were known to be impacted by the COVID-19 pandemic, which could make such entities low risk for noncompliance. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Department of Health conduct during-the-award monitoring activities as required for pass-through entities in accordance with 2 CFR 200.332. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly Department of Health) agrees with the recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Health Department did not receive audit reports for all subrecipients that received greater than $750,000 or verify that all subrecipients receiving less than $750,000 from the Health Department were not subject to requirements under 2 CFR 200 Subpart F. One subrecipient received over $980,000 and the Health Department did not receive an audit report from this entity. There were 6 additional subrecipients that received less than $750,000 but there were no verifications to ensure additional Federal funds weren't received from another source. Any of these entities that received greater than $750,000 in Federal funds from all sources would be required to receive an audit under 2 CFR 200 Subpart F. CRITERIA 2 CFR 200.332(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F. CAUSE The tracking spreadsheet for subrecipient audit reports is not being used to verify that all subrecipients received an audit or a certification that an audit is not required. EFFECT The Health Department is not meeting the requirements of a pass through entity required by 2 CFR 200 Subpart F. CONTEXT There were 27 subrecipients that received Federal funds from the Health Department which were subject to monitoring during our audit period. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Health Department ensure all subrecipients obtain audits or a certification that an audit is not required in accordance with 2 CFR 200 Subpart F. DEPARTMENT OF HEALTH RESPONSE The Public Health Division of the Department of Health and Human Services (formerly the Department of Health) agrees with this recommendation. See ?Management?s Response and Corrective Action? section of this report.
Various Agencies Finding 2022 ? 014: ALN 10.553, 10.555, 10.556, 10.559, and 10.582 ? Child Nutrition Cluster (including COVID-19) ALN 10.557 ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (including COVID-19) ALN 10.558 ? Child and Adult Care Food Program (including COVID-19) ALN 15.252 ? Abandoned Mine Land Reclamation ALN 21.023 ? COVID-19 ? Emergency Rental Assistance Program ALN 84.010 ? Title I Grants to Local Educational Agencies ALN 84.027 and 84.173 ? ? Special Education Cluster (IDEA) (including COVID-19) ALN 84.425C ? COVID 19 ? Education Stabilization Fund - GEER Fund ALN 84.425D ? COVID 19 ? Education Stabilization Fund - ESSER Fund ALN 84.425R ? COVID 19 ? Education Stabilization Fund - CRRSA EANS ALN 84.425U ? COVID 19 ? Education Stabilization Fund - ARP ESSER ALN 84.425W ? COVID 19 ? Education Stabilization Fund - ARP ESSER HCY ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) ALN 93.563 ? Child Support Enforcement ALN 93.575 and 93.596 ? Child Care and Development Fund (CCDF) Cluster (including COVID-19) ALN 93.658 ? Foster Care ? Title IV-E (including COVID-19) ALN 93.659 ? Adoption Assistance (including COVID-19) ALN 93.775, 93.777, and 93.778 ? Medicaid Cluster (including COVID-19) A Material Weakness and Material Noncompliance Exist in the Commonwealth?s Subrecipient Audit Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2021-015) Federal Grant Number(s) and Year(s): 1PA300365 (1/01/2022 ? 9/30/2023), 1PA310305 (10/01/2021 ? 9/30/2022), 1PA310305 (10/01/2020 ? 9/30/2021), 1PA300305 (10/01/2021 ? 9/30/2022), 1PA300305 (10/01/2020 ? 9/30/2021), 1PA320305 (12/27/2020 ? 9/30/2021), Y22174 (10/01/2021 ? 9/30/2024), Y13194 (10/01/2020 ? 9/30/2023), Y03194 (10/01/2019 ? 9/30/2023), Y03191 (10/01/2019 ? 9/30/2020), Y22173 (10/01/2021 ? 9/30/2022), Y22172 (10/01/2021 ? 9/30/2022, Y13191 (10/01/2020 ? 9/30/2021), Y13061 (10/01/2020 ? 9/30/2021), S22AF00017 (1/01/2022 ? 12/31/2024), S21AF10050 (6/01/2021 ? 5/31/2024), S21AF10015 (1/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 9/30/2023), S20AF20006 (1/01/2020 ? 12/31/2022), S19AF20006 (1/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2023), S18AF20004 (11/01/2017 ? 10/31/2023), ERAE0131 (1/19/2021 ? 12/29/2022), ERAE0333 (5/11/2021 ? 12/30/2025), S010A210038 (7/01/2021 ? 9/30/2022), S010A200038 (7/01/2020 ? 9/30/2021), H027A210093 (7/01/2021 ? 9/30/2022), H027A200093 (7/01/2020 ? 9/30/2021), S425D200028 (3/13/2020 ? 9/30/2022), S425D210028 (3/13/2020 ? 9/30/2022), 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 2201PACSES (10/01/2021 ? 9/30/2022), 2101PACSES (10/01/2020 ? 9/30/2021), G2201PACCDF (10/01/2021 ? 9/30/2022), G2101PACCDF (10/01/2020 ? 9/30/2021), 2201PAFOST (10/01/2021 ? 9/30/2022), 2101PAFOST (10/01/2020 ? 9/30/2021), 2001PAFOST (10/01/2019 ? 9/30/2020), 2201PAADPT (10/01/2021 ? 9/30/2022), 2101PAADPT (10/01/2020 ? 9/30/2021), 2205PA5MAP (10/01/2021 ? 9/30/2022), 2105PA5MAP (10/01/2020 ? 9/30/2021) Finding 2022 ? 014: (continued) Type of Finding: Significant Deficiency, Noncompliance for Medicaid Cluster Material Weakness, Material Noncompliance for Other Programs Compliance Requirement: Subrecipient Monitoring Condition: Under the Commonwealth of Pennsylvania's (Commonwealth) implementation of the Single Audit Act, review and resolution of subrecipient Single Audit reports is split into two stages. The Office of the Budget?s Bureau of Accounting and Financial Management (OB-BAFM) ensures the reports meet technical standards through a centralized desk review process. The various funding agencies in the Commonwealth are responsible for making a management decision on each finding within six months of the Federal Audit Clearinghouse?s (FAC) Management Decision Letter (MDL) start date for audits subject to Uniform Guidance and to ensure appropriate corrective action is taken by the subrecipient (except for Uniform Guidance audits under U.S. Department of Labor programs which are permitted 12 months for management decisions in accordance with 2 CFR Section 2900.21). Each Commonwealth agency is also responsible for reviewing financial information in each audit report to determine whether the audit included all pass-through funding provided by the agency in order to ensure pass-through funds were subject to audit. Most agencies meet this requirement by performing Schedule of Expenditures of Federal Awards (SEFA) reconciliations. The agency is also required to adjust Commonwealth records, if necessary. Our fiscal year ended June 30, 2022 audit of the Commonwealth?s process for review and resolution of subrecipient Single Audits included an evaluation of the Commonwealth?s fiscal year ended June 30, 2021 subrecipient audit universe for audits due for submission to the FAC during the fiscal year ended June 30, 2022. We also evaluated the Commonwealth?s review of 44 subrecipient audit reports with findings in major programs/clusters which were identified on the Commonwealth agencies? tracking lists during the fiscal year ended June 30, 2022 and required management decisions by Commonwealth agencies. Our testing disclosed the following audit exceptions regarding the Commonwealth agencies? review of subrecipient audit reports: ? Department of Education (PDE): The time period for making a management decision on findings was approximately 6.5 to over 13 months after the FAC MDL start date for 14 out of 25 audit reports with findings. Three of the 14 audit reports were improperly classified on PDE?s audit tracking list as not having federal award findings. ? Department of Environmental Protection (DEP): The time period for making a management decision on findings was approximately 16.2 months after the FAC MDL start date for one out of three audit reports with findings. In addition, our review disclosed that DEP subgranted federal funds totaling $10,338,570 to one subrecipient during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended due to the COVID-19 pandemic in accordance with the Office of Management and Budget?s (OMB) Memorandum M-21-20, Appendix 3. ? Department of Health (DOH): Our review disclosed that DOH subgranted federal funds totaling $8,103,407 to one subrecipient during the fiscal year ended September 30, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 12.5 months after the December 31, 2021 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. ? Department of Human Services (DHS): The time period for making a management decision on findings ranged from approximately 6.6 months to over 19.6 months after the FAC MDL start date for 12 out of 14 subrecipient audit reports with findings. There was also a delay in DHS?s procedures to ensure the subrecipient SEFAs were accurate so that major programs were properly determined and subjected to audit. Finding 2022 ? 014: (continued) As a follow-up to the prior year finding, we noted that the Commonwealth subgranted federal funds totaling $327,988,063 to the City of Philadelphia during the fiscal year ended June 30, 2021, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 3.5 months after the September 30, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. Our testing disclosed that DHS?s subgrants to the City of Philadelphia were material for five of the 16 major programs/clusters with material subgranted funds. Our follow-up on the prior year finding also disclosed that the Commonwealth subgranted federal funds totaling $28,725,212 to Bucks County during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. DHS was the lead agency for the City of Philadelphia and Bucks County audits. Criteria: 2 CFR ?200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (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, and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 [Management decision]. (f) Verify that every subrecipient is audited as required by Subpart F [Audit Requirements] of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 [Audit requirements]. (g) Consider whether the results of the subrecipient?s audit, on-site review, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ?200.339 [Remedies for noncompliance] of this part and in program regulations. In order to carry out these responsibilities properly, good internal control dictates that state pass-through agencies ensure subrecipient Single Audit SEFAs are representative of state payment records each year, and that the related federal programs have been properly subjected to Single Audit procedures. 2 CFR ?200.512, Report submission, states in part: (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Finding 2022 ? 014: (continued) 2 CFR ?200.521, Management decision, states in part: (a) General. The management decision must clearly state whether or not the finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. 2 CFR ?200.505, Sanctions, states: In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, Federal agencies and pass-through entities must take appropriate action as provided in ?200.339 [Remedies for noncompliance]. 2 CFR ?200.339, Remedies for noncompliance, states in part: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.208 [Specific conditions]. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances. (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. To ensure Commonwealth enforcement of federal regulations for subrecipient noncompliance with audit requirements, Commonwealth Management Directive 325.08, Amended ? Remedies for Recipient Noncompliance with Audit Requirements, Section 5 related to policy, states in part: (a) Agencies must develop and implement remedial action that reflects the unique requirements of each program? (b) The remedial action should be implemented within six months from the date the first remedial action is initiated. At the end of the six-month period, the recipient should take the appropriate corrective action or the final stage of remedial action should be imposed on the recipient. Examples of remedial action include, but are not limited to: Finding 2022 ? 014: (continued) (1) Meeting or calling the recipient to explain the importance and benefits of the audit and audit resolution processes, emphasizing the value of the audit as an administrative tool and the Commonwealth?s reliance on an acceptable audit and prompt resolution as evidence of the recipient?s ability to properly administer the program. (2) Encouraging the entity to establish an audit committee or designate an individual as the single point of contact to: (a) Communicate regarding the audit. (b) Arrange for and oversee the audit. (c) Direct and monitor audit resolution. (3) Providing technical assistance to the recipient in devising and implementing an appropriate plan to remedy the noncompliance. (4) Withholding a portion of assistance payments until the noncompliance is resolved. (5) Withholding or disallowing overhead costs until the noncompliance is resolved. (6) Suspending the assistance agreement until the noncompliance is resolved. (7) Terminating the assistance agreement with the recipient and, if necessary, seeking alternative entities to administer the program. Management Directive 325.09, Amended ? Processing Subrecipient Single Audits of Federal Pass-Through Funds, Section 7 related to procedures, states in part: c. Agencies. (1) Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. (6) Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR ?200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. (7) Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s, Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: One reason provided by Commonwealth management for untimely audit resolution in the various agencies, including making management decisions, approving corrective action, and performing procedures to ensure the accuracy of subrecipient SEFAs, was either a change in staff or a lack of staff to follow up and process subrecipient audit reports more timely. The late management decision at DEP appeared to be the result of a subrecipient being treated as a contractor as described in current year Single Audit Finding #2022-005, despite having a subrecipient Single Audit requirement clause in its contract with DEP. Regarding late and outstanding audit report submissions, the Commonwealth agencies did not appear to be timely implementing remedial action steps in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.8 in order to ensure compliance with federal audit submission requirements. Finding 2022 ? 014: (continued) Effect: Since required management decisions were not made within six months to ensure appropriate corrective action was taken on audits received from subrecipients, the Commonwealth did not comply with federal regulations, and subrecipients were not made aware of acceptance or rejection of corrective action plans in a timely manner. Further, noncompliance may recur in future periods if control deficiencies are not corrected on a timely basis, and there is an increased risk of unallowable charges being made to federal programs if corrective action and recovery of questioned costs is not timely. Regarding the SEFA reviews or alternate procedures which are not being performed timely and the late Single Audit report submissions, there is an increased risk that subrecipients could be misspending and/or inappropriately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis as required. Finally, additional federal pass-through funds may be unaudited in the future without timely and effective remedial action from Commonwealth agencies to enforce compliance. Recommendation: We recommend that the above weaknesses that cause untimely subrecipient Single Audit resolution, including untimely management decisions on findings, untimely review of the SEFA or alternate procedures, and late audit report submissions be corrected to ensure compliance with federal requirements and Commonwealth Management Directives, and to better ensure timelier subrecipient compliance with program requirements. Commonwealth agencies should promptly pursue outstanding audits and implement remedial action steps on a timely basis in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08. PDE Response: PDE agrees with the finding. DEP Response: DEP agrees with the finding. DOH Response: DOH agrees with the finding. DHS Response: While DHS agrees with this finding, we believe we are in compliance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08 related to outstanding audits. We continue to work with counties and their independent auditors to obtain any late Single Audit reports, and albeit late, we do receive them which is the ultimate goal. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Various Agencies Finding 2022 ? 014: ALN 10.553, 10.555, 10.556, 10.559, and 10.582 ? Child Nutrition Cluster (including COVID-19) ALN 10.557 ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (including COVID-19) ALN 10.558 ? Child and Adult Care Food Program (including COVID-19) ALN 15.252 ? Abandoned Mine Land Reclamation ALN 21.023 ? COVID-19 ? Emergency Rental Assistance Program ALN 84.010 ? Title I Grants to Local Educational Agencies ALN 84.027 and 84.173 ? ? Special Education Cluster (IDEA) (including COVID-19) ALN 84.425C ? COVID 19 ? Education Stabilization Fund - GEER Fund ALN 84.425D ? COVID 19 ? Education Stabilization Fund - ESSER Fund ALN 84.425R ? COVID 19 ? Education Stabilization Fund - CRRSA EANS ALN 84.425U ? COVID 19 ? Education Stabilization Fund - ARP ESSER ALN 84.425W ? COVID 19 ? Education Stabilization Fund - ARP ESSER HCY ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) ALN 93.563 ? Child Support Enforcement ALN 93.575 and 93.596 ? Child Care and Development Fund (CCDF) Cluster (including COVID-19) ALN 93.658 ? Foster Care ? Title IV-E (including COVID-19) ALN 93.659 ? Adoption Assistance (including COVID-19) ALN 93.775, 93.777, and 93.778 ? Medicaid Cluster (including COVID-19) A Material Weakness and Material Noncompliance Exist in the Commonwealth?s Subrecipient Audit Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2021-015) Federal Grant Number(s) and Year(s): 1PA300365 (1/01/2022 ? 9/30/2023), 1PA310305 (10/01/2021 ? 9/30/2022), 1PA310305 (10/01/2020 ? 9/30/2021), 1PA300305 (10/01/2021 ? 9/30/2022), 1PA300305 (10/01/2020 ? 9/30/2021), 1PA320305 (12/27/2020 ? 9/30/2021), Y22174 (10/01/2021 ? 9/30/2024), Y13194 (10/01/2020 ? 9/30/2023), Y03194 (10/01/2019 ? 9/30/2023), Y03191 (10/01/2019 ? 9/30/2020), Y22173 (10/01/2021 ? 9/30/2022), Y22172 (10/01/2021 ? 9/30/2022, Y13191 (10/01/2020 ? 9/30/2021), Y13061 (10/01/2020 ? 9/30/2021), S22AF00017 (1/01/2022 ? 12/31/2024), S21AF10050 (6/01/2021 ? 5/31/2024), S21AF10015 (1/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 9/30/2023), S20AF20006 (1/01/2020 ? 12/31/2022), S19AF20006 (1/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2023), S18AF20004 (11/01/2017 ? 10/31/2023), ERAE0131 (1/19/2021 ? 12/29/2022), ERAE0333 (5/11/2021 ? 12/30/2025), S010A210038 (7/01/2021 ? 9/30/2022), S010A200038 (7/01/2020 ? 9/30/2021), H027A210093 (7/01/2021 ? 9/30/2022), H027A200093 (7/01/2020 ? 9/30/2021), S425D200028 (3/13/2020 ? 9/30/2022), S425D210028 (3/13/2020 ? 9/30/2022), 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 2201PACSES (10/01/2021 ? 9/30/2022), 2101PACSES (10/01/2020 ? 9/30/2021), G2201PACCDF (10/01/2021 ? 9/30/2022), G2101PACCDF (10/01/2020 ? 9/30/2021), 2201PAFOST (10/01/2021 ? 9/30/2022), 2101PAFOST (10/01/2020 ? 9/30/2021), 2001PAFOST (10/01/2019 ? 9/30/2020), 2201PAADPT (10/01/2021 ? 9/30/2022), 2101PAADPT (10/01/2020 ? 9/30/2021), 2205PA5MAP (10/01/2021 ? 9/30/2022), 2105PA5MAP (10/01/2020 ? 9/30/2021) Finding 2022 ? 014: (continued) Type of Finding: Significant Deficiency, Noncompliance for Medicaid Cluster Material Weakness, Material Noncompliance for Other Programs Compliance Requirement: Subrecipient Monitoring Condition: Under the Commonwealth of Pennsylvania's (Commonwealth) implementation of the Single Audit Act, review and resolution of subrecipient Single Audit reports is split into two stages. The Office of the Budget?s Bureau of Accounting and Financial Management (OB-BAFM) ensures the reports meet technical standards through a centralized desk review process. The various funding agencies in the Commonwealth are responsible for making a management decision on each finding within six months of the Federal Audit Clearinghouse?s (FAC) Management Decision Letter (MDL) start date for audits subject to Uniform Guidance and to ensure appropriate corrective action is taken by the subrecipient (except for Uniform Guidance audits under U.S. Department of Labor programs which are permitted 12 months for management decisions in accordance with 2 CFR Section 2900.21). Each Commonwealth agency is also responsible for reviewing financial information in each audit report to determine whether the audit included all pass-through funding provided by the agency in order to ensure pass-through funds were subject to audit. Most agencies meet this requirement by performing Schedule of Expenditures of Federal Awards (SEFA) reconciliations. The agency is also required to adjust Commonwealth records, if necessary. Our fiscal year ended June 30, 2022 audit of the Commonwealth?s process for review and resolution of subrecipient Single Audits included an evaluation of the Commonwealth?s fiscal year ended June 30, 2021 subrecipient audit universe for audits due for submission to the FAC during the fiscal year ended June 30, 2022. We also evaluated the Commonwealth?s review of 44 subrecipient audit reports with findings in major programs/clusters which were identified on the Commonwealth agencies? tracking lists during the fiscal year ended June 30, 2022 and required management decisions by Commonwealth agencies. Our testing disclosed the following audit exceptions regarding the Commonwealth agencies? review of subrecipient audit reports: ? Department of Education (PDE): The time period for making a management decision on findings was approximately 6.5 to over 13 months after the FAC MDL start date for 14 out of 25 audit reports with findings. Three of the 14 audit reports were improperly classified on PDE?s audit tracking list as not having federal award findings. ? Department of Environmental Protection (DEP): The time period for making a management decision on findings was approximately 16.2 months after the FAC MDL start date for one out of three audit reports with findings. In addition, our review disclosed that DEP subgranted federal funds totaling $10,338,570 to one subrecipient during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended due to the COVID-19 pandemic in accordance with the Office of Management and Budget?s (OMB) Memorandum M-21-20, Appendix 3. ? Department of Health (DOH): Our review disclosed that DOH subgranted federal funds totaling $8,103,407 to one subrecipient during the fiscal year ended September 30, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 12.5 months after the December 31, 2021 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. ? Department of Human Services (DHS): The time period for making a management decision on findings ranged from approximately 6.6 months to over 19.6 months after the FAC MDL start date for 12 out of 14 subrecipient audit reports with findings. There was also a delay in DHS?s procedures to ensure the subrecipient SEFAs were accurate so that major programs were properly determined and subjected to audit. Finding 2022 ? 014: (continued) As a follow-up to the prior year finding, we noted that the Commonwealth subgranted federal funds totaling $327,988,063 to the City of Philadelphia during the fiscal year ended June 30, 2021, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 3.5 months after the September 30, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. Our testing disclosed that DHS?s subgrants to the City of Philadelphia were material for five of the 16 major programs/clusters with material subgranted funds. Our follow-up on the prior year finding also disclosed that the Commonwealth subgranted federal funds totaling $28,725,212 to Bucks County during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. DHS was the lead agency for the City of Philadelphia and Bucks County audits. Criteria: 2 CFR ?200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (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, and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 [Management decision]. (f) Verify that every subrecipient is audited as required by Subpart F [Audit Requirements] of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 [Audit requirements]. (g) Consider whether the results of the subrecipient?s audit, on-site review, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ?200.339 [Remedies for noncompliance] of this part and in program regulations. In order to carry out these responsibilities properly, good internal control dictates that state pass-through agencies ensure subrecipient Single Audit SEFAs are representative of state payment records each year, and that the related federal programs have been properly subjected to Single Audit procedures. 2 CFR ?200.512, Report submission, states in part: (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Finding 2022 ? 014: (continued) 2 CFR ?200.521, Management decision, states in part: (a) General. The management decision must clearly state whether or not the finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. 2 CFR ?200.505, Sanctions, states: In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, Federal agencies and pass-through entities must take appropriate action as provided in ?200.339 [Remedies for noncompliance]. 2 CFR ?200.339, Remedies for noncompliance, states in part: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.208 [Specific conditions]. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances. (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. To ensure Commonwealth enforcement of federal regulations for subrecipient noncompliance with audit requirements, Commonwealth Management Directive 325.08, Amended ? Remedies for Recipient Noncompliance with Audit Requirements, Section 5 related to policy, states in part: (a) Agencies must develop and implement remedial action that reflects the unique requirements of each program? (b) The remedial action should be implemented within six months from the date the first remedial action is initiated. At the end of the six-month period, the recipient should take the appropriate corrective action or the final stage of remedial action should be imposed on the recipient. Examples of remedial action include, but are not limited to: Finding 2022 ? 014: (continued) (1) Meeting or calling the recipient to explain the importance and benefits of the audit and audit resolution processes, emphasizing the value of the audit as an administrative tool and the Commonwealth?s reliance on an acceptable audit and prompt resolution as evidence of the recipient?s ability to properly administer the program. (2) Encouraging the entity to establish an audit committee or designate an individual as the single point of contact to: (a) Communicate regarding the audit. (b) Arrange for and oversee the audit. (c) Direct and monitor audit resolution. (3) Providing technical assistance to the recipient in devising and implementing an appropriate plan to remedy the noncompliance. (4) Withholding a portion of assistance payments until the noncompliance is resolved. (5) Withholding or disallowing overhead costs until the noncompliance is resolved. (6) Suspending the assistance agreement until the noncompliance is resolved. (7) Terminating the assistance agreement with the recipient and, if necessary, seeking alternative entities to administer the program. Management Directive 325.09, Amended ? Processing Subrecipient Single Audits of Federal Pass-Through Funds, Section 7 related to procedures, states in part: c. Agencies. (1) Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. (6) Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR ?200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. (7) Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s, Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: One reason provided by Commonwealth management for untimely audit resolution in the various agencies, including making management decisions, approving corrective action, and performing procedures to ensure the accuracy of subrecipient SEFAs, was either a change in staff or a lack of staff to follow up and process subrecipient audit reports more timely. The late management decision at DEP appeared to be the result of a subrecipient being treated as a contractor as described in current year Single Audit Finding #2022-005, despite having a subrecipient Single Audit requirement clause in its contract with DEP. Regarding late and outstanding audit report submissions, the Commonwealth agencies did not appear to be timely implementing remedial action steps in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.8 in order to ensure compliance with federal audit submission requirements. Finding 2022 ? 014: (continued) Effect: Since required management decisions were not made within six months to ensure appropriate corrective action was taken on audits received from subrecipients, the Commonwealth did not comply with federal regulations, and subrecipients were not made aware of acceptance or rejection of corrective action plans in a timely manner. Further, noncompliance may recur in future periods if control deficiencies are not corrected on a timely basis, and there is an increased risk of unallowable charges being made to federal programs if corrective action and recovery of questioned costs is not timely. Regarding the SEFA reviews or alternate procedures which are not being performed timely and the late Single Audit report submissions, there is an increased risk that subrecipients could be misspending and/or inappropriately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis as required. Finally, additional federal pass-through funds may be unaudited in the future without timely and effective remedial action from Commonwealth agencies to enforce compliance. Recommendation: We recommend that the above weaknesses that cause untimely subrecipient Single Audit resolution, including untimely management decisions on findings, untimely review of the SEFA or alternate procedures, and late audit report submissions be corrected to ensure compliance with federal requirements and Commonwealth Management Directives, and to better ensure timelier subrecipient compliance with program requirements. Commonwealth agencies should promptly pursue outstanding audits and implement remedial action steps on a timely basis in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08. PDE Response: PDE agrees with the finding. DEP Response: DEP agrees with the finding. DOH Response: DOH agrees with the finding. DHS Response: While DHS agrees with this finding, we believe we are in compliance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08 related to outstanding audits. We continue to work with counties and their independent auditors to obtain any late Single Audit reports, and albeit late, we do receive them which is the ultimate goal. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Various Agencies Finding 2022 ? 014: ALN 10.553, 10.555, 10.556, 10.559, and 10.582 ? Child Nutrition Cluster (including COVID-19) ALN 10.557 ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (including COVID-19) ALN 10.558 ? Child and Adult Care Food Program (including COVID-19) ALN 15.252 ? Abandoned Mine Land Reclamation ALN 21.023 ? COVID-19 ? Emergency Rental Assistance Program ALN 84.010 ? Title I Grants to Local Educational Agencies ALN 84.027 and 84.173 ? ? Special Education Cluster (IDEA) (including COVID-19) ALN 84.425C ? COVID 19 ? Education Stabilization Fund - GEER Fund ALN 84.425D ? COVID 19 ? Education Stabilization Fund - ESSER Fund ALN 84.425R ? COVID 19 ? Education Stabilization Fund - CRRSA EANS ALN 84.425U ? COVID 19 ? Education Stabilization Fund - ARP ESSER ALN 84.425W ? COVID 19 ? Education Stabilization Fund - ARP ESSER HCY ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) ALN 93.563 ? Child Support Enforcement ALN 93.575 and 93.596 ? Child Care and Development Fund (CCDF) Cluster (including COVID-19) ALN 93.658 ? Foster Care ? Title IV-E (including COVID-19) ALN 93.659 ? Adoption Assistance (including COVID-19) ALN 93.775, 93.777, and 93.778 ? Medicaid Cluster (including COVID-19) A Material Weakness and Material Noncompliance Exist in the Commonwealth?s Subrecipient Audit Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2021-015) Federal Grant Number(s) and Year(s): 1PA300365 (1/01/2022 ? 9/30/2023), 1PA310305 (10/01/2021 ? 9/30/2022), 1PA310305 (10/01/2020 ? 9/30/2021), 1PA300305 (10/01/2021 ? 9/30/2022), 1PA300305 (10/01/2020 ? 9/30/2021), 1PA320305 (12/27/2020 ? 9/30/2021), Y22174 (10/01/2021 ? 9/30/2024), Y13194 (10/01/2020 ? 9/30/2023), Y03194 (10/01/2019 ? 9/30/2023), Y03191 (10/01/2019 ? 9/30/2020), Y22173 (10/01/2021 ? 9/30/2022), Y22172 (10/01/2021 ? 9/30/2022, Y13191 (10/01/2020 ? 9/30/2021), Y13061 (10/01/2020 ? 9/30/2021), S22AF00017 (1/01/2022 ? 12/31/2024), S21AF10050 (6/01/2021 ? 5/31/2024), S21AF10015 (1/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 9/30/2023), S20AF20006 (1/01/2020 ? 12/31/2022), S19AF20006 (1/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2023), S18AF20004 (11/01/2017 ? 10/31/2023), ERAE0131 (1/19/2021 ? 12/29/2022), ERAE0333 (5/11/2021 ? 12/30/2025), S010A210038 (7/01/2021 ? 9/30/2022), S010A200038 (7/01/2020 ? 9/30/2021), H027A210093 (7/01/2021 ? 9/30/2022), H027A200093 (7/01/2020 ? 9/30/2021), S425D200028 (3/13/2020 ? 9/30/2022), S425D210028 (3/13/2020 ? 9/30/2022), 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 2201PACSES (10/01/2021 ? 9/30/2022), 2101PACSES (10/01/2020 ? 9/30/2021), G2201PACCDF (10/01/2021 ? 9/30/2022), G2101PACCDF (10/01/2020 ? 9/30/2021), 2201PAFOST (10/01/2021 ? 9/30/2022), 2101PAFOST (10/01/2020 ? 9/30/2021), 2001PAFOST (10/01/2019 ? 9/30/2020), 2201PAADPT (10/01/2021 ? 9/30/2022), 2101PAADPT (10/01/2020 ? 9/30/2021), 2205PA5MAP (10/01/2021 ? 9/30/2022), 2105PA5MAP (10/01/2020 ? 9/30/2021) Finding 2022 ? 014: (continued) Type of Finding: Significant Deficiency, Noncompliance for Medicaid Cluster Material Weakness, Material Noncompliance for Other Programs Compliance Requirement: Subrecipient Monitoring Condition: Under the Commonwealth of Pennsylvania's (Commonwealth) implementation of the Single Audit Act, review and resolution of subrecipient Single Audit reports is split into two stages. The Office of the Budget?s Bureau of Accounting and Financial Management (OB-BAFM) ensures the reports meet technical standards through a centralized desk review process. The various funding agencies in the Commonwealth are responsible for making a management decision on each finding within six months of the Federal Audit Clearinghouse?s (FAC) Management Decision Letter (MDL) start date for audits subject to Uniform Guidance and to ensure appropriate corrective action is taken by the subrecipient (except for Uniform Guidance audits under U.S. Department of Labor programs which are permitted 12 months for management decisions in accordance with 2 CFR Section 2900.21). Each Commonwealth agency is also responsible for reviewing financial information in each audit report to determine whether the audit included all pass-through funding provided by the agency in order to ensure pass-through funds were subject to audit. Most agencies meet this requirement by performing Schedule of Expenditures of Federal Awards (SEFA) reconciliations. The agency is also required to adjust Commonwealth records, if necessary. Our fiscal year ended June 30, 2022 audit of the Commonwealth?s process for review and resolution of subrecipient Single Audits included an evaluation of the Commonwealth?s fiscal year ended June 30, 2021 subrecipient audit universe for audits due for submission to the FAC during the fiscal year ended June 30, 2022. We also evaluated the Commonwealth?s review of 44 subrecipient audit reports with findings in major programs/clusters which were identified on the Commonwealth agencies? tracking lists during the fiscal year ended June 30, 2022 and required management decisions by Commonwealth agencies. Our testing disclosed the following audit exceptions regarding the Commonwealth agencies? review of subrecipient audit reports: ? Department of Education (PDE): The time period for making a management decision on findings was approximately 6.5 to over 13 months after the FAC MDL start date for 14 out of 25 audit reports with findings. Three of the 14 audit reports were improperly classified on PDE?s audit tracking list as not having federal award findings. ? Department of Environmental Protection (DEP): The time period for making a management decision on findings was approximately 16.2 months after the FAC MDL start date for one out of three audit reports with findings. In addition, our review disclosed that DEP subgranted federal funds totaling $10,338,570 to one subrecipient during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended due to the COVID-19 pandemic in accordance with the Office of Management and Budget?s (OMB) Memorandum M-21-20, Appendix 3. ? Department of Health (DOH): Our review disclosed that DOH subgranted federal funds totaling $8,103,407 to one subrecipient during the fiscal year ended September 30, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 12.5 months after the December 31, 2021 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. ? Department of Human Services (DHS): The time period for making a management decision on findings ranged from approximately 6.6 months to over 19.6 months after the FAC MDL start date for 12 out of 14 subrecipient audit reports with findings. There was also a delay in DHS?s procedures to ensure the subrecipient SEFAs were accurate so that major programs were properly determined and subjected to audit. Finding 2022 ? 014: (continued) As a follow-up to the prior year finding, we noted that the Commonwealth subgranted federal funds totaling $327,988,063 to the City of Philadelphia during the fiscal year ended June 30, 2021, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 3.5 months after the September 30, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. Our testing disclosed that DHS?s subgrants to the City of Philadelphia were material for five of the 16 major programs/clusters with material subgranted funds. Our follow-up on the prior year finding also disclosed that the Commonwealth subgranted federal funds totaling $28,725,212 to Bucks County during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. DHS was the lead agency for the City of Philadelphia and Bucks County audits. Criteria: 2 CFR ?200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (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, and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 [Management decision]. (f) Verify that every subrecipient is audited as required by Subpart F [Audit Requirements] of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 [Audit requirements]. (g) Consider whether the results of the subrecipient?s audit, on-site review, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ?200.339 [Remedies for noncompliance] of this part and in program regulations. In order to carry out these responsibilities properly, good internal control dictates that state pass-through agencies ensure subrecipient Single Audit SEFAs are representative of state payment records each year, and that the related federal programs have been properly subjected to Single Audit procedures. 2 CFR ?200.512, Report submission, states in part: (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Finding 2022 ? 014: (continued) 2 CFR ?200.521, Management decision, states in part: (a) General. The management decision must clearly state whether or not the finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. 2 CFR ?200.505, Sanctions, states: In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, Federal agencies and pass-through entities must take appropriate action as provided in ?200.339 [Remedies for noncompliance]. 2 CFR ?200.339, Remedies for noncompliance, states in part: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.208 [Specific conditions]. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances. (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. To ensure Commonwealth enforcement of federal regulations for subrecipient noncompliance with audit requirements, Commonwealth Management Directive 325.08, Amended ? Remedies for Recipient Noncompliance with Audit Requirements, Section 5 related to policy, states in part: (a) Agencies must develop and implement remedial action that reflects the unique requirements of each program? (b) The remedial action should be implemented within six months from the date the first remedial action is initiated. At the end of the six-month period, the recipient should take the appropriate corrective action or the final stage of remedial action should be imposed on the recipient. Examples of remedial action include, but are not limited to: Finding 2022 ? 014: (continued) (1) Meeting or calling the recipient to explain the importance and benefits of the audit and audit resolution processes, emphasizing the value of the audit as an administrative tool and the Commonwealth?s reliance on an acceptable audit and prompt resolution as evidence of the recipient?s ability to properly administer the program. (2) Encouraging the entity to establish an audit committee or designate an individual as the single point of contact to: (a) Communicate regarding the audit. (b) Arrange for and oversee the audit. (c) Direct and monitor audit resolution. (3) Providing technical assistance to the recipient in devising and implementing an appropriate plan to remedy the noncompliance. (4) Withholding a portion of assistance payments until the noncompliance is resolved. (5) Withholding or disallowing overhead costs until the noncompliance is resolved. (6) Suspending the assistance agreement until the noncompliance is resolved. (7) Terminating the assistance agreement with the recipient and, if necessary, seeking alternative entities to administer the program. Management Directive 325.09, Amended ? Processing Subrecipient Single Audits of Federal Pass-Through Funds, Section 7 related to procedures, states in part: c. Agencies. (1) Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. (6) Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR ?200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. (7) Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s, Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: One reason provided by Commonwealth management for untimely audit resolution in the various agencies, including making management decisions, approving corrective action, and performing procedures to ensure the accuracy of subrecipient SEFAs, was either a change in staff or a lack of staff to follow up and process subrecipient audit reports more timely. The late management decision at DEP appeared to be the result of a subrecipient being treated as a contractor as described in current year Single Audit Finding #2022-005, despite having a subrecipient Single Audit requirement clause in its contract with DEP. Regarding late and outstanding audit report submissions, the Commonwealth agencies did not appear to be timely implementing remedial action steps in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.8 in order to ensure compliance with federal audit submission requirements. Finding 2022 ? 014: (continued) Effect: Since required management decisions were not made within six months to ensure appropriate corrective action was taken on audits received from subrecipients, the Commonwealth did not comply with federal regulations, and subrecipients were not made aware of acceptance or rejection of corrective action plans in a timely manner. Further, noncompliance may recur in future periods if control deficiencies are not corrected on a timely basis, and there is an increased risk of unallowable charges being made to federal programs if corrective action and recovery of questioned costs is not timely. Regarding the SEFA reviews or alternate procedures which are not being performed timely and the late Single Audit report submissions, there is an increased risk that subrecipients could be misspending and/or inappropriately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis as required. Finally, additional federal pass-through funds may be unaudited in the future without timely and effective remedial action from Commonwealth agencies to enforce compliance. Recommendation: We recommend that the above weaknesses that cause untimely subrecipient Single Audit resolution, including untimely management decisions on findings, untimely review of the SEFA or alternate procedures, and late audit report submissions be corrected to ensure compliance with federal requirements and Commonwealth Management Directives, and to better ensure timelier subrecipient compliance with program requirements. Commonwealth agencies should promptly pursue outstanding audits and implement remedial action steps on a timely basis in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08. PDE Response: PDE agrees with the finding. DEP Response: DEP agrees with the finding. DOH Response: DOH agrees with the finding. DHS Response: While DHS agrees with this finding, we believe we are in compliance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08 related to outstanding audits. We continue to work with counties and their independent auditors to obtain any late Single Audit reports, and albeit late, we do receive them which is the ultimate goal. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Various Agencies Finding 2022 ? 014: ALN 10.553, 10.555, 10.556, 10.559, and 10.582 ? Child Nutrition Cluster (including COVID-19) ALN 10.557 ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (including COVID-19) ALN 10.558 ? Child and Adult Care Food Program (including COVID-19) ALN 15.252 ? Abandoned Mine Land Reclamation ALN 21.023 ? COVID-19 ? Emergency Rental Assistance Program ALN 84.010 ? Title I Grants to Local Educational Agencies ALN 84.027 and 84.173 ? ? Special Education Cluster (IDEA) (including COVID-19) ALN 84.425C ? COVID 19 ? Education Stabilization Fund - GEER Fund ALN 84.425D ? COVID 19 ? Education Stabilization Fund - ESSER Fund ALN 84.425R ? COVID 19 ? Education Stabilization Fund - CRRSA EANS ALN 84.425U ? COVID 19 ? Education Stabilization Fund - ARP ESSER ALN 84.425W ? COVID 19 ? Education Stabilization Fund - ARP ESSER HCY ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) ALN 93.563 ? Child Support Enforcement ALN 93.575 and 93.596 ? Child Care and Development Fund (CCDF) Cluster (including COVID-19) ALN 93.658 ? Foster Care ? Title IV-E (including COVID-19) ALN 93.659 ? Adoption Assistance (including COVID-19) ALN 93.775, 93.777, and 93.778 ? Medicaid Cluster (including COVID-19) A Material Weakness and Material Noncompliance Exist in the Commonwealth?s Subrecipient Audit Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2021-015) Federal Grant Number(s) and Year(s): 1PA300365 (1/01/2022 ? 9/30/2023), 1PA310305 (10/01/2021 ? 9/30/2022), 1PA310305 (10/01/2020 ? 9/30/2021), 1PA300305 (10/01/2021 ? 9/30/2022), 1PA300305 (10/01/2020 ? 9/30/2021), 1PA320305 (12/27/2020 ? 9/30/2021), Y22174 (10/01/2021 ? 9/30/2024), Y13194 (10/01/2020 ? 9/30/2023), Y03194 (10/01/2019 ? 9/30/2023), Y03191 (10/01/2019 ? 9/30/2020), Y22173 (10/01/2021 ? 9/30/2022), Y22172 (10/01/2021 ? 9/30/2022, Y13191 (10/01/2020 ? 9/30/2021), Y13061 (10/01/2020 ? 9/30/2021), S22AF00017 (1/01/2022 ? 12/31/2024), S21AF10050 (6/01/2021 ? 5/31/2024), S21AF10015 (1/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 9/30/2023), S20AF20006 (1/01/2020 ? 12/31/2022), S19AF20006 (1/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2023), S18AF20004 (11/01/2017 ? 10/31/2023), ERAE0131 (1/19/2021 ? 12/29/2022), ERAE0333 (5/11/2021 ? 12/30/2025), S010A210038 (7/01/2021 ? 9/30/2022), S010A200038 (7/01/2020 ? 9/30/2021), H027A210093 (7/01/2021 ? 9/30/2022), H027A200093 (7/01/2020 ? 9/30/2021), S425D200028 (3/13/2020 ? 9/30/2022), S425D210028 (3/13/2020 ? 9/30/2022), 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 2201PACSES (10/01/2021 ? 9/30/2022), 2101PACSES (10/01/2020 ? 9/30/2021), G2201PACCDF (10/01/2021 ? 9/30/2022), G2101PACCDF (10/01/2020 ? 9/30/2021), 2201PAFOST (10/01/2021 ? 9/30/2022), 2101PAFOST (10/01/2020 ? 9/30/2021), 2001PAFOST (10/01/2019 ? 9/30/2020), 2201PAADPT (10/01/2021 ? 9/30/2022), 2101PAADPT (10/01/2020 ? 9/30/2021), 2205PA5MAP (10/01/2021 ? 9/30/2022), 2105PA5MAP (10/01/2020 ? 9/30/2021) Finding 2022 ? 014: (continued) Type of Finding: Significant Deficiency, Noncompliance for Medicaid Cluster Material Weakness, Material Noncompliance for Other Programs Compliance Requirement: Subrecipient Monitoring Condition: Under the Commonwealth of Pennsylvania's (Commonwealth) implementation of the Single Audit Act, review and resolution of subrecipient Single Audit reports is split into two stages. The Office of the Budget?s Bureau of Accounting and Financial Management (OB-BAFM) ensures the reports meet technical standards through a centralized desk review process. The various funding agencies in the Commonwealth are responsible for making a management decision on each finding within six months of the Federal Audit Clearinghouse?s (FAC) Management Decision Letter (MDL) start date for audits subject to Uniform Guidance and to ensure appropriate corrective action is taken by the subrecipient (except for Uniform Guidance audits under U.S. Department of Labor programs which are permitted 12 months for management decisions in accordance with 2 CFR Section 2900.21). Each Commonwealth agency is also responsible for reviewing financial information in each audit report to determine whether the audit included all pass-through funding provided by the agency in order to ensure pass-through funds were subject to audit. Most agencies meet this requirement by performing Schedule of Expenditures of Federal Awards (SEFA) reconciliations. The agency is also required to adjust Commonwealth records, if necessary. Our fiscal year ended June 30, 2022 audit of the Commonwealth?s process for review and resolution of subrecipient Single Audits included an evaluation of the Commonwealth?s fiscal year ended June 30, 2021 subrecipient audit universe for audits due for submission to the FAC during the fiscal year ended June 30, 2022. We also evaluated the Commonwealth?s review of 44 subrecipient audit reports with findings in major programs/clusters which were identified on the Commonwealth agencies? tracking lists during the fiscal year ended June 30, 2022 and required management decisions by Commonwealth agencies. Our testing disclosed the following audit exceptions regarding the Commonwealth agencies? review of subrecipient audit reports: ? Department of Education (PDE): The time period for making a management decision on findings was approximately 6.5 to over 13 months after the FAC MDL start date for 14 out of 25 audit reports with findings. Three of the 14 audit reports were improperly classified on PDE?s audit tracking list as not having federal award findings. ? Department of Environmental Protection (DEP): The time period for making a management decision on findings was approximately 16.2 months after the FAC MDL start date for one out of three audit reports with findings. In addition, our review disclosed that DEP subgranted federal funds totaling $10,338,570 to one subrecipient during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended due to the COVID-19 pandemic in accordance with the Office of Management and Budget?s (OMB) Memorandum M-21-20, Appendix 3. ? Department of Health (DOH): Our review disclosed that DOH subgranted federal funds totaling $8,103,407 to one subrecipient during the fiscal year ended September 30, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 12.5 months after the December 31, 2021 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. ? Department of Human Services (DHS): The time period for making a management decision on findings ranged from approximately 6.6 months to over 19.6 months after the FAC MDL start date for 12 out of 14 subrecipient audit reports with findings. There was also a delay in DHS?s procedures to ensure the subrecipient SEFAs were accurate so that major programs were properly determined and subjected to audit. Finding 2022 ? 014: (continued) As a follow-up to the prior year finding, we noted that the Commonwealth subgranted federal funds totaling $327,988,063 to the City of Philadelphia during the fiscal year ended June 30, 2021, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 3.5 months after the September 30, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. Our testing disclosed that DHS?s subgrants to the City of Philadelphia were material for five of the 16 major programs/clusters with material subgranted funds. Our follow-up on the prior year finding also disclosed that the Commonwealth subgranted federal funds totaling $28,725,212 to Bucks County during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. DHS was the lead agency for the City of Philadelphia and Bucks County audits. Criteria: 2 CFR ?200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (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, and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 [Management decision]. (f) Verify that every subrecipient is audited as required by Subpart F [Audit Requirements] of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 [Audit requirements]. (g) Consider whether the results of the subrecipient?s audit, on-site review, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ?200.339 [Remedies for noncompliance] of this part and in program regulations. In order to carry out these responsibilities properly, good internal control dictates that state pass-through agencies ensure subrecipient Single Audit SEFAs are representative of state payment records each year, and that the related federal programs have been properly subjected to Single Audit procedures. 2 CFR ?200.512, Report submission, states in part: (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Finding 2022 ? 014: (continued) 2 CFR ?200.521, Management decision, states in part: (a) General. The management decision must clearly state whether or not the finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. 2 CFR ?200.505, Sanctions, states: In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, Federal agencies and pass-through entities must take appropriate action as provided in ?200.339 [Remedies for noncompliance]. 2 CFR ?200.339, Remedies for noncompliance, states in part: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.208 [Specific conditions]. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances. (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. To ensure Commonwealth enforcement of federal regulations for subrecipient noncompliance with audit requirements, Commonwealth Management Directive 325.08, Amended ? Remedies for Recipient Noncompliance with Audit Requirements, Section 5 related to policy, states in part: (a) Agencies must develop and implement remedial action that reflects the unique requirements of each program? (b) The remedial action should be implemented within six months from the date the first remedial action is initiated. At the end of the six-month period, the recipient should take the appropriate corrective action or the final stage of remedial action should be imposed on the recipient. Examples of remedial action include, but are not limited to: Finding 2022 ? 014: (continued) (1) Meeting or calling the recipient to explain the importance and benefits of the audit and audit resolution processes, emphasizing the value of the audit as an administrative tool and the Commonwealth?s reliance on an acceptable audit and prompt resolution as evidence of the recipient?s ability to properly administer the program. (2) Encouraging the entity to establish an audit committee or designate an individual as the single point of contact to: (a) Communicate regarding the audit. (b) Arrange for and oversee the audit. (c) Direct and monitor audit resolution. (3) Providing technical assistance to the recipient in devising and implementing an appropriate plan to remedy the noncompliance. (4) Withholding a portion of assistance payments until the noncompliance is resolved. (5) Withholding or disallowing overhead costs until the noncompliance is resolved. (6) Suspending the assistance agreement until the noncompliance is resolved. (7) Terminating the assistance agreement with the recipient and, if necessary, seeking alternative entities to administer the program. Management Directive 325.09, Amended ? Processing Subrecipient Single Audits of Federal Pass-Through Funds, Section 7 related to procedures, states in part: c. Agencies. (1) Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. (6) Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR ?200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. (7) Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s, Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: One reason provided by Commonwealth management for untimely audit resolution in the various agencies, including making management decisions, approving corrective action, and performing procedures to ensure the accuracy of subrecipient SEFAs, was either a change in staff or a lack of staff to follow up and process subrecipient audit reports more timely. The late management decision at DEP appeared to be the result of a subrecipient being treated as a contractor as described in current year Single Audit Finding #2022-005, despite having a subrecipient Single Audit requirement clause in its contract with DEP. Regarding late and outstanding audit report submissions, the Commonwealth agencies did not appear to be timely implementing remedial action steps in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.8 in order to ensure compliance with federal audit submission requirements. Finding 2022 ? 014: (continued) Effect: Since required management decisions were not made within six months to ensure appropriate corrective action was taken on audits received from subrecipients, the Commonwealth did not comply with federal regulations, and subrecipients were not made aware of acceptance or rejection of corrective action plans in a timely manner. Further, noncompliance may recur in future periods if control deficiencies are not corrected on a timely basis, and there is an increased risk of unallowable charges being made to federal programs if corrective action and recovery of questioned costs is not timely. Regarding the SEFA reviews or alternate procedures which are not being performed timely and the late Single Audit report submissions, there is an increased risk that subrecipients could be misspending and/or inappropriately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis as required. Finally, additional federal pass-through funds may be unaudited in the future without timely and effective remedial action from Commonwealth agencies to enforce compliance. Recommendation: We recommend that the above weaknesses that cause untimely subrecipient Single Audit resolution, including untimely management decisions on findings, untimely review of the SEFA or alternate procedures, and late audit report submissions be corrected to ensure compliance with federal requirements and Commonwealth Management Directives, and to better ensure timelier subrecipient compliance with program requirements. Commonwealth agencies should promptly pursue outstanding audits and implement remedial action steps on a timely basis in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08. PDE Response: PDE agrees with the finding. DEP Response: DEP agrees with the finding. DOH Response: DOH agrees with the finding. DHS Response: While DHS agrees with this finding, we believe we are in compliance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08 related to outstanding audits. We continue to work with counties and their independent auditors to obtain any late Single Audit reports, and albeit late, we do receive them which is the ultimate goal. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Various Agencies Finding 2022 ? 014: ALN 10.553, 10.555, 10.556, 10.559, and 10.582 ? Child Nutrition Cluster (including COVID-19) ALN 10.557 ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (including COVID-19) ALN 10.558 ? Child and Adult Care Food Program (including COVID-19) ALN 15.252 ? Abandoned Mine Land Reclamation ALN 21.023 ? COVID-19 ? Emergency Rental Assistance Program ALN 84.010 ? Title I Grants to Local Educational Agencies ALN 84.027 and 84.173 ? ? Special Education Cluster (IDEA) (including COVID-19) ALN 84.425C ? COVID 19 ? Education Stabilization Fund - GEER Fund ALN 84.425D ? COVID 19 ? Education Stabilization Fund - ESSER Fund ALN 84.425R ? COVID 19 ? Education Stabilization Fund - CRRSA EANS ALN 84.425U ? COVID 19 ? Education Stabilization Fund - ARP ESSER ALN 84.425W ? COVID 19 ? Education Stabilization Fund - ARP ESSER HCY ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) ALN 93.563 ? Child Support Enforcement ALN 93.575 and 93.596 ? Child Care and Development Fund (CCDF) Cluster (including COVID-19) ALN 93.658 ? Foster Care ? Title IV-E (including COVID-19) ALN 93.659 ? Adoption Assistance (including COVID-19) ALN 93.775, 93.777, and 93.778 ? Medicaid Cluster (including COVID-19) A Material Weakness and Material Noncompliance Exist in the Commonwealth?s Subrecipient Audit Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2021-015) Federal Grant Number(s) and Year(s): 1PA300365 (1/01/2022 ? 9/30/2023), 1PA310305 (10/01/2021 ? 9/30/2022), 1PA310305 (10/01/2020 ? 9/30/2021), 1PA300305 (10/01/2021 ? 9/30/2022), 1PA300305 (10/01/2020 ? 9/30/2021), 1PA320305 (12/27/2020 ? 9/30/2021), Y22174 (10/01/2021 ? 9/30/2024), Y13194 (10/01/2020 ? 9/30/2023), Y03194 (10/01/2019 ? 9/30/2023), Y03191 (10/01/2019 ? 9/30/2020), Y22173 (10/01/2021 ? 9/30/2022), Y22172 (10/01/2021 ? 9/30/2022, Y13191 (10/01/2020 ? 9/30/2021), Y13061 (10/01/2020 ? 9/30/2021), S22AF00017 (1/01/2022 ? 12/31/2024), S21AF10050 (6/01/2021 ? 5/31/2024), S21AF10015 (1/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 9/30/2023), S20AF20006 (1/01/2020 ? 12/31/2022), S19AF20006 (1/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2023), S18AF20004 (11/01/2017 ? 10/31/2023), ERAE0131 (1/19/2021 ? 12/29/2022), ERAE0333 (5/11/2021 ? 12/30/2025), S010A210038 (7/01/2021 ? 9/30/2022), S010A200038 (7/01/2020 ? 9/30/2021), H027A210093 (7/01/2021 ? 9/30/2022), H027A200093 (7/01/2020 ? 9/30/2021), S425D200028 (3/13/2020 ? 9/30/2022), S425D210028 (3/13/2020 ? 9/30/2022), 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 2201PACSES (10/01/2021 ? 9/30/2022), 2101PACSES (10/01/2020 ? 9/30/2021), G2201PACCDF (10/01/2021 ? 9/30/2022), G2101PACCDF (10/01/2020 ? 9/30/2021), 2201PAFOST (10/01/2021 ? 9/30/2022), 2101PAFOST (10/01/2020 ? 9/30/2021), 2001PAFOST (10/01/2019 ? 9/30/2020), 2201PAADPT (10/01/2021 ? 9/30/2022), 2101PAADPT (10/01/2020 ? 9/30/2021), 2205PA5MAP (10/01/2021 ? 9/30/2022), 2105PA5MAP (10/01/2020 ? 9/30/2021) Finding 2022 ? 014: (continued) Type of Finding: Significant Deficiency, Noncompliance for Medicaid Cluster Material Weakness, Material Noncompliance for Other Programs Compliance Requirement: Subrecipient Monitoring Condition: Under the Commonwealth of Pennsylvania's (Commonwealth) implementation of the Single Audit Act, review and resolution of subrecipient Single Audit reports is split into two stages. The Office of the Budget?s Bureau of Accounting and Financial Management (OB-BAFM) ensures the reports meet technical standards through a centralized desk review process. The various funding agencies in the Commonwealth are responsible for making a management decision on each finding within six months of the Federal Audit Clearinghouse?s (FAC) Management Decision Letter (MDL) start date for audits subject to Uniform Guidance and to ensure appropriate corrective action is taken by the subrecipient (except for Uniform Guidance audits under U.S. Department of Labor programs which are permitted 12 months for management decisions in accordance with 2 CFR Section 2900.21). Each Commonwealth agency is also responsible for reviewing financial information in each audit report to determine whether the audit included all pass-through funding provided by the agency in order to ensure pass-through funds were subject to audit. Most agencies meet this requirement by performing Schedule of Expenditures of Federal Awards (SEFA) reconciliations. The agency is also required to adjust Commonwealth records, if necessary. Our fiscal year ended June 30, 2022 audit of the Commonwealth?s process for review and resolution of subrecipient Single Audits included an evaluation of the Commonwealth?s fiscal year ended June 30, 2021 subrecipient audit universe for audits due for submission to the FAC during the fiscal year ended June 30, 2022. We also evaluated the Commonwealth?s review of 44 subrecipient audit reports with findings in major programs/clusters which were identified on the Commonwealth agencies? tracking lists during the fiscal year ended June 30, 2022 and required management decisions by Commonwealth agencies. Our testing disclosed the following audit exceptions regarding the Commonwealth agencies? review of subrecipient audit reports: ? Department of Education (PDE): The time period for making a management decision on findings was approximately 6.5 to over 13 months after the FAC MDL start date for 14 out of 25 audit reports with findings. Three of the 14 audit reports were improperly classified on PDE?s audit tracking list as not having federal award findings. ? Department of Environmental Protection (DEP): The time period for making a management decision on findings was approximately 16.2 months after the FAC MDL start date for one out of three audit reports with findings. In addition, our review disclosed that DEP subgranted federal funds totaling $10,338,570 to one subrecipient during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended due to the COVID-19 pandemic in accordance with the Office of Management and Budget?s (OMB) Memorandum M-21-20, Appendix 3. ? Department of Health (DOH): Our review disclosed that DOH subgranted federal funds totaling $8,103,407 to one subrecipient during the fiscal year ended September 30, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 12.5 months after the December 31, 2021 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. ? Department of Human Services (DHS): The time period for making a management decision on findings ranged from approximately 6.6 months to over 19.6 months after the FAC MDL start date for 12 out of 14 subrecipient audit reports with findings. There was also a delay in DHS?s procedures to ensure the subrecipient SEFAs were accurate so that major programs were properly determined and subjected to audit. Finding 2022 ? 014: (continued) As a follow-up to the prior year finding, we noted that the Commonwealth subgranted federal funds totaling $327,988,063 to the City of Philadelphia during the fiscal year ended June 30, 2021, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 3.5 months after the September 30, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. Our testing disclosed that DHS?s subgrants to the City of Philadelphia were material for five of the 16 major programs/clusters with material subgranted funds. Our follow-up on the prior year finding also disclosed that the Commonwealth subgranted federal funds totaling $28,725,212 to Bucks County during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. DHS was the lead agency for the City of Philadelphia and Bucks County audits. Criteria: 2 CFR ?200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (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, and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 [Management decision]. (f) Verify that every subrecipient is audited as required by Subpart F [Audit Requirements] of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 [Audit requirements]. (g) Consider whether the results of the subrecipient?s audit, on-site review, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ?200.339 [Remedies for noncompliance] of this part and in program regulations. In order to carry out these responsibilities properly, good internal control dictates that state pass-through agencies ensure subrecipient Single Audit SEFAs are representative of state payment records each year, and that the related federal programs have been properly subjected to Single Audit procedures. 2 CFR ?200.512, Report submission, states in part: (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Finding 2022 ? 014: (continued) 2 CFR ?200.521, Management decision, states in part: (a) General. The management decision must clearly state whether or not the finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. 2 CFR ?200.505, Sanctions, states: In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, Federal agencies and pass-through entities must take appropriate action as provided in ?200.339 [Remedies for noncompliance]. 2 CFR ?200.339, Remedies for noncompliance, states in part: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.208 [Specific conditions]. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances. (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. To ensure Commonwealth enforcement of federal regulations for subrecipient noncompliance with audit requirements, Commonwealth Management Directive 325.08, Amended ? Remedies for Recipient Noncompliance with Audit Requirements, Section 5 related to policy, states in part: (a) Agencies must develop and implement remedial action that reflects the unique requirements of each program? (b) The remedial action should be implemented within six months from the date the first remedial action is initiated. At the end of the six-month period, the recipient should take the appropriate corrective action or the final stage of remedial action should be imposed on the recipient. Examples of remedial action include, but are not limited to: Finding 2022 ? 014: (continued) (1) Meeting or calling the recipient to explain the importance and benefits of the audit and audit resolution processes, emphasizing the value of the audit as an administrative tool and the Commonwealth?s reliance on an acceptable audit and prompt resolution as evidence of the recipient?s ability to properly administer the program. (2) Encouraging the entity to establish an audit committee or designate an individual as the single point of contact to: (a) Communicate regarding the audit. (b) Arrange for and oversee the audit. (c) Direct and monitor audit resolution. (3) Providing technical assistance to the recipient in devising and implementing an appropriate plan to remedy the noncompliance. (4) Withholding a portion of assistance payments until the noncompliance is resolved. (5) Withholding or disallowing overhead costs until the noncompliance is resolved. (6) Suspending the assistance agreement until the noncompliance is resolved. (7) Terminating the assistance agreement with the recipient and, if necessary, seeking alternative entities to administer the program. Management Directive 325.09, Amended ? Processing Subrecipient Single Audits of Federal Pass-Through Funds, Section 7 related to procedures, states in part: c. Agencies. (1) Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. (6) Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR ?200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. (7) Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s, Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: One reason provided by Commonwealth management for untimely audit resolution in the various agencies, including making management decisions, approving corrective action, and performing procedures to ensure the accuracy of subrecipient SEFAs, was either a change in staff or a lack of staff to follow up and process subrecipient audit reports more timely. The late management decision at DEP appeared to be the result of a subrecipient being treated as a contractor as described in current year Single Audit Finding #2022-005, despite having a subrecipient Single Audit requirement clause in its contract with DEP. Regarding late and outstanding audit report submissions, the Commonwealth agencies did not appear to be timely implementing remedial action steps in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.8 in order to ensure compliance with federal audit submission requirements. Finding 2022 ? 014: (continued) Effect: Since required management decisions were not made within six months to ensure appropriate corrective action was taken on audits received from subrecipients, the Commonwealth did not comply with federal regulations, and subrecipients were not made aware of acceptance or rejection of corrective action plans in a timely manner. Further, noncompliance may recur in future periods if control deficiencies are not corrected on a timely basis, and there is an increased risk of unallowable charges being made to federal programs if corrective action and recovery of questioned costs is not timely. Regarding the SEFA reviews or alternate procedures which are not being performed timely and the late Single Audit report submissions, there is an increased risk that subrecipients could be misspending and/or inappropriately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis as required. Finally, additional federal pass-through funds may be unaudited in the future without timely and effective remedial action from Commonwealth agencies to enforce compliance. Recommendation: We recommend that the above weaknesses that cause untimely subrecipient Single Audit resolution, including untimely management decisions on findings, untimely review of the SEFA or alternate procedures, and late audit report submissions be corrected to ensure compliance with federal requirements and Commonwealth Management Directives, and to better ensure timelier subrecipient compliance with program requirements. Commonwealth agencies should promptly pursue outstanding audits and implement remedial action steps on a timely basis in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08. PDE Response: PDE agrees with the finding. DEP Response: DEP agrees with the finding. DOH Response: DOH agrees with the finding. DHS Response: While DHS agrees with this finding, we believe we are in compliance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08 related to outstanding audits. We continue to work with counties and their independent auditors to obtain any late Single Audit reports, and albeit late, we do receive them which is the ultimate goal. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Various Agencies Finding 2022 ? 014: ALN 10.553, 10.555, 10.556, 10.559, and 10.582 ? Child Nutrition Cluster (including COVID-19) ALN 10.557 ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (including COVID-19) ALN 10.558 ? Child and Adult Care Food Program (including COVID-19) ALN 15.252 ? Abandoned Mine Land Reclamation ALN 21.023 ? COVID-19 ? Emergency Rental Assistance Program ALN 84.010 ? Title I Grants to Local Educational Agencies ALN 84.027 and 84.173 ? ? Special Education Cluster (IDEA) (including COVID-19) ALN 84.425C ? COVID 19 ? Education Stabilization Fund - GEER Fund ALN 84.425D ? COVID 19 ? Education Stabilization Fund - ESSER Fund ALN 84.425R ? COVID 19 ? Education Stabilization Fund - CRRSA EANS ALN 84.425U ? COVID 19 ? Education Stabilization Fund - ARP ESSER ALN 84.425W ? COVID 19 ? Education Stabilization Fund - ARP ESSER HCY ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) ALN 93.563 ? Child Support Enforcement ALN 93.575 and 93.596 ? Child Care and Development Fund (CCDF) Cluster (including COVID-19) ALN 93.658 ? Foster Care ? Title IV-E (including COVID-19) ALN 93.659 ? Adoption Assistance (including COVID-19) ALN 93.775, 93.777, and 93.778 ? Medicaid Cluster (including COVID-19) A Material Weakness and Material Noncompliance Exist in the Commonwealth?s Subrecipient Audit Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2021-015) Federal Grant Number(s) and Year(s): 1PA300365 (1/01/2022 ? 9/30/2023), 1PA310305 (10/01/2021 ? 9/30/2022), 1PA310305 (10/01/2020 ? 9/30/2021), 1PA300305 (10/01/2021 ? 9/30/2022), 1PA300305 (10/01/2020 ? 9/30/2021), 1PA320305 (12/27/2020 ? 9/30/2021), Y22174 (10/01/2021 ? 9/30/2024), Y13194 (10/01/2020 ? 9/30/2023), Y03194 (10/01/2019 ? 9/30/2023), Y03191 (10/01/2019 ? 9/30/2020), Y22173 (10/01/2021 ? 9/30/2022), Y22172 (10/01/2021 ? 9/30/2022, Y13191 (10/01/2020 ? 9/30/2021), Y13061 (10/01/2020 ? 9/30/2021), S22AF00017 (1/01/2022 ? 12/31/2024), S21AF10050 (6/01/2021 ? 5/31/2024), S21AF10015 (1/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 9/30/2023), S20AF20006 (1/01/2020 ? 12/31/2022), S19AF20006 (1/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2023), S18AF20004 (11/01/2017 ? 10/31/2023), ERAE0131 (1/19/2021 ? 12/29/2022), ERAE0333 (5/11/2021 ? 12/30/2025), S010A210038 (7/01/2021 ? 9/30/2022), S010A200038 (7/01/2020 ? 9/30/2021), H027A210093 (7/01/2021 ? 9/30/2022), H027A200093 (7/01/2020 ? 9/30/2021), S425D200028 (3/13/2020 ? 9/30/2022), S425D210028 (3/13/2020 ? 9/30/2022), 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 2201PACSES (10/01/2021 ? 9/30/2022), 2101PACSES (10/01/2020 ? 9/30/2021), G2201PACCDF (10/01/2021 ? 9/30/2022), G2101PACCDF (10/01/2020 ? 9/30/2021), 2201PAFOST (10/01/2021 ? 9/30/2022), 2101PAFOST (10/01/2020 ? 9/30/2021), 2001PAFOST (10/01/2019 ? 9/30/2020), 2201PAADPT (10/01/2021 ? 9/30/2022), 2101PAADPT (10/01/2020 ? 9/30/2021), 2205PA5MAP (10/01/2021 ? 9/30/2022), 2105PA5MAP (10/01/2020 ? 9/30/2021) Finding 2022 ? 014: (continued) Type of Finding: Significant Deficiency, Noncompliance for Medicaid Cluster Material Weakness, Material Noncompliance for Other Programs Compliance Requirement: Subrecipient Monitoring Condition: Under the Commonwealth of Pennsylvania's (Commonwealth) implementation of the Single Audit Act, review and resolution of subrecipient Single Audit reports is split into two stages. The Office of the Budget?s Bureau of Accounting and Financial Management (OB-BAFM) ensures the reports meet technical standards through a centralized desk review process. The various funding agencies in the Commonwealth are responsible for making a management decision on each finding within six months of the Federal Audit Clearinghouse?s (FAC) Management Decision Letter (MDL) start date for audits subject to Uniform Guidance and to ensure appropriate corrective action is taken by the subrecipient (except for Uniform Guidance audits under U.S. Department of Labor programs which are permitted 12 months for management decisions in accordance with 2 CFR Section 2900.21). Each Commonwealth agency is also responsible for reviewing financial information in each audit report to determine whether the audit included all pass-through funding provided by the agency in order to ensure pass-through funds were subject to audit. Most agencies meet this requirement by performing Schedule of Expenditures of Federal Awards (SEFA) reconciliations. The agency is also required to adjust Commonwealth records, if necessary. Our fiscal year ended June 30, 2022 audit of the Commonwealth?s process for review and resolution of subrecipient Single Audits included an evaluation of the Commonwealth?s fiscal year ended June 30, 2021 subrecipient audit universe for audits due for submission to the FAC during the fiscal year ended June 30, 2022. We also evaluated the Commonwealth?s review of 44 subrecipient audit reports with findings in major programs/clusters which were identified on the Commonwealth agencies? tracking lists during the fiscal year ended June 30, 2022 and required management decisions by Commonwealth agencies. Our testing disclosed the following audit exceptions regarding the Commonwealth agencies? review of subrecipient audit reports: ? Department of Education (PDE): The time period for making a management decision on findings was approximately 6.5 to over 13 months after the FAC MDL start date for 14 out of 25 audit reports with findings. Three of the 14 audit reports were improperly classified on PDE?s audit tracking list as not having federal award findings. ? Department of Environmental Protection (DEP): The time period for making a management decision on findings was approximately 16.2 months after the FAC MDL start date for one out of three audit reports with findings. In addition, our review disclosed that DEP subgranted federal funds totaling $10,338,570 to one subrecipient during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended due to the COVID-19 pandemic in accordance with the Office of Management and Budget?s (OMB) Memorandum M-21-20, Appendix 3. ? Department of Health (DOH): Our review disclosed that DOH subgranted federal funds totaling $8,103,407 to one subrecipient during the fiscal year ended September 30, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 12.5 months after the December 31, 2021 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. ? Department of Human Services (DHS): The time period for making a management decision on findings ranged from approximately 6.6 months to over 19.6 months after the FAC MDL start date for 12 out of 14 subrecipient audit reports with findings. There was also a delay in DHS?s procedures to ensure the subrecipient SEFAs were accurate so that major programs were properly determined and subjected to audit. Finding 2022 ? 014: (continued) As a follow-up to the prior year finding, we noted that the Commonwealth subgranted federal funds totaling $327,988,063 to the City of Philadelphia during the fiscal year ended June 30, 2021, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 3.5 months after the September 30, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. Our testing disclosed that DHS?s subgrants to the City of Philadelphia were material for five of the 16 major programs/clusters with material subgranted funds. Our follow-up on the prior year finding also disclosed that the Commonwealth subgranted federal funds totaling $28,725,212 to Bucks County during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. DHS was the lead agency for the City of Philadelphia and Bucks County audits. Criteria: 2 CFR ?200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (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, and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 [Management decision]. (f) Verify that every subrecipient is audited as required by Subpart F [Audit Requirements] of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 [Audit requirements]. (g) Consider whether the results of the subrecipient?s audit, on-site review, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ?200.339 [Remedies for noncompliance] of this part and in program regulations. In order to carry out these responsibilities properly, good internal control dictates that state pass-through agencies ensure subrecipient Single Audit SEFAs are representative of state payment records each year, and that the related federal programs have been properly subjected to Single Audit procedures. 2 CFR ?200.512, Report submission, states in part: (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Finding 2022 ? 014: (continued) 2 CFR ?200.521, Management decision, states in part: (a) General. The management decision must clearly state whether or not the finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. 2 CFR ?200.505, Sanctions, states: In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, Federal agencies and pass-through entities must take appropriate action as provided in ?200.339 [Remedies for noncompliance]. 2 CFR ?200.339, Remedies for noncompliance, states in part: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.208 [Specific conditions]. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances. (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. To ensure Commonwealth enforcement of federal regulations for subrecipient noncompliance with audit requirements, Commonwealth Management Directive 325.08, Amended ? Remedies for Recipient Noncompliance with Audit Requirements, Section 5 related to policy, states in part: (a) Agencies must develop and implement remedial action that reflects the unique requirements of each program? (b) The remedial action should be implemented within six months from the date the first remedial action is initiated. At the end of the six-month period, the recipient should take the appropriate corrective action or the final stage of remedial action should be imposed on the recipient. Examples of remedial action include, but are not limited to: Finding 2022 ? 014: (continued) (1) Meeting or calling the recipient to explain the importance and benefits of the audit and audit resolution processes, emphasizing the value of the audit as an administrative tool and the Commonwealth?s reliance on an acceptable audit and prompt resolution as evidence of the recipient?s ability to properly administer the program. (2) Encouraging the entity to establish an audit committee or designate an individual as the single point of contact to: (a) Communicate regarding the audit. (b) Arrange for and oversee the audit. (c) Direct and monitor audit resolution. (3) Providing technical assistance to the recipient in devising and implementing an appropriate plan to remedy the noncompliance. (4) Withholding a portion of assistance payments until the noncompliance is resolved. (5) Withholding or disallowing overhead costs until the noncompliance is resolved. (6) Suspending the assistance agreement until the noncompliance is resolved. (7) Terminating the assistance agreement with the recipient and, if necessary, seeking alternative entities to administer the program. Management Directive 325.09, Amended ? Processing Subrecipient Single Audits of Federal Pass-Through Funds, Section 7 related to procedures, states in part: c. Agencies. (1) Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. (6) Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR ?200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. (7) Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s, Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: One reason provided by Commonwealth management for untimely audit resolution in the various agencies, including making management decisions, approving corrective action, and performing procedures to ensure the accuracy of subrecipient SEFAs, was either a change in staff or a lack of staff to follow up and process subrecipient audit reports more timely. The late management decision at DEP appeared to be the result of a subrecipient being treated as a contractor as described in current year Single Audit Finding #2022-005, despite having a subrecipient Single Audit requirement clause in its contract with DEP. Regarding late and outstanding audit report submissions, the Commonwealth agencies did not appear to be timely implementing remedial action steps in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.8 in order to ensure compliance with federal audit submission requirements. Finding 2022 ? 014: (continued) Effect: Since required management decisions were not made within six months to ensure appropriate corrective action was taken on audits received from subrecipients, the Commonwealth did not comply with federal regulations, and subrecipients were not made aware of acceptance or rejection of corrective action plans in a timely manner. Further, noncompliance may recur in future periods if control deficiencies are not corrected on a timely basis, and there is an increased risk of unallowable charges being made to federal programs if corrective action and recovery of questioned costs is not timely. Regarding the SEFA reviews or alternate procedures which are not being performed timely and the late Single Audit report submissions, there is an increased risk that subrecipients could be misspending and/or inappropriately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis as required. Finally, additional federal pass-through funds may be unaudited in the future without timely and effective remedial action from Commonwealth agencies to enforce compliance. Recommendation: We recommend that the above weaknesses that cause untimely subrecipient Single Audit resolution, including untimely management decisions on findings, untimely review of the SEFA or alternate procedures, and late audit report submissions be corrected to ensure compliance with federal requirements and Commonwealth Management Directives, and to better ensure timelier subrecipient compliance with program requirements. Commonwealth agencies should promptly pursue outstanding audits and implement remedial action steps on a timely basis in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08. PDE Response: PDE agrees with the finding. DEP Response: DEP agrees with the finding. DOH Response: DOH agrees with the finding. DHS Response: While DHS agrees with this finding, we believe we are in compliance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08 related to outstanding audits. We continue to work with counties and their independent auditors to obtain any late Single Audit reports, and albeit late, we do receive them which is the ultimate goal. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Various Agencies Finding 2022 ? 014: ALN 10.553, 10.555, 10.556, 10.559, and 10.582 ? Child Nutrition Cluster (including COVID-19) ALN 10.557 ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (including COVID-19) ALN 10.558 ? Child and Adult Care Food Program (including COVID-19) ALN 15.252 ? Abandoned Mine Land Reclamation ALN 21.023 ? COVID-19 ? Emergency Rental Assistance Program ALN 84.010 ? Title I Grants to Local Educational Agencies ALN 84.027 and 84.173 ? ? Special Education Cluster (IDEA) (including COVID-19) ALN 84.425C ? COVID 19 ? Education Stabilization Fund - GEER Fund ALN 84.425D ? COVID 19 ? Education Stabilization Fund - ESSER Fund ALN 84.425R ? COVID 19 ? Education Stabilization Fund - CRRSA EANS ALN 84.425U ? COVID 19 ? Education Stabilization Fund - ARP ESSER ALN 84.425W ? COVID 19 ? Education Stabilization Fund - ARP ESSER HCY ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) ALN 93.563 ? Child Support Enforcement ALN 93.575 and 93.596 ? Child Care and Development Fund (CCDF) Cluster (including COVID-19) ALN 93.658 ? Foster Care ? Title IV-E (including COVID-19) ALN 93.659 ? Adoption Assistance (including COVID-19) ALN 93.775, 93.777, and 93.778 ? Medicaid Cluster (including COVID-19) A Material Weakness and Material Noncompliance Exist in the Commonwealth?s Subrecipient Audit Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2021-015) Federal Grant Number(s) and Year(s): 1PA300365 (1/01/2022 ? 9/30/2023), 1PA310305 (10/01/2021 ? 9/30/2022), 1PA310305 (10/01/2020 ? 9/30/2021), 1PA300305 (10/01/2021 ? 9/30/2022), 1PA300305 (10/01/2020 ? 9/30/2021), 1PA320305 (12/27/2020 ? 9/30/2021), Y22174 (10/01/2021 ? 9/30/2024), Y13194 (10/01/2020 ? 9/30/2023), Y03194 (10/01/2019 ? 9/30/2023), Y03191 (10/01/2019 ? 9/30/2020), Y22173 (10/01/2021 ? 9/30/2022), Y22172 (10/01/2021 ? 9/30/2022, Y13191 (10/01/2020 ? 9/30/2021), Y13061 (10/01/2020 ? 9/30/2021), S22AF00017 (1/01/2022 ? 12/31/2024), S21AF10050 (6/01/2021 ? 5/31/2024), S21AF10015 (1/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 9/30/2023), S20AF20006 (1/01/2020 ? 12/31/2022), S19AF20006 (1/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2023), S18AF20004 (11/01/2017 ? 10/31/2023), ERAE0131 (1/19/2021 ? 12/29/2022), ERAE0333 (5/11/2021 ? 12/30/2025), S010A210038 (7/01/2021 ? 9/30/2022), S010A200038 (7/01/2020 ? 9/30/2021), H027A210093 (7/01/2021 ? 9/30/2022), H027A200093 (7/01/2020 ? 9/30/2021), S425D200028 (3/13/2020 ? 9/30/2022), S425D210028 (3/13/2020 ? 9/30/2022), 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 2201PACSES (10/01/2021 ? 9/30/2022), 2101PACSES (10/01/2020 ? 9/30/2021), G2201PACCDF (10/01/2021 ? 9/30/2022), G2101PACCDF (10/01/2020 ? 9/30/2021), 2201PAFOST (10/01/2021 ? 9/30/2022), 2101PAFOST (10/01/2020 ? 9/30/2021), 2001PAFOST (10/01/2019 ? 9/30/2020), 2201PAADPT (10/01/2021 ? 9/30/2022), 2101PAADPT (10/01/2020 ? 9/30/2021), 2205PA5MAP (10/01/2021 ? 9/30/2022), 2105PA5MAP (10/01/2020 ? 9/30/2021) Finding 2022 ? 014: (continued) Type of Finding: Significant Deficiency, Noncompliance for Medicaid Cluster Material Weakness, Material Noncompliance for Other Programs Compliance Requirement: Subrecipient Monitoring Condition: Under the Commonwealth of Pennsylvania's (Commonwealth) implementation of the Single Audit Act, review and resolution of subrecipient Single Audit reports is split into two stages. The Office of the Budget?s Bureau of Accounting and Financial Management (OB-BAFM) ensures the reports meet technical standards through a centralized desk review process. The various funding agencies in the Commonwealth are responsible for making a management decision on each finding within six months of the Federal Audit Clearinghouse?s (FAC) Management Decision Letter (MDL) start date for audits subject to Uniform Guidance and to ensure appropriate corrective action is taken by the subrecipient (except for Uniform Guidance audits under U.S. Department of Labor programs which are permitted 12 months for management decisions in accordance with 2 CFR Section 2900.21). Each Commonwealth agency is also responsible for reviewing financial information in each audit report to determine whether the audit included all pass-through funding provided by the agency in order to ensure pass-through funds were subject to audit. Most agencies meet this requirement by performing Schedule of Expenditures of Federal Awards (SEFA) reconciliations. The agency is also required to adjust Commonwealth records, if necessary. Our fiscal year ended June 30, 2022 audit of the Commonwealth?s process for review and resolution of subrecipient Single Audits included an evaluation of the Commonwealth?s fiscal year ended June 30, 2021 subrecipient audit universe for audits due for submission to the FAC during the fiscal year ended June 30, 2022. We also evaluated the Commonwealth?s review of 44 subrecipient audit reports with findings in major programs/clusters which were identified on the Commonwealth agencies? tracking lists during the fiscal year ended June 30, 2022 and required management decisions by Commonwealth agencies. Our testing disclosed the following audit exceptions regarding the Commonwealth agencies? review of subrecipient audit reports: ? Department of Education (PDE): The time period for making a management decision on findings was approximately 6.5 to over 13 months after the FAC MDL start date for 14 out of 25 audit reports with findings. Three of the 14 audit reports were improperly classified on PDE?s audit tracking list as not having federal award findings. ? Department of Environmental Protection (DEP): The time period for making a management decision on findings was approximately 16.2 months after the FAC MDL start date for one out of three audit reports with findings. In addition, our review disclosed that DEP subgranted federal funds totaling $10,338,570 to one subrecipient during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended due to the COVID-19 pandemic in accordance with the Office of Management and Budget?s (OMB) Memorandum M-21-20, Appendix 3. ? Department of Health (DOH): Our review disclosed that DOH subgranted federal funds totaling $8,103,407 to one subrecipient during the fiscal year ended September 30, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 12.5 months after the December 31, 2021 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. ? Department of Human Services (DHS): The time period for making a management decision on findings ranged from approximately 6.6 months to over 19.6 months after the FAC MDL start date for 12 out of 14 subrecipient audit reports with findings. There was also a delay in DHS?s procedures to ensure the subrecipient SEFAs were accurate so that major programs were properly determined and subjected to audit. Finding 2022 ? 014: (continued) As a follow-up to the prior year finding, we noted that the Commonwealth subgranted federal funds totaling $327,988,063 to the City of Philadelphia during the fiscal year ended June 30, 2021, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 3.5 months after the September 30, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. Our testing disclosed that DHS?s subgrants to the City of Philadelphia were material for five of the 16 major programs/clusters with material subgranted funds. Our follow-up on the prior year finding also disclosed that the Commonwealth subgranted federal funds totaling $28,725,212 to Bucks County during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. DHS was the lead agency for the City of Philadelphia and Bucks County audits. Criteria: 2 CFR ?200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (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, and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 [Management decision]. (f) Verify that every subrecipient is audited as required by Subpart F [Audit Requirements] of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 [Audit requirements]. (g) Consider whether the results of the subrecipient?s audit, on-site review, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ?200.339 [Remedies for noncompliance] of this part and in program regulations. In order to carry out these responsibilities properly, good internal control dictates that state pass-through agencies ensure subrecipient Single Audit SEFAs are representative of state payment records each year, and that the related federal programs have been properly subjected to Single Audit procedures. 2 CFR ?200.512, Report submission, states in part: (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Finding 2022 ? 014: (continued) 2 CFR ?200.521, Management decision, states in part: (a) General. The management decision must clearly state whether or not the finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. 2 CFR ?200.505, Sanctions, states: In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, Federal agencies and pass-through entities must take appropriate action as provided in ?200.339 [Remedies for noncompliance]. 2 CFR ?200.339, Remedies for noncompliance, states in part: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.208 [Specific conditions]. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances. (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. To ensure Commonwealth enforcement of federal regulations for subrecipient noncompliance with audit requirements, Commonwealth Management Directive 325.08, Amended ? Remedies for Recipient Noncompliance with Audit Requirements, Section 5 related to policy, states in part: (a) Agencies must develop and implement remedial action that reflects the unique requirements of each program? (b) The remedial action should be implemented within six months from the date the first remedial action is initiated. At the end of the six-month period, the recipient should take the appropriate corrective action or the final stage of remedial action should be imposed on the recipient. Examples of remedial action include, but are not limited to: Finding 2022 ? 014: (continued) (1) Meeting or calling the recipient to explain the importance and benefits of the audit and audit resolution processes, emphasizing the value of the audit as an administrative tool and the Commonwealth?s reliance on an acceptable audit and prompt resolution as evidence of the recipient?s ability to properly administer the program. (2) Encouraging the entity to establish an audit committee or designate an individual as the single point of contact to: (a) Communicate regarding the audit. (b) Arrange for and oversee the audit. (c) Direct and monitor audit resolution. (3) Providing technical assistance to the recipient in devising and implementing an appropriate plan to remedy the noncompliance. (4) Withholding a portion of assistance payments until the noncompliance is resolved. (5) Withholding or disallowing overhead costs until the noncompliance is resolved. (6) Suspending the assistance agreement until the noncompliance is resolved. (7) Terminating the assistance agreement with the recipient and, if necessary, seeking alternative entities to administer the program. Management Directive 325.09, Amended ? Processing Subrecipient Single Audits of Federal Pass-Through Funds, Section 7 related to procedures, states in part: c. Agencies. (1) Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. (6) Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR ?200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. (7) Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s, Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: One reason provided by Commonwealth management for untimely audit resolution in the various agencies, including making management decisions, approving corrective action, and performing procedures to ensure the accuracy of subrecipient SEFAs, was either a change in staff or a lack of staff to follow up and process subrecipient audit reports more timely. The late management decision at DEP appeared to be the result of a subrecipient being treated as a contractor as described in current year Single Audit Finding #2022-005, despite having a subrecipient Single Audit requirement clause in its contract with DEP. Regarding late and outstanding audit report submissions, the Commonwealth agencies did not appear to be timely implementing remedial action steps in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.8 in order to ensure compliance with federal audit submission requirements. Finding 2022 ? 014: (continued) Effect: Since required management decisions were not made within six months to ensure appropriate corrective action was taken on audits received from subrecipients, the Commonwealth did not comply with federal regulations, and subrecipients were not made aware of acceptance or rejection of corrective action plans in a timely manner. Further, noncompliance may recur in future periods if control deficiencies are not corrected on a timely basis, and there is an increased risk of unallowable charges being made to federal programs if corrective action and recovery of questioned costs is not timely. Regarding the SEFA reviews or alternate procedures which are not being performed timely and the late Single Audit report submissions, there is an increased risk that subrecipients could be misspending and/or inappropriately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis as required. Finally, additional federal pass-through funds may be unaudited in the future without timely and effective remedial action from Commonwealth agencies to enforce compliance. Recommendation: We recommend that the above weaknesses that cause untimely subrecipient Single Audit resolution, including untimely management decisions on findings, untimely review of the SEFA or alternate procedures, and late audit report submissions be corrected to ensure compliance with federal requirements and Commonwealth Management Directives, and to better ensure timelier subrecipient compliance with program requirements. Commonwealth agencies should promptly pursue outstanding audits and implement remedial action steps on a timely basis in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08. PDE Response: PDE agrees with the finding. DEP Response: DEP agrees with the finding. DOH Response: DOH agrees with the finding. DHS Response: While DHS agrees with this finding, we believe we are in compliance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08 related to outstanding audits. We continue to work with counties and their independent auditors to obtain any late Single Audit reports, and albeit late, we do receive them which is the ultimate goal. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Various Agencies Finding 2022 ? 014: ALN 10.553, 10.555, 10.556, 10.559, and 10.582 ? Child Nutrition Cluster (including COVID-19) ALN 10.557 ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (including COVID-19) ALN 10.558 ? Child and Adult Care Food Program (including COVID-19) ALN 15.252 ? Abandoned Mine Land Reclamation ALN 21.023 ? COVID-19 ? Emergency Rental Assistance Program ALN 84.010 ? Title I Grants to Local Educational Agencies ALN 84.027 and 84.173 ? ? Special Education Cluster (IDEA) (including COVID-19) ALN 84.425C ? COVID 19 ? Education Stabilization Fund - GEER Fund ALN 84.425D ? COVID 19 ? Education Stabilization Fund - ESSER Fund ALN 84.425R ? COVID 19 ? Education Stabilization Fund - CRRSA EANS ALN 84.425U ? COVID 19 ? Education Stabilization Fund - ARP ESSER ALN 84.425W ? COVID 19 ? Education Stabilization Fund - ARP ESSER HCY ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) ALN 93.563 ? Child Support Enforcement ALN 93.575 and 93.596 ? Child Care and Development Fund (CCDF) Cluster (including COVID-19) ALN 93.658 ? Foster Care ? Title IV-E (including COVID-19) ALN 93.659 ? Adoption Assistance (including COVID-19) ALN 93.775, 93.777, and 93.778 ? Medicaid Cluster (including COVID-19) A Material Weakness and Material Noncompliance Exist in the Commonwealth?s Subrecipient Audit Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2021-015) Federal Grant Number(s) and Year(s): 1PA300365 (1/01/2022 ? 9/30/2023), 1PA310305 (10/01/2021 ? 9/30/2022), 1PA310305 (10/01/2020 ? 9/30/2021), 1PA300305 (10/01/2021 ? 9/30/2022), 1PA300305 (10/01/2020 ? 9/30/2021), 1PA320305 (12/27/2020 ? 9/30/2021), Y22174 (10/01/2021 ? 9/30/2024), Y13194 (10/01/2020 ? 9/30/2023), Y03194 (10/01/2019 ? 9/30/2023), Y03191 (10/01/2019 ? 9/30/2020), Y22173 (10/01/2021 ? 9/30/2022), Y22172 (10/01/2021 ? 9/30/2022, Y13191 (10/01/2020 ? 9/30/2021), Y13061 (10/01/2020 ? 9/30/2021), S22AF00017 (1/01/2022 ? 12/31/2024), S21AF10050 (6/01/2021 ? 5/31/2024), S21AF10015 (1/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 9/30/2023), S20AF20006 (1/01/2020 ? 12/31/2022), S19AF20006 (1/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2023), S18AF20004 (11/01/2017 ? 10/31/2023), ERAE0131 (1/19/2021 ? 12/29/2022), ERAE0333 (5/11/2021 ? 12/30/2025), S010A210038 (7/01/2021 ? 9/30/2022), S010A200038 (7/01/2020 ? 9/30/2021), H027A210093 (7/01/2021 ? 9/30/2022), H027A200093 (7/01/2020 ? 9/30/2021), S425D200028 (3/13/2020 ? 9/30/2022), S425D210028 (3/13/2020 ? 9/30/2022), 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 2201PACSES (10/01/2021 ? 9/30/2022), 2101PACSES (10/01/2020 ? 9/30/2021), G2201PACCDF (10/01/2021 ? 9/30/2022), G2101PACCDF (10/01/2020 ? 9/30/2021), 2201PAFOST (10/01/2021 ? 9/30/2022), 2101PAFOST (10/01/2020 ? 9/30/2021), 2001PAFOST (10/01/2019 ? 9/30/2020), 2201PAADPT (10/01/2021 ? 9/30/2022), 2101PAADPT (10/01/2020 ? 9/30/2021), 2205PA5MAP (10/01/2021 ? 9/30/2022), 2105PA5MAP (10/01/2020 ? 9/30/2021) Finding 2022 ? 014: (continued) Type of Finding: Significant Deficiency, Noncompliance for Medicaid Cluster Material Weakness, Material Noncompliance for Other Programs Compliance Requirement: Subrecipient Monitoring Condition: Under the Commonwealth of Pennsylvania's (Commonwealth) implementation of the Single Audit Act, review and resolution of subrecipient Single Audit reports is split into two stages. The Office of the Budget?s Bureau of Accounting and Financial Management (OB-BAFM) ensures the reports meet technical standards through a centralized desk review process. The various funding agencies in the Commonwealth are responsible for making a management decision on each finding within six months of the Federal Audit Clearinghouse?s (FAC) Management Decision Letter (MDL) start date for audits subject to Uniform Guidance and to ensure appropriate corrective action is taken by the subrecipient (except for Uniform Guidance audits under U.S. Department of Labor programs which are permitted 12 months for management decisions in accordance with 2 CFR Section 2900.21). Each Commonwealth agency is also responsible for reviewing financial information in each audit report to determine whether the audit included all pass-through funding provided by the agency in order to ensure pass-through funds were subject to audit. Most agencies meet this requirement by performing Schedule of Expenditures of Federal Awards (SEFA) reconciliations. The agency is also required to adjust Commonwealth records, if necessary. Our fiscal year ended June 30, 2022 audit of the Commonwealth?s process for review and resolution of subrecipient Single Audits included an evaluation of the Commonwealth?s fiscal year ended June 30, 2021 subrecipient audit universe for audits due for submission to the FAC during the fiscal year ended June 30, 2022. We also evaluated the Commonwealth?s review of 44 subrecipient audit reports with findings in major programs/clusters which were identified on the Commonwealth agencies? tracking lists during the fiscal year ended June 30, 2022 and required management decisions by Commonwealth agencies. Our testing disclosed the following audit exceptions regarding the Commonwealth agencies? review of subrecipient audit reports: ? Department of Education (PDE): The time period for making a management decision on findings was approximately 6.5 to over 13 months after the FAC MDL start date for 14 out of 25 audit reports with findings. Three of the 14 audit reports were improperly classified on PDE?s audit tracking list as not having federal award findings. ? Department of Environmental Protection (DEP): The time period for making a management decision on findings was approximately 16.2 months after the FAC MDL start date for one out of three audit reports with findings. In addition, our review disclosed that DEP subgranted federal funds totaling $10,338,570 to one subrecipient during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended due to the COVID-19 pandemic in accordance with the Office of Management and Budget?s (OMB) Memorandum M-21-20, Appendix 3. ? Department of Health (DOH): Our review disclosed that DOH subgranted federal funds totaling $8,103,407 to one subrecipient during the fiscal year ended September 30, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 12.5 months after the December 31, 2021 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. ? Department of Human Services (DHS): The time period for making a management decision on findings ranged from approximately 6.6 months to over 19.6 months after the FAC MDL start date for 12 out of 14 subrecipient audit reports with findings. There was also a delay in DHS?s procedures to ensure the subrecipient SEFAs were accurate so that major programs were properly determined and subjected to audit. Finding 2022 ? 014: (continued) As a follow-up to the prior year finding, we noted that the Commonwealth subgranted federal funds totaling $327,988,063 to the City of Philadelphia during the fiscal year ended June 30, 2021, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 3.5 months after the September 30, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. Our testing disclosed that DHS?s subgrants to the City of Philadelphia were material for five of the 16 major programs/clusters with material subgranted funds. Our follow-up on the prior year finding also disclosed that the Commonwealth subgranted federal funds totaling $28,725,212 to Bucks County during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. DHS was the lead agency for the City of Philadelphia and Bucks County audits. Criteria: 2 CFR ?200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (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, and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 [Management decision]. (f) Verify that every subrecipient is audited as required by Subpart F [Audit Requirements] of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 [Audit requirements]. (g) Consider whether the results of the subrecipient?s audit, on-site review, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ?200.339 [Remedies for noncompliance] of this part and in program regulations. In order to carry out these responsibilities properly, good internal control dictates that state pass-through agencies ensure subrecipient Single Audit SEFAs are representative of state payment records each year, and that the related federal programs have been properly subjected to Single Audit procedures. 2 CFR ?200.512, Report submission, states in part: (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Finding 2022 ? 014: (continued) 2 CFR ?200.521, Management decision, states in part: (a) General. The management decision must clearly state whether or not the finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. 2 CFR ?200.505, Sanctions, states: In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, Federal agencies and pass-through entities must take appropriate action as provided in ?200.339 [Remedies for noncompliance]. 2 CFR ?200.339, Remedies for noncompliance, states in part: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.208 [Specific conditions]. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances. (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. To ensure Commonwealth enforcement of federal regulations for subrecipient noncompliance with audit requirements, Commonwealth Management Directive 325.08, Amended ? Remedies for Recipient Noncompliance with Audit Requirements, Section 5 related to policy, states in part: (a) Agencies must develop and implement remedial action that reflects the unique requirements of each program? (b) The remedial action should be implemented within six months from the date the first remedial action is initiated. At the end of the six-month period, the recipient should take the appropriate corrective action or the final stage of remedial action should be imposed on the recipient. Examples of remedial action include, but are not limited to: Finding 2022 ? 014: (continued) (1) Meeting or calling the recipient to explain the importance and benefits of the audit and audit resolution processes, emphasizing the value of the audit as an administrative tool and the Commonwealth?s reliance on an acceptable audit and prompt resolution as evidence of the recipient?s ability to properly administer the program. (2) Encouraging the entity to establish an audit committee or designate an individual as the single point of contact to: (a) Communicate regarding the audit. (b) Arrange for and oversee the audit. (c) Direct and monitor audit resolution. (3) Providing technical assistance to the recipient in devising and implementing an appropriate plan to remedy the noncompliance. (4) Withholding a portion of assistance payments until the noncompliance is resolved. (5) Withholding or disallowing overhead costs until the noncompliance is resolved. (6) Suspending the assistance agreement until the noncompliance is resolved. (7) Terminating the assistance agreement with the recipient and, if necessary, seeking alternative entities to administer the program. Management Directive 325.09, Amended ? Processing Subrecipient Single Audits of Federal Pass-Through Funds, Section 7 related to procedures, states in part: c. Agencies. (1) Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. (6) Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR ?200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. (7) Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s, Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: One reason provided by Commonwealth management for untimely audit resolution in the various agencies, including making management decisions, approving corrective action, and performing procedures to ensure the accuracy of subrecipient SEFAs, was either a change in staff or a lack of staff to follow up and process subrecipient audit reports more timely. The late management decision at DEP appeared to be the result of a subrecipient being treated as a contractor as described in current year Single Audit Finding #2022-005, despite having a subrecipient Single Audit requirement clause in its contract with DEP. Regarding late and outstanding audit report submissions, the Commonwealth agencies did not appear to be timely implementing remedial action steps in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.8 in order to ensure compliance with federal audit submission requirements. Finding 2022 ? 014: (continued) Effect: Since required management decisions were not made within six months to ensure appropriate corrective action was taken on audits received from subrecipients, the Commonwealth did not comply with federal regulations, and subrecipients were not made aware of acceptance or rejection of corrective action plans in a timely manner. Further, noncompliance may recur in future periods if control deficiencies are not corrected on a timely basis, and there is an increased risk of unallowable charges being made to federal programs if corrective action and recovery of questioned costs is not timely. Regarding the SEFA reviews or alternate procedures which are not being performed timely and the late Single Audit report submissions, there is an increased risk that subrecipients could be misspending and/or inappropriately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis as required. Finally, additional federal pass-through funds may be unaudited in the future without timely and effective remedial action from Commonwealth agencies to enforce compliance. Recommendation: We recommend that the above weaknesses that cause untimely subrecipient Single Audit resolution, including untimely management decisions on findings, untimely review of the SEFA or alternate procedures, and late audit report submissions be corrected to ensure compliance with federal requirements and Commonwealth Management Directives, and to better ensure timelier subrecipient compliance with program requirements. Commonwealth agencies should promptly pursue outstanding audits and implement remedial action steps on a timely basis in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08. PDE Response: PDE agrees with the finding. DEP Response: DEP agrees with the finding. DOH Response: DOH agrees with the finding. DHS Response: While DHS agrees with this finding, we believe we are in compliance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08 related to outstanding audits. We continue to work with counties and their independent auditors to obtain any late Single Audit reports, and albeit late, we do receive them which is the ultimate goal. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Various Agencies Finding 2022 ? 014: ALN 10.553, 10.555, 10.556, 10.559, and 10.582 ? Child Nutrition Cluster (including COVID-19) ALN 10.557 ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children (including COVID-19) ALN 10.558 ? Child and Adult Care Food Program (including COVID-19) ALN 15.252 ? Abandoned Mine Land Reclamation ALN 21.023 ? COVID-19 ? Emergency Rental Assistance Program ALN 84.010 ? Title I Grants to Local Educational Agencies ALN 84.027 and 84.173 ? ? Special Education Cluster (IDEA) (including COVID-19) ALN 84.425C ? COVID 19 ? Education Stabilization Fund - GEER Fund ALN 84.425D ? COVID 19 ? Education Stabilization Fund - ESSER Fund ALN 84.425R ? COVID 19 ? Education Stabilization Fund - CRRSA EANS ALN 84.425U ? COVID 19 ? Education Stabilization Fund - ARP ESSER ALN 84.425W ? COVID 19 ? Education Stabilization Fund - ARP ESSER HCY ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) ALN 93.563 ? Child Support Enforcement ALN 93.575 and 93.596 ? Child Care and Development Fund (CCDF) Cluster (including COVID-19) ALN 93.658 ? Foster Care ? Title IV-E (including COVID-19) ALN 93.659 ? Adoption Assistance (including COVID-19) ALN 93.775, 93.777, and 93.778 ? Medicaid Cluster (including COVID-19) A Material Weakness and Material Noncompliance Exist in the Commonwealth?s Subrecipient Audit Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2021-015) Federal Grant Number(s) and Year(s): 1PA300365 (1/01/2022 ? 9/30/2023), 1PA310305 (10/01/2021 ? 9/30/2022), 1PA310305 (10/01/2020 ? 9/30/2021), 1PA300305 (10/01/2021 ? 9/30/2022), 1PA300305 (10/01/2020 ? 9/30/2021), 1PA320305 (12/27/2020 ? 9/30/2021), Y22174 (10/01/2021 ? 9/30/2024), Y13194 (10/01/2020 ? 9/30/2023), Y03194 (10/01/2019 ? 9/30/2023), Y03191 (10/01/2019 ? 9/30/2020), Y22173 (10/01/2021 ? 9/30/2022), Y22172 (10/01/2021 ? 9/30/2022, Y13191 (10/01/2020 ? 9/30/2021), Y13061 (10/01/2020 ? 9/30/2021), S22AF00017 (1/01/2022 ? 12/31/2024), S21AF10050 (6/01/2021 ? 5/31/2024), S21AF10015 (1/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 9/30/2023), S20AF20006 (1/01/2020 ? 12/31/2022), S19AF20006 (1/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2023), S18AF20004 (11/01/2017 ? 10/31/2023), ERAE0131 (1/19/2021 ? 12/29/2022), ERAE0333 (5/11/2021 ? 12/30/2025), S010A210038 (7/01/2021 ? 9/30/2022), S010A200038 (7/01/2020 ? 9/30/2021), H027A210093 (7/01/2021 ? 9/30/2022), H027A200093 (7/01/2020 ? 9/30/2021), S425D200028 (3/13/2020 ? 9/30/2022), S425D210028 (3/13/2020 ? 9/30/2022), 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 2201PACSES (10/01/2021 ? 9/30/2022), 2101PACSES (10/01/2020 ? 9/30/2021), G2201PACCDF (10/01/2021 ? 9/30/2022), G2101PACCDF (10/01/2020 ? 9/30/2021), 2201PAFOST (10/01/2021 ? 9/30/2022), 2101PAFOST (10/01/2020 ? 9/30/2021), 2001PAFOST (10/01/2019 ? 9/30/2020), 2201PAADPT (10/01/2021 ? 9/30/2022), 2101PAADPT (10/01/2020 ? 9/30/2021), 2205PA5MAP (10/01/2021 ? 9/30/2022), 2105PA5MAP (10/01/2020 ? 9/30/2021) Finding 2022 ? 014: (continued) Type of Finding: Significant Deficiency, Noncompliance for Medicaid Cluster Material Weakness, Material Noncompliance for Other Programs Compliance Requirement: Subrecipient Monitoring Condition: Under the Commonwealth of Pennsylvania's (Commonwealth) implementation of the Single Audit Act, review and resolution of subrecipient Single Audit reports is split into two stages. The Office of the Budget?s Bureau of Accounting and Financial Management (OB-BAFM) ensures the reports meet technical standards through a centralized desk review process. The various funding agencies in the Commonwealth are responsible for making a management decision on each finding within six months of the Federal Audit Clearinghouse?s (FAC) Management Decision Letter (MDL) start date for audits subject to Uniform Guidance and to ensure appropriate corrective action is taken by the subrecipient (except for Uniform Guidance audits under U.S. Department of Labor programs which are permitted 12 months for management decisions in accordance with 2 CFR Section 2900.21). Each Commonwealth agency is also responsible for reviewing financial information in each audit report to determine whether the audit included all pass-through funding provided by the agency in order to ensure pass-through funds were subject to audit. Most agencies meet this requirement by performing Schedule of Expenditures of Federal Awards (SEFA) reconciliations. The agency is also required to adjust Commonwealth records, if necessary. Our fiscal year ended June 30, 2022 audit of the Commonwealth?s process for review and resolution of subrecipient Single Audits included an evaluation of the Commonwealth?s fiscal year ended June 30, 2021 subrecipient audit universe for audits due for submission to the FAC during the fiscal year ended June 30, 2022. We also evaluated the Commonwealth?s review of 44 subrecipient audit reports with findings in major programs/clusters which were identified on the Commonwealth agencies? tracking lists during the fiscal year ended June 30, 2022 and required management decisions by Commonwealth agencies. Our testing disclosed the following audit exceptions regarding the Commonwealth agencies? review of subrecipient audit reports: ? Department of Education (PDE): The time period for making a management decision on findings was approximately 6.5 to over 13 months after the FAC MDL start date for 14 out of 25 audit reports with findings. Three of the 14 audit reports were improperly classified on PDE?s audit tracking list as not having federal award findings. ? Department of Environmental Protection (DEP): The time period for making a management decision on findings was approximately 16.2 months after the FAC MDL start date for one out of three audit reports with findings. In addition, our review disclosed that DEP subgranted federal funds totaling $10,338,570 to one subrecipient during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended due to the COVID-19 pandemic in accordance with the Office of Management and Budget?s (OMB) Memorandum M-21-20, Appendix 3. ? Department of Health (DOH): Our review disclosed that DOH subgranted federal funds totaling $8,103,407 to one subrecipient during the fiscal year ended September 30, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 12.5 months after the December 31, 2021 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. ? Department of Human Services (DHS): The time period for making a management decision on findings ranged from approximately 6.6 months to over 19.6 months after the FAC MDL start date for 12 out of 14 subrecipient audit reports with findings. There was also a delay in DHS?s procedures to ensure the subrecipient SEFAs were accurate so that major programs were properly determined and subjected to audit. Finding 2022 ? 014: (continued) As a follow-up to the prior year finding, we noted that the Commonwealth subgranted federal funds totaling $327,988,063 to the City of Philadelphia during the fiscal year ended June 30, 2021, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 3.5 months after the September 30, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. Our testing disclosed that DHS?s subgrants to the City of Philadelphia were material for five of the 16 major programs/clusters with material subgranted funds. Our follow-up on the prior year finding also disclosed that the Commonwealth subgranted federal funds totaling $28,725,212 to Bucks County during the fiscal year ended December 31, 2020, for which a Single Audit was not submitted to the FAC as of our January 2023 testing date. This was over 9.5 months after the March 31, 2022 due date, which had been extended in accordance with OMB?s Memorandum M-21-20, Appendix 3. DHS was the lead agency for the City of Philadelphia and Bucks County audits. Criteria: 2 CFR ?200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (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, and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 [Management decision]. (f) Verify that every subrecipient is audited as required by Subpart F [Audit Requirements] of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 [Audit requirements]. (g) Consider whether the results of the subrecipient?s audit, on-site review, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ?200.339 [Remedies for noncompliance] of this part and in program regulations. In order to carry out these responsibilities properly, good internal control dictates that state pass-through agencies ensure subrecipient Single Audit SEFAs are representative of state payment records each year, and that the related federal programs have been properly subjected to Single Audit procedures. 2 CFR ?200.512, Report submission, states in part: (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Finding 2022 ? 014: (continued) 2 CFR ?200.521, Management decision, states in part: (a) General. The management decision must clearly state whether or not the finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. 2 CFR ?200.505, Sanctions, states: In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, Federal agencies and pass-through entities must take appropriate action as provided in ?200.339 [Remedies for noncompliance]. 2 CFR ?200.339, Remedies for noncompliance, states in part: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ?200.208 [Specific conditions]. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances. (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. To ensure Commonwealth enforcement of federal regulations for subrecipient noncompliance with audit requirements, Commonwealth Management Directive 325.08, Amended ? Remedies for Recipient Noncompliance with Audit Requirements, Section 5 related to policy, states in part: (a) Agencies must develop and implement remedial action that reflects the unique requirements of each program? (b) The remedial action should be implemented within six months from the date the first remedial action is initiated. At the end of the six-month period, the recipient should take the appropriate corrective action or the final stage of remedial action should be imposed on the recipient. Examples of remedial action include, but are not limited to: Finding 2022 ? 014: (continued) (1) Meeting or calling the recipient to explain the importance and benefits of the audit and audit resolution processes, emphasizing the value of the audit as an administrative tool and the Commonwealth?s reliance on an acceptable audit and prompt resolution as evidence of the recipient?s ability to properly administer the program. (2) Encouraging the entity to establish an audit committee or designate an individual as the single point of contact to: (a) Communicate regarding the audit. (b) Arrange for and oversee the audit. (c) Direct and monitor audit resolution. (3) Providing technical assistance to the recipient in devising and implementing an appropriate plan to remedy the noncompliance. (4) Withholding a portion of assistance payments until the noncompliance is resolved. (5) Withholding or disallowing overhead costs until the noncompliance is resolved. (6) Suspending the assistance agreement until the noncompliance is resolved. (7) Terminating the assistance agreement with the recipient and, if necessary, seeking alternative entities to administer the program. Management Directive 325.09, Amended ? Processing Subrecipient Single Audits of Federal Pass-Through Funds, Section 7 related to procedures, states in part: c. Agencies. (1) Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. (6) Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR ?200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. (7) Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s, Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: One reason provided by Commonwealth management for untimely audit resolution in the various agencies, including making management decisions, approving corrective action, and performing procedures to ensure the accuracy of subrecipient SEFAs, was either a change in staff or a lack of staff to follow up and process subrecipient audit reports more timely. The late management decision at DEP appeared to be the result of a subrecipient being treated as a contractor as described in current year Single Audit Finding #2022-005, despite having a subrecipient Single Audit requirement clause in its contract with DEP. Regarding late and outstanding audit report submissions, the Commonwealth agencies did not appear to be timely implementing remedial action steps in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.8 in order to ensure compliance with federal audit submission requirements. Finding 2022 ? 014: (continued) Effect: Since required management decisions were not made within six months to ensure appropriate corrective action was taken on audits received from subrecipients, the Commonwealth did not comply with federal regulations, and subrecipients were not made aware of acceptance or rejection of corrective action plans in a timely manner. Further, noncompliance may recur in future periods if control deficiencies are not corrected on a timely basis, and there is an increased risk of unallowable charges being made to federal programs if corrective action and recovery of questioned costs is not timely. Regarding the SEFA reviews or alternate procedures which are not being performed timely and the late Single Audit report submissions, there is an increased risk that subrecipients could be misspending and/or inappropriately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by agency personnel on a timely basis as required. Finally, additional federal pass-through funds may be unaudited in the future without timely and effective remedial action from Commonwealth agencies to enforce compliance. Recommendation: We recommend that the above weaknesses that cause untimely subrecipient Single Audit resolution, including untimely management decisions on findings, untimely review of the SEFA or alternate procedures, and late audit report submissions be corrected to ensure compliance with federal requirements and Commonwealth Management Directives, and to better ensure timelier subrecipient compliance with program requirements. Commonwealth agencies should promptly pursue outstanding audits and implement remedial action steps on a timely basis in accordance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08. PDE Response: PDE agrees with the finding. DEP Response: DEP agrees with the finding. DOH Response: DOH agrees with the finding. DHS Response: While DHS agrees with this finding, we believe we are in compliance with 2 CFR ?200.339 and Commonwealth Management Directive 325.08 related to outstanding audits. We continue to work with counties and their independent auditors to obtain any late Single Audit reports, and albeit late, we do receive them which is the ultimate goal. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.