Finding 1076302 (2023-001)

Finding 2023-001 – Subrecipient Monitoring U.S. Department of Health and Human Services Foster Care Title IV-E – ALN 93.658 Pass-through Agency: Pennsylvania Department of Human Services Program: Foster Care Title IV-E Condition: The County has internal controls in place to monitor subrecipients of Foster Care Title IV-E funding, however, not all required procedures are being performed. The County did not ensure that Foster Care Title IV-E subrecipients were notified via contract or letter of the subaward ALN and amount that was paid during the year. Additionally, the County does not have a formally documented risk assessment process for evaluating subrecipients’ risks of non-compliance. As part of the monitoring process, the County obtained and reviewed annual audit reports for a portion of, but not all of, the subrecipients in a timely manner in order to ensure the subrecipient complied with the Foster Care Title IV-E Instructions and Requirements. Criteria: The Pennsylvania Department of Human Services (PA DHS) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients. Additionally, 2 CFR section 200.332(a) requires pass-through entities to notify the subrecipient at the time of the subaward of the subaward ALN as well as notify the subrecipient of the amount that was paid during the year. Cause: Procedures are in place over subrecipient monitoring, however the procedures to ensure that subrecipients are notified of their subaward including ALN number and amount are not adequate. The County does not have procedures in place to document the assessment of risk for subrecipients. In addition, the County does not have procedures in place to adequately review all subrecipient audits or notify the subrecipient of the subaward ALN and amount that was paid during the year. Effect: The deficiencies in subrecipient monitoring could result in the County not identifying unallowable expenses being incurred by County subrecipients. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that procedures be implemented to ensure all subrecipients are notified of subawards and implement a process to ensure all subrecipient audits are reviewed and deficiencies be followed up on. In addition, we recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the County should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits. Questioned Costs: Unknown Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate corrective action plan.