FAC Explorer

Finding 1162535 (2024-002)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-11-17
Audit: 372243
Organization: County of Northampton, Pennsylvania (PA)
Auditor: MAHER DUESSEL CPAS

AI Summary

  • Core Issue: The County's monitoring of subrecipients lacks compliance with federal requirements, particularly in notifying them of funding details and conducting necessary risk assessments.
  • Impacted Requirements: Key regulations under 2 CFR 200.332 regarding subrecipient notifications, audit requirements, and annual risk assessments are not being fully met.
  • Recommended Follow-up: Implement procedures to ensure all subrecipients are informed of their obligations, review all subrecipient audits, and conduct annual risk assessments for compliance.

Finding Text

Finding 2024-002 – Subrecipient Monitoring US Department of Health and Human Services - Passed through the Pennsylvania Department of Human Services – Foster Care Title IV-E (ALN 93.658) US Department of Health and Human Services - Passed through the Pennsylvania Department of Aging – Aging Cluster (ALNs 93.044, 93.045, and 93.053) Grant Number 4100089721 Condition: The County has internal controls in place to monitor subrecipients of Foster Care Title IV-E and aging funding, however, the policies do not incorporate all required federal compliance requirements. For Aging, the County did not conduct the annual risk assessment prior to the disbursement of funds. The County did not ensure that all Foster Care Title IV-E and aging subrecipients were notified via contract or letter of the subaward ALN and amount that was paid during the year. Additionally, the County only request audits from subrecipients if the county passes over $150,000 federal dollars to the subrecipient. 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 subrecipients complied with the Foster Care Title IV-E and Aging requirements. Criteria: In accordance with the federal compliance requirements all pass through entities must ensure that every subaward is clearly identified to the subrecipient and includes specific information as discussed at 2 CFR 200.332(b). Additionally, 2 CFR 200.332(e) and 200.332(g) requires the pass through entity to resolve audit finding specifically related to the subaward and to verify that a subrecipient is audited as required by subpart f of this requirement. Finally, 2 CFR 200.332 (c) requires that the County evaluate all subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate monitoring. Cause: Procedures are in place over subrecipient monitoring, however the procedures to ensure that subrecipients are notified of the requirements listed in 2 CFR 200.332(b) are not adequate. The County also only requires audits and follows up on any deficiencies for subrecipients that they pass through more than $150,000 in federal funding, which is not adequate in accordance with 2 CFR 200.332(e) and 200.332(g). Finally, the county did not perform a timely annual risk assessment for Aging subrecipients in accordance with 2 CFR 200.332 (c). Effect: Subrecipients may have been unaware of the federal nature of their funding, relevant compliance requirements, and the need to prepare for single audit submission as required under federal regulations. Additionally, incomplete monitoring of subrecipient audits may result in noncompliance with federal program requirements and increase the risk of misuse or mismanagement of federal funds. Repeat Finding: This is not a repeat finding Questioned Costs: Unknown Recommendation: We recommend that procedures be implemented to ensure all subrecipients are notified of subaward requirements as outlined in 2 CFR 200.332(b) and the County implement a process to ensure all subrecipients audits are reviewed and deficiencies be followed up on. We also recommend that the County perform annual risk assessments for all subrecipients. Management Response: See corrective action plan.

Corrective Action Plan

Finding 2024-002 – Subrecipient Monitoring (Significant Deficiency) Recommendation: We recommend that procedures be implemented to ensure all subrecipients are notified of subaward requirements as outlined in 2 CFR 200.332(b) and the County implement a process to ensure all subrecipients audits are reviewed and deficiencies be followed up on. We also recommend that the County perform annual risk assessments for all subrecipients. The Area Agency on Aging failed to conduct the required annual risk assessment prior to disbursing funds. Corrective Action: • All divisions within the Department of Human Services (excluding Gracedale) will conduct an annual risk assessment for each provider during the contracting process. • DHS Policy 300.8 will be revised to include a standardized, department-wide risk assessment form for use across all divisions. The County did not ensure that all Foster Care Title IV-E and aging subrecipients were notified via contract or letter of their subaward Assistance Listing Number (ALN) and the amount paid during the year. Corrective Action: When issuing contracts, the County will include a notification letter to each provider indicating whether they have the potential to be a subrecipient of federal funds. If applicable, the letter will also include the relevant Assistance Listing Number (ALN). After the close of each fiscal year, the County will issue a summary letter to all subrecipients detailing the total amount of federal, state, and county funds paid to them. The portion of federal funding will be clearly identified and accompanied by the corresponding ALN. Cindy Smith, Financial and Information Systems Director for the Department of Human Services and her staff will be responsible for the corrective actions for finding 2024-002. The Department of Human Services began issuing notification letters in fall 2025 to vendors identified as potential subrecipients of federal funding. These notifications apply to fiscal year 2025–2026. In addition, summary letters informing vendors of federal award amounts are currently being distributed for fiscal year 2024–2025.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1162520 2024-003
    Material Weakness Repeat
  • 1162521 2024-003
    Material Weakness Repeat
  • 1162522 2024-002
    Material Weakness Repeat
  • 1162523 2024-002
    Material Weakness Repeat
  • 1162524 2024-002
    Material Weakness Repeat
  • 1162525 2024-002
    Material Weakness Repeat
  • 1162526 2024-002
    Material Weakness Repeat
  • 1162527 2024-002
    Material Weakness Repeat
  • 1162528 2024-002
    Material Weakness Repeat
  • 1162529 2024-002
    Material Weakness Repeat
  • 1162530 2024-002
    Material Weakness Repeat
  • 1162531 2024-002
    Material Weakness Repeat
  • 1162532 2024-002
    Material Weakness Repeat
  • 1162533 2024-002
    Material Weakness Repeat
  • 1162534 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.563 CHILD SUPPORT SERVICES $2.96M
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $1.32M
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $873,818
21.027 COVID-19, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $545,202
93.045 COVID-19, SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $361,658
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $280,505
93.044 COVID-19, SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $280,384
14.218 COVID-19, COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $180,000
66.818 BROWNFIELDS MULTIPURPOSE, ASSESSMENT, REVOLVING LOAN FUND, AND CLEANUP COOPERATIVE AGREEMENTS $152,935
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $134,488
93.658 FOSTER CARE TITLE IV-E $118,060
93.667 SOCIAL SERVICES BLOCK GRANT $114,964
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $109,126
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $108,659
93.788 OPIOID STR $105,883
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $84,790
97.039 HAZARD MITIGATION GRANT $80,498
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $73,753
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $72,779
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $71,716
93.791 MONEY FOLLOWS THE PERSON REBALANCING DEMONSTRATION $65,551
20.706 PIPELINE EMERGENCY RESPONSE GRANT (PERG) $54,857
10.555 NATIONAL SCHOOL LUNCH PROGRAM $36,541
16.606 STATE CRIMINAL ALIEN ASSISTANCE PROGRAM $35,715
93.659 COVID-19, ADOPTION ASSISTANCE $34,760
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $32,895
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $31,870
93.472 TITLE IV-E PREVENTION PROGRAM $31,711
90.404 HAVA ELECTION SECURITY GRANTS $27,673
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $26,427
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $25,467
10.553 SCHOOL BREAKFAST PROGRAM $22,997
10.912 ENVIRONMENTAL QUALITY INCENTIVES PROGRAM $22,045
20.710 TECHNICAL ASSISTANCE GRANTS $17,825
93.324 STATE HEALTH INSURANCE ASSISTANCE PROGRAM $17,292
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $17,013
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $16,928
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $15,125
93.778 MEDICAL ASSISTANCE PROGRAM $14,292
93.071 MEDICARE ENROLLMENT ASSISTANCE PROGRAM $14,243
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $12,644
20.703 INTERAGENCY HAZARDOUS MATERIALS PUBLIC SECTOR TRAINING AND PLANNING GRANTS $11,816
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $11,124
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $10,000
15.226 PAYMENTS IN LIEU OF TAXES $6,214
93.090 COVID-19, GUARDIANSHIP ASSISTANCE $5,560
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $5,310
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $4,188
93.659 ADOPTION ASSISTANCE $3,455
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $3,000
93.658 COVID-19, FOSTER CARE TITLE IV-E $1,868
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $1,000
97.067 HOMELAND SECURITY GRANT PROGRAM $900
96.001 SOCIAL SECURITY DISABILITY INSURANCE $531
93.090 GUARDIANSHIP ASSISTANCE $99