Finding 1164825 (2024-002)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-12-15
Audit: 374654
Organization: County of Montgomery (PA)

AI Summary

  • Core Issue: The County did not obtain or review annual audit reports from subrecipients, violating federal monitoring requirements.
  • Impacted Requirements: This oversight breaches 2 CFR Section 200.332, which mandates that pass-through entities verify subrecipient audits and address any findings.
  • Recommended Follow-Up: The County should enhance its policies to ensure timely collection and review of subrecipient audit reports, including evaluating relevant findings and assessing risk.

Finding Text

Finding 2024-002 – Subrecipient Monitoring Federal Agency: Department of Treasury Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – ALN #21.027 Condition: As part of the monitoring process, the County did not obtain and review the annual audit reports of subrecipients. Criteria: Per 2 CFR Section 200.332 Requirements for pass-through entities, a pass-through entity must: (g) Verify that a subrecipient is audited as required by subpart F of 200.332. In addition, a pass through entity must resolve subrecipient audit findings specifically related to the subaward. Cause: The County does not have procedures in place to adequately review the subrecipient audits received. Effect: Failure to obtain and review subrecipient audit reports increases the risk that subrecipient noncompliance, internal control deficiencies, or questioned costs remain unidentified and unaddressed, which may result in unallowable costs being charged to the federal awards. Repeat Finding: No Recommendation: The County should update written policies and procedures to require timely obtaining and documented review of subrecipient audit reports including documented evaluation of findings relevant to the PTE’s awards and assessment of subrecipient risk. Questioned Costs: Unknown Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate correction action plan.

Corrective Action Plan

Finding 2024-002 - Subrecipient Monitoring Federal Agency: Department of Treasury Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - ALN #21.027 Condition: As part of the monitoring process, the County did not obtain and review the annual audit reports of subrecipients. Planned Corrective Action: Upon notification of this issue during the 2024 Single Audit, the County immediately took action to implement corrective actions to be compliant with this with this requirement. The County modified the subrecipient quarterly report template for Q3 2025 to include a question requiring all subrecipients to verify if they were audited as required by subpart F of 200.332. The County then conducted the required follow up to obtain and review each audit to identify any significant developments that might negatively impact the subaward. Of the 27 subrecipient audits reviewed, only one had a finding related to 21.027 regarding keeping records of their reporting to the County and hiring a full-time finance director. The County followed up with the subrecipient to confirm that they have put their corrective action into place and the subrecipient responded that this was complete. Additionally, there were four subrecipients who reported that they were required to have an audit, but it wasn't completed yet. The County is in the process of conducting follow-up with these organizations to remind them of their responsibilities under 200.332 and to obtain and review the required audits. The County will conduct subrecipient monitoring of ARPA subrecipients each year throughout the remainder of the program. Additionally, the Controllers department will provide Subrecipient Monitoring training and information in 2026 to County departments who administer subrecipient funding in order to assist them in fully complying with this requirement Name(s) of contact person(s) responsible for corrective action: Fonta Reilly and Eli Gilman Planned completion date for corrective action plan: Corrective action implemented in November 2025

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1164821 2024-002
    Material Weakness Repeat
  • 1164822 2024-002
    Material Weakness Repeat
  • 1164823 2024-002
    Material Weakness Repeat
  • 1164824 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $25.13M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $7.04M
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $5.38M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $4.97M
21.023 COVID-19 EMERGENCY RENTAL ASSISTANCE PROGRAM $1.23M
93.563 CHILD SUPPORT SERVICES $1.12M
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $1.11M
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $1.08M
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $966,276
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $402,684
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $390,902
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $374,652
14.920 LEAD HAZARD CONTROL FOR HIGH RISK AREAS $356,440
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $354,414
93.044 COVID-19 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $308,977
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $300,333
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $290,404
16.838 COMPREHENSIVE OPIOID, STIMULANT, AND OTHER SUBSTANCES USE PROGRAM $289,199
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $262,942
93.667 SOCIAL SERVICES BLOCK GRANT $241,990
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $238,758
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $230,977
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $204,396
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $178,653
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $178,168
93.052 COVID-19 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $173,576
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $154,065
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $149,130
14.218 COVID-19 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $146,044
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $141,684
16.575 CRIME VICTIM ASSISTANCE $130,781
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $129,206
20.205 HIGHWAY PLANNING AND CONSTRUCTION $125,577
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $125,186
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $121,594
16.839 STOP SCHOOL VIOLENCE $115,065
93.778 COVID-19 MEDICAL ASSISTANCE PROGRAM $106,135
97.067 HOMELAND SECURITY GRANT PROGRAM $95,624
93.071 MEDICARE ENROLLMENT ASSISTANCE PROGRAM $82,298
93.788 OPIOID STR $78,940
93.958 COVID-19 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $75,625
93.045 COVID-19 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $75,000
90.404 HAVA ELECTION SECURITY GRANTS $74,969
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $65,103
14.913 HEALTHY HOMES PRODUCTION PROGRAM $65,023
93.472 TITLE IV-E PREVENTION PROGRAM $63,987
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $60,274
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $51,877
93.197 CHILDHOOD LEAD POISONING PREVENTION PROJECTS, STATE AND LOCAL CHILDHOOD LEAD POISONING PREVENTION AND SURVEILLANCE OF BLOOD LEAD LEVELS IN CHILDREN $49,704
20.939 SAFE STREETS AND ROADS FOR ALL $45,315
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $43,680
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $41,738
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $39,999
14.239 COVID-19 HOME INVESTMENT PARTNERSHIPS PROGRAM $37,750
93.940 HIV PREVENTION ACTIVITIES HEALTH DEPARTMENT BASED $34,068
93.778 MEDICAL ASSISTANCE PROGRAM $32,117
93.324 STATE HEALTH INSURANCE ASSISTANCE PROGRAM $31,250
20.505 METROPOLITAN TRANSPORTATION PLANNING AND STATE AND NON-METROPOLITAN PLANNING AND RESEARCH $28,909
10.553 SCHOOL BREAKFAST PROGRAM $27,603
93.959 COVID-19 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $27,512
97.036 COVID-19 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $24,583
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $23,646
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $21,858
14.267 CONTINUUM OF CARE PROGRAM $21,502
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $18,505
93.791 MONEY FOLLOWS THE PERSON REBALANCING DEMONSTRATION $16,883
17.258 WIOA ADULT PROGRAM $15,438
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $15,271
93.658 FOSTER CARE TITLE IV-E $11,681
10.555 NATIONAL SCHOOL LUNCH PROGRAM $10,567
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $10,000
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $7,405
97.024 COVID-19 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $6,139
17.277 WIOA NATIONAL DISLOCATED WORKER GRANTS / WIA NATIONAL EMERGENCY GRANTS $5,529
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $5,487
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $4,389
17.259 WIOA YOUTH ACTIVITIES $4,143
93.659 ADOPTION ASSISTANCE $3,867
10.576 SENIOR FARMERS MARKET NUTRITION PROGRAM $3,171
93.747 COVID-19 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $2,733
93.042 COVID-19 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $1,333
93.090 GUARDIANSHIP ASSISTANCE $262