FAC Explorer

Finding 1170371 (2024-001)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2026-01-23
Audit: 383503
Organization: CASA/Youth Advocates Inc. (PA)
Auditor: WILKIN & GUTTENPLAN PC

AI Summary

  • Core Issue: The Organization lacks proper procedures for monitoring subrecipients under the PCCD grant, risking non-compliance with grant terms.
  • Impacted Requirements: The Organization must review all supporting documentation, not just summary-level reports, to ensure expenses are allowable.
  • Recommended Follow-Up: Implement a detailed review process for invoices and approvals before reimbursing subrecipients to prevent unallowable costs.

Finding Text

During our audit, it came to our attention that the Organization does not have appropriate procedures when it comes to monitoring the subrecipients under the Pennsylvania Commission on Crime and Delinquency (PCCD) grant. Since the Organization is the legal recipient of the award, the Organization is accountable to the PCCD for ensuring that the funds are used in accordance with the terms and conditions of the grant. Criteria and Condition: It is the Organization’s responsibility to monitor and review all proof of expenses from the subrecipients prior to reimbursing. Currently, management relies on summary-level expense reports provided by the subrecipient; however, the Uniform Guidance requires review and approval of all underlying supporting documentation. Cause: Management does not view all supporting documentation, such as invoices, prior to sending funding to the subrecipients. Effect: The subrecipients could have unallowable expenses submitted for reimbursement. Recommendations: We recommend establishing a detailed review process to help ensure compliance with grant requirements, improve oversight of subrecipient spending, and reduce the risk of unallowable or unsupported costs being reimbursed. This includes reviewing the list of invoices submitted against the actual invoices, ensuring that the invoices that are being submitted for reimbursement are aligned with the grant's allowable costs, and ensuring that there are proper approvals/sign offs from management. All of this should be done prior to sending funding to the subrecipients.

Corrective Action Plan

Management Responses: We acknowledge that prior to this audit, CASA relied on summary-level expense reports from subrecipients under the PCCD grant and did not consistently verify underlying invoices. The established oversight also included the following efforts: 1) the individual previously responsible for invoicing did review submissions for reasonableness against the approved budget, 2) subrecipients were advised to maintain detailed back-up for all expenses, and 3) the Coalition Director regularly visited subrecipient sites to observe work being completed and to meet and observe personnel covered by the grant. However, we acknowledge this process did not meet the full requirements of the Uniform Guidance. While prior audits were not performed under Government Auditing Standards , management notes that the agency has received federal funding since 2016 with no history of previous management-related findings. The identified grant in this finding was a pilot project and the first time the agency has managed subrecipients. Corrective Actions Already Taken: CASA has engaged a new contracted accounting firm with a wider breadth of experience and expertise. CASA has completed an internal restructuring to provide increased opportunity for oversight and review of contracted financial services. CASA has adopted a new review protocol requiring verification of all supporting documentation for subrecipient reimbursements. The Operations Manager now performs a detailed review of invoices, approvals, and alignment with allowable costs prior to releasing funds. Planned Actions: Subrecipient Monitoring Policy: CASA will implement a policy immediately that includes: A standardized invoice review checklist (verifying vendor, date, amount, and allowability). Documentation of management approvals and sign-offs. Monitoring visits or virtual reviews for subrecipients by Coalition Director or Operations Director. Communication: CASA will issue written guidance to all subrecipients outlining documentation requirements and timelines.

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
16.575 CRIME VICTIM ASSISTANCE $101,221
93.647 SOCIAL SERVICES RESEARCH AND DEMONSTRATION $41,936
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $30,688
16.756 COURT APPOINTED SPECIAL ADVOCATES $9,755
93.669 CHILD ABUSE AND NEGLECT STATE GRANTS $6,249