Finding 35568 (2022-001)

Material Weakness
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2023-08-29
Audit: 24837
Organization: County of Butler (PA)

AI Summary

  • Core Issue: The County lacks a documented process to assess the risk of subrecipients not complying with regulations.
  • Impacted Requirements: Compliance with PA DHS and 2 CFR sections 200.332(b) and (d) regarding subrecipient monitoring and audit follow-up.
  • Recommended Follow-Up: Implement procedures for risk assessment and ensure timely review of subrecipient audits to address identified risks.

Finding Text

Please see table on page 16 of the Single Audit.Finding 2022-001 ? Subrecipient Monitoring Condition: The County did not have a documented risk assessment process for evaluating subrecipient?s risk of non-compliance. Additionally, as part of the monitoring process, the County did not have controls in place to obtain and review the annual audit reports of all subrecipients in a timely manner with documentation of such review. Criteria: The Pennsylvania Department of Human Services (PA DHS) and 2 CFR section 200.332(b) 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. Cause: There were no procedures in place to document the County?s assessment of risk for subrecipients. In addition, the County does not have procedures in place to adequately review the subrecipient audits received. 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 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 and deficiencies be followed up on, if applicable. Questioned Costs: Unknown Views of Responsible Official and Planned Corrective Action: Management agrees with the finding. See separate correction action plan.

Corrective Action Plan

Corrective Action Plan - Finding 2022-001 The County will implement procedures to formally document and complete a risk assessment of sub-recipients (provider), and for the development of monitoring procedures to address the risks. This corrective action plan calls for the County's Human Services department to annually prepare a risk assessment for each provider for the fiscal period, and submit it along with the funding awards, if available, to the Butler County Controller office, by August 31st of each year. The County Controllers office will then by documenting that the amount of the awards, if available, agree to the County's general ledger. Additionally, the Controller's office will document whether or not a risk assessment has been performed for the provider. The funding award, along with the risk assessment shall serve as the basis from which the Controller's office will review the provider's audits and deficiencies. Provider audits for years-ending on December 31st are due within 180 days, or June 30th each year. Similarly, provider audits for year-ending June 30th are due within 180 days, or December 31st of each year. If an audit report is not received within six month, and an extension for time has not be granted, a delinquent letter will be issued by the Human Services department to the provider, not more than thirty (30) days after the deadline. For providers with a 12/31 year-end, the Controller's office will notify the Human Services department by September 30th each year, issuing a documentation that lists the provider that failed to submit an acceptable audit report; and further action will be documented by the Human Services department. Likewise, for providers with a 06/30 year-end, the Controller's office will notify the Human Services department by March 31st each year, issuing documentation that lists the providers that failed to submit an acceptable audit report; and further action will be taken and noted by the Human Services department. Audit opinions, findings, or deficiencies that indicate concern will be communicated by the Controller's office, to the Human Services department in a timely manner, but no less than ninety (90) days after the report was received by the Controller's office. In the event that a sub-recipient is issued a finding in their Single Audit, the County, either through the Board of Commissioners or the Human Services Department, shall furnish a written management decision to the Auditee, within six months of the audit being received by the Federal Audit Clearinghouse. The risk assessments and subsequent monitoring procedures, including review of the provider audits for the previous fiscal contract period, will be presented formally to the Board of County Commissioners, County Controller, and Director of Human Services by April 30th of the following year.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 612010 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.023 Covid-19 Emergency Rental Assistance Program $7.18M
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $4.68M
93.659 Adoption Assistance $1.55M
93.658 Foster Care_title IV-E $1.34M
20.205 Highway Planning and Construction $1.13M
93.778 Medical Assistance Program $849,699
14.231 Covid-19 Emergency Solutions Grant Program $718,968
93.788 Opioid Str $592,206
14.228 Covid-19 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $320,166
93.558 Temporary Assistance for Needy Families $309,260
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $284,189
93.959 Block Grants for Prevention and Treatment of Substance Abuse $280,538
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $278,257
93.563 Child Support Enforcement $237,576
93.958 Block Grants for Community Mental Health Services $231,824
20.509 Covid-19 Formula Grants for Rural Areas and Tribal Transit Program $220,007
93.044 Covid-19 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $200,381
14.267 Continuum of Care Program $191,400
84.181 Special Education-Grants for Infants and Families $155,952
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $146,895
10.569 Emergency Food Assistance Program (food Commodities) $124,454
93.659 Covid-19 Adoption Assistance $121,637
93.090 Guardianship Assistance $106,737
90.404 Covid-19 2018 Hava Election Security Grants $105,268
97.042 Emergency Management Performance Grants $101,562
93.667 Social Services Block Grant $94,092
93.150 Projects for Assistance in Transition From Homelessness (path) $81,903
93.052 National Family Caregiver Support, Title Iii, Part E $81,050
93.778 Covid-19 Medical Assistance Program $75,722
93.052 Covid-19 National Family Caregiver Support, Title Iii, Part E $66,237
14.239 Home Investment Partnerships Program $61,969
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $61,288
93.053 Nutrition Services Incentive Program $57,250
93.959 Covid-19 Block Grants for Prevention and Treatment of Substance Abuse $54,255
16.588 Violence Against Women Formula Grants $46,875
20.600 State and Community Highway Safety $38,797
93.048 Covid-19 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $37,817
97.047 Pre-Disaster Mitigation $37,498
20.616 National Priority Safety Programs $32,700
16.575 Crime Victim Assistance $31,889
93.645 Stephanie Tubbs Jones Child Welfare Services Program $31,194
93.658 Covid-19 Foster Care_title IV-E $29,399
93.779 Centers for Medicare and Medicaid Services (cms) Research, Demonstrations and Evaluations $18,478
10.568 Emergency Food Assistance Program (administrative Costs) $17,308
90.404 2018 Hava Election Security Grants $16,960
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $15,018
93.071 Medicare Enrollment Assistance Program $13,817
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $12,938
93.090 Covid-19 Guardianship Assistance $11,629
93.556 Promoting Safe and Stable Families $9,313
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $8,873
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $8,840
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $7,039
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $2,247
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $1,208