FAC Explorer

Finding 509684 (2023-010)

Significant Deficiency
Requirement
G
Questioned Costs
-
Year
2023
Accepted
2024-11-21
Audit: 329338
Organization: City of Philadelphia (PA)
Auditor: City of Philadelphia Office of the Controller

AI Summary

  • Core Issue: OHS failed to provide complete documentation for matching funds in 2 out of 6 grant allocations, risking non-compliance with federal regulations.
  • Impacted Requirements: The lack of documentation violates 24 CFR 578.73(a) and (c)(3), which mandates a 25% match for grant funds.
  • Recommended Follow-Up: OHS should develop and implement written policies for maintaining matching documentation to ensure compliance.

Finding Text

Assistance Listing 14.267 Continuum of Care Program Condition: For one out of six grant agreements tested, the Office of Homeless Services (OHS) was unable to provide complete supporting documentation for matching amounts. The grant agreement was passed through to subrecipients via six grant allocations, and OHS could not provide the supporting documentation for matching amounts for two out of the six grant allocations. Funding for this program is received from the U.S. Department of Housing and Urban Development. Criteria: Per 24 CFR 578.73(a) and (c)(3), the recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of funds or in-kind contributions from other sources. Before grant execution, services to be provided by a third party must be documented by a memorandum of understanding (MOU) between the recipient or subrecipient and the third party that will provide the services. Effect: Failing to properly maintain matching documentation could result in OHS being non-compliant with federal regulations. Cause: OHS did not have written policies and procedures in place for the maintenance of matching documentation. Recommendation: We recommend that OHS create written policies and procedures for the maintenance of matching documentation and ensure they are implemented. Views of the Responsible Officials and Corrective Action Plan: OHS acknowledges the finding and agrees with the need to develop a corrective action plan. Given that this will require collaboration across multiple units, we are unable to provide a specific timeline for a comprehensive and accurate response at this moment. However, I will take immediate steps to initiate the necessary discussions. It is important to note that the prevailing, though incorrect, understanding within our team was that when a match involves cash, the primary source of verification occurs during the filing of the Annual Performance Report (APR). Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556

Corrective Action Plan

Assistance Listing 14.267 Continuum of Care Program Views of the Responsible Officials and Corrective Action Plan: OHS acknowledges the finding and agrees with the need to develop a corrective action plan. Given that this will require collaboration across multiple units, we are unable to provide a specific timeline for a comprehensive and accurate response at this moment. However, I will take immediate steps to initiate the necessary discussions. It is important to note that the prevailing, though incorrect, understanding within our team was that when a match involves cash, the primary source of verification occurs during the filing of the Annual Performance Report (APR). Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 509683 2023-009
    Significant Deficiency
  • 509685 2023-011
    Significant Deficiency
  • 509686 2023-012
    -
  • 509687 2023-009
    Significant Deficiency
  • 1086125 2023-009
    Significant Deficiency
  • 1086126 2023-010
    Significant Deficiency
  • 1086127 2023-011
    Significant Deficiency
  • 1086128 2023-012
    -
  • 1086129 2023-009
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.658 Foster Care Title IV-E $87.52M
14.218 Community Development Block Grants/entitlement Grants $71.31M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $58.98M
20.205 Highway Planning and Construction $44.38M
20.106 Airport Improvement Program, Covid-19 Airports Programs, and Infrastructure Investment and Jobs Act Programs $42.80M
66.458 Clean Water State Revolving Fund $38.42M
93.558 Temporary Assistance for Needy Families $37.10M
93.659 Adoption Assistance $31.86M
66.468 Drinking Water State Revolving Fund $30.47M
93.563 Child Support Services $25.60M
93.914 Hiv Emergency Relief Project Grants $22.21M
93.667 Social Services Block Grant $15.15M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $14.48M
21.023 Emergency Rental Assistance Program $11.89M
93.778 Medical Assistance Program $11.87M
93.569 Community Services Block Grant $9.17M
93.940 Hiv Prevention Activities Health Department Based $8.92M
14.267 Continuum of Care Program $8.51M
14.239 Home Investment Partnerships Program $8.51M
14.241 Housing Opportunities for Persons with Aids $7.71M
84.181 Special Education-Grants for Infants and Families $6.56M
93.224 Community Health Centers $5.81M
21.027 Coronavirus State and Local Fiscal Recovery Funds $4.62M
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $4.41M
66.958 Water Infrastructure Finance and Innovation (wifia) $3.87M
93.788 Opioid Str $3.44M
93.090 Guardianship Assistance $3.36M
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $3.33M
97.067 Homeland Security Grant Program $2.99M
93.958 Block Grants for Community Mental Health Services $2.86M
10.559 Summer Food Service Program for Children $2.82M
93.994 Maternal and Child Health Services Block Grant to the States $2.48M
93.645 Stephanie Tubbs Jones Child Welfare Services Program $2.29M
16.922 Equitable Sharing Program $2.22M
93.686 Ending the Hiv Epidemic: A Plan for America � Ryan White Hiv/aids Program Parts A and B $2.13M
97.025 National Urban Search and Rescue (us&r) Response System $2.00M
16.575 Crime Victim Assistance $1.84M
10.558 Child and Adult Care Food Program $1.84M
97.044 Assistance to Firefighters Grant $1.65M
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $1.60M
93.217 Family Planning Services $1.48M
93.556 Marylee Allen Promoting Safe and Stable Families Program $1.36M
66.001 Air Pollution Control Program Support $1.34M
93.495 Community Health Workers for Public Health Response and Resilient $1.31M
93.435 The Innovative Cardiovascular Health Program $1.21M
93.069 Public Health Emergency Preparedness $1.17M
94.006 Americorps State and National 94.006 $1.06M
93.926 Healthy Start Initiative $945,392
93.944 Human Immunodeficiency Virus (hiv)/acquired Immunodeficiency Virus Syndrome (aids) Surveillance $938,048
14.905 Lead Hazard Reduction Demonstration Grant Program $896,004
17.235 Senior Community Service Employment Program $769,951
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $752,380
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $741,812
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $702,483
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $688,513
14.231 Emergency Solutions Grant Program $663,617
16.741 Dna Backlog Reduction Program $624,969
93.088 Advancing System Improvements for Key Issues in Women's Health $583,589
93.919 Cooperative Agreement State-Based Comprehension Breast & Cervical Cancer Early Detection $542,301
93.136 Injury Prevention and Control Research and State and Community Based Programs $538,138
93.270 Viral Hepatitis Prevention and Control $528,080
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $526,867
20.600 State and Community Highway Safety $492,642
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $441,170
93.150 Projects for Assistance in Transition From Homelessness (path) $438,674
93.991 Preventive Health and Health Services Block Grant $411,069
14.900 Lead Hazard Reduction Grant Program $363,846
97.091 Homeland Security Biowatch Program $347,516
20.616 National Priority Safety Programs $343,693
93.648 Child Welfare Research Training Or Demonstration $332,623
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $319,849
10.555 National School Lunch Program $319,011
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $309,650
16.034 Coronavirus Emergency Supplemental Funding Program $301,205
17.225 Unemployment Insurance $298,231
95.007 Research and Data Analysis $287,107
93.197 Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $241,957
93.928 Special Projects of National Significance $240,993
94.011 Americorps Seniors Foster Grandparent Program (fgp) 94.011 $238,952
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $228,820
16.812 Second Chance Act Reentry Initiative $222,448
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $218,293
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $205,984
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $202,712
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $198,567
10.553 School Breakfast Program $195,911
93.387 National and State Tobacco Control Program $188,326
93.478 Preventing Maternal Deaths: Supporting Maternal Mortality Review Committees $179,834
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $176,780
97.042 Emergency Management Performance Grants $172,270
93.439 State Physical Activity and Nutrition (span $161,251
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $144,088
95.001 High Intensity Drug Trafficking Areas Program $141,517
96.006 Supplemental Security Income $134,000
14.235 Supportive Housing Program $120,359
97.056 Port Security Grant Program $111,559
30.002 Employment Discrimination State and Local Fair Employment $93,608
16.582 Crime Victim Assistance/discretionary Grants $91,687
93.669 Child Abuse and Neglect State Grants $90,797
90.401 Help America Vote Act Requirements Payments $85,860
10.680 Forest Health Protection $82,875
16.710 Public Safety Partnership and Community Policing Grants $74,876
42.001 Books for the Blind and Physically Handicapped $72,700
16.833 National Sexual Assault Kit Initiative $67,012
21.016 Equitable Sharing $65,691
93.978 Sexually Transmitted Diseases (std) Provider Education Grants $50,000
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $45,237
93.870 Maternal, Infant and Early Childhood Homevisiting Grant Program $32,843
10.569 Emergency Food Assistance Program (food Commodities) $32,642
16.588 Violence Against Women Formula Grants $31,250
93.526 Fip Verification $29,654
10.935 Urban Agriculture and Innovative Production $29,257
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $28,842
93.791 Money Follows the Person Rebalancing Demonstration $27,810
20.933 National Infrastructure Investments $27,579
16.738 Edward Byrne Memorial Justice Assistance Grant Program $27,319
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $24,503
93.945 Assistance Programs for Chronic Disease Prevention and Control $21,384
21.019 Coronavirus Relief Fund $20,000
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $16,119
15.608 Fish and Wildlife Management Assistance $4,650
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $3,923
16.836 Indigent Defense $3,459
97.132 Financial Assistance for Targeted Violence and Terrorism Prevention $549
93.268 Immunization Cooperative Agreements $212