Finding 509687 (2023-009)

Assistance Listing 14.239 Home Investment Partnerships Program Assistance Listing 93.569 Community Services Block Grant Condition: The Office of Homeless Services (OHS) contracted with one subrecipient to provide services for both the Home Investment Partnerships Program (HOME) and Community Services Block Grant (CSBG). OHS did not perform a risk assessment to determine the appropriate monitoring of this subrecipient as required under 2 CFR §200.331(b). Funding for HOME is received from the U.S. Department of Housing and Urban Development. Funding for CSBG is received from the U.S. Department of Health and Human Services and passed through the PA Department of Community and Economic Development. Criteria: OMB’s Uniform Guidance 2 CFR §200.331(b) states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring to ensure proper accountability and compliance with program requirements. Effect:Without a risk assessment, OHS may not know how to properly plan subrecipient monitoring. They may over-monitor a subrecipient that should be considered low risk or under-monitor a subrecipient that should be considered high risk. Cause: OHS had not implemented policies and procedures to ensure the performance of risk assessments for all subrecipients. Recommendation: OHS should implement policies and procedures to ensure the performance of risk assessments for all subrecipients to determine the appropriate level of subrecipient monitoring. Views of the Responsible Officials and Corrective Action Plan: OHS is in the process of finalizing a risk assessment and a RA policy and procedure to ensure that the RAs are completed timely and inform our monitoring plan. Both will be in compliance with OMB’s Uniform Guidance 2 CFR §200.331(b). PHMC will be the first subrecipient that will be tested. We will provide that risk assessment to your office and our partners at DHCD when it is completed. It is the goal to have this RA finalized and all grant funded program providers assessed for risk by 12/31/2024. Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556