LYCOMING-CLINTON COUNTIES COMMISSION FOR COMMUNITY ACTIONNon-Profit

COVID-19 Community Services Block Grant - Assistance Listing 93.569 passed through Pennsylvania Department of Community and Economic Development - Pass-through Grantor’s Number - C000066976; Community Services Block Grant - Assistance Listing 93.569 passed through Pennsylvania Department of Community and Economic Development - Pass- through Grantor’s Number - C000082022; Grant period - Fiscal Year Ended June 30, 2023. Criteria: The Community Services Block Grant (CSBG) Act at 42 USC 9910(a), requires nonprofit organizations administer CSBG through a board comprising not fewer than one-third of the board members are chosen in a democratic selection process adequate to assure that these members of the board are representative of the low-income individuals and families served and reside in the neighborhood served. Condition: There was a vacancy in the low income representation that reduced the required representation. Perspective Information: The vacancy, during the audit period, was July 1, 2022 - March 20, 2023. The state does not have a policy or procedure that allows a grace period to fill board vacancies. Cause: A low income representation board member resigned and STEP was unable to fill the board vacancy. Effect: STEP was not in compliance with special tests and provisions requirements for tri-partite board compliance. Questioned Costs: None. Identification of Repeat Findings: Not applicable. Recommendation: STEP should establish procedures to fill vacancies timely. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP’s corrective action plan.

COVID-19 CCDF Cluster - Assistance Listing 93.575, 93.596 passed through Pennsylvania Department of Human Services - Pass-Through Grantor?s Number - SAP DC21079943; Temporary Assistance for Needy Families- Assistance Listing 93.558 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC21079943; Grant period - Fiscal Year Ended June 30, 2022. Criteria: ELRC guidelines allow a temporary period of presumptive eligibility for a parent/caretaker experiencing homelessness. At the end of the 92-day period, the ELRC must verify that the parent/caretaker meets the work-hour requirement to maintain eligibility and reassess co-payments to be paid by the parent/caretaker. Condition: An incorrect co-payment was charged for a parent/caretaker after the temporary period of presumptive eligibility. Perspective Information: This finding is isolated to an instance of noncompliance with presumptive eligibility requirements. Cause: Policies and procedures were not properly designed and implemented to ensure compliance with presumptive eligibility requirements. Effect: STEP was not in compliance with special tests and provisions requirements for co-payments. Questioned Costs: None. Identification of Repeat Findings: Not applicable. Recommendation: STEP should ensure their file compliance review procedures include review of files at the end of periods of presumptive eligibility. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP?s corrective action plan.

COVID-19 Coronavirus Relief Fund - Assistance Listing 21.019 passed through Lycoming County, Pass through Grantor?s Number - C000073983; Grant Period - Fiscal Year Ended June 30, 2021. Criteria: The OMB Compliance Supplement 2021 for Assistance Listing 21.019 Coronavirus Relief Fund states ?Recipients may not use payments from the Fund to cover expenditures for which they will receive reimbursement from other sources?. Condition: Expenditures previously reimbursed from other grant funding sources were reimbursed with federal funds passed through the County of Lycoming. Perspective Information: Not applicable. Cause: The grant application through the County of Lycoming only required applicants to certify expenditures for which they were seeking grant funds were not previously funded through PPP or EIDL loan programs. Effect: STEP may have to repay the reimbursement. Questioned Costs: $77,763. Identification of Repeat Findings: Not applicable. Recommendation: STEP should evaluate the risk of noncompliance with federal statutes and regulations, in addition to the terms and conditions of awards passed through from a subrecipient. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP?s corrective action plan.

COVID-19 Coronavirus Relief Fund - Assistance Listing 21.019 passed through Pennsylvania Department of Human Services, Pennsylvania Housing and Finance Agency, Lycoming County - Pass-through Grantor?s Number - C000073983, Pennsylvania Department of Education; COVID-19 Emergency Rental Assistance Program - Assistance Listing 21.023 passed through Lycoming County; COVID-19 Formula Based Grants for Rural Areas - Assistance Listing 20.509 passed through Pennsylvania Department of Transportation - Pass-through Grantor?s Number - EG000827337; CCDF Cluster - Assistance Listing 93.575, 93.596 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC1879943; Social Services Block Grant - Assistance Listing 93.667 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC1879943; Grant period - Fiscal Year Ended June 30, 2021. Significant deficiency: See deficiency 2021-004 in Section II.

COVID-19 Coronavirus Relief Fund - Assistance Listing 21.019 passed through Pennsylvania Department of Human Services, Pennsylvania Housing and Finance Agency, Lycoming County - Pass-through Grantor?s Number - C000073983, Pennsylvania Department of Education; COVID-19 Emergency Rental Assistance Program - Assistance Listing 21.023 passed through Lycoming County; COVID-19 Formula Based Grants for Rural Areas - Assistance Listing 20.509 passed through Pennsylvania Department of Transportation - Pass-through Grantor?s Number - EG000827337; CCDF Cluster - Assistance Listing 93.575, 93.596 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC1879943; Social Services Block Grant - Assistance Listing 93.667 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC1879943; Grant period - Fiscal Year Ended June 30, 2021. Material weakness: See deficiency 2021-005 in Section II.

COVID-19 Coronavirus Relief Fund - Assistance Listing 21.019 passed through Pennsylvania Department of Human Services, Pennsylvania Housing and Finance Agency, Lycoming County - Pass through Grantor?s Number - C000073983, Pennsylvania Department of Education; COVID-19 Emergency Rental Assistance Program - Assistance Listing 21.023 passed through Lycoming County; COVID-19 Formula Based Grants for Rural Areas - Assistance Listing 20.509 passed through Pennsylvania Department of Transportation - Pass-through Grantor?s Number - EG000827337; CCDF Cluster - Assistance Listing 93.575, 93.596 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC1879943; Social Services Block Grant - Assistance Listing 93.667 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC1879943; Grant period - Fiscal Year Ended June 30, 2021. Material weakness: See deficiency 2021-001 in Section II.

COVID-19 Coronavirus Relief Fund - Assistance Listing 21.019 passed through Pennsylvania Department of Human Services, Pennsylvania Housing and Finance Agency, Lycoming County - Pass-through Grantor?s Number - C000073983, Pennsylvania Department of Education; COVID-19 Emergency Rental Assistance Program - Assistance Listing 21.023 passed-through Lycoming County; COVID-19 Formula Based Grants for Rural Areas - Assistance Listing 20.509 pass-through Pennsylvania Department of Transportation - Pass-through Grantor?s Number - EG000827337; CCDF Cluster - Assistance Listing 93.575, 93.596 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC1879943; Social Services Block Grant - Assistance Listing 93.667 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC1879943; Grant period - Fiscal Year Ended June 30, 2021. Significant deficiency: See deficiency 2021-002 in Section II.

COVID-19 Coronavirus Relief Fund - Assistance Listing 21.019 passed through Pennsylvania Department of Human Services, Pennsylvania Housing and Finance Agency, Lycoming County - Pass-through Grantor?s Number - C000073983, Pennsylvania Department of Education; COVID-19 Emergency Rental Assistance Program - Assistance Listing 21.023 passed through Lycoming County; COVID-19 Formula Based Grants for Rural Areas - Assistance Listing 20.509 passed through Pennsylvania Department of Transportation - Pass-through Grantor?s Number - EG000827337; CCDF Cluster - Assistance Listing 93.575, 93.596 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC1879943; Social Services Block Grant - Assistance Listing 93.667 passed through Pennsylvania Department of Human Services - Pass-through Grantor?s Number - SAP DC1879943; Grant period - Fiscal Year Ended June 30, 2021. Significant deficiency: See deficiency 2021-003 in Section II.

Head Start Cluster - Assistance Listing 93.600; Grant Period - Fiscal Year Ended June 30, 2021. Significant deficiency: See deficiency 2021-004 in Section II. Questioned costs: $57,454.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES CORPORATION FOR NATIONAL AND COMMUNITY SERVICE 2020-005. Aging Cluster - CFDA No. 93.044 / 93.045 / 93.053; Passed through Pennsylvania Department of Aging; Pass-through Grantor?s Number - 4100072788; Head Start Cluster - CFDA No. 93.600; Medicaid Cluster - CFDA No. 93.778; Passed through Pennsylvania Department of Human Services, passed through Lycoming County and Clinton County; AmeriCorps - CFDA No. 94.006; Passed through Pennsylvania Department of Labor & Industry, PennSERVE; Pass-through Grantor?s Number - SAP 4100084233; Grant Period - Fiscal Year Ended June 30, 2020. Significant deficiency: See deficiency 2020-001 in Section II.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES CORPORATION FOR NATIONAL AND COMMUNITY SERVICE 2020-006. Aging Cluster - CFDA No. 93.044 / 93.045 / 93.053; Passed through Pennsylvania Department of Aging; Pass-through Grantor?s Number - 4100072788; Head Start Cluster - CFDA No. 93.600; Medicaid Cluster - CFDA No. 93.778; Passed through Pennsylvania Department of Human Services, passed through Lycoming County and Clinton County; AmeriCorps - CFDA No. 94.006; Passed through Pennsylvania Department of Labor & Industry, PennSERVE; Pass-through Grantor?s Number - SAP 4100084233; Grant Period - Fiscal Year Ended June 30, 2020. Significant deficiency: See deficiency 2020-002 in Section II.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES CORPORATION FOR NATIONAL AND COMMUNITY SERVICE 2020-007. Aging Cluster - CFDA No. 93.044 / 93.045 / 93.053; Passed through Pennsylvania Department of Aging; Pass-through Grantor?s Number - 4100072788; Medicaid Cluster - CFDA No. 93.778; Passed through Pennsylvania Department of Human Services, passed through Lycoming County and Clinton County; AmeriCorps - CFDA No. 94.006; Passed through Pennsylvania Department of Labor & Industry, PennSERVE; Pass-through Grantor?s Number - SAP 4100084233; Grant Period - Fiscal Year Ended June 30, 2020. Significant deficiency: See deficiency 2020-003 in Section II.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 2020-008. Head Start Cluster - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2020. Significant deficiency: See deficiency 2020-003 in Section II. Questioned costs: $38,834.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 2020-009. Head Start Cluster - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2020. Criteria: The Uniform Guidance requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Health & Human Services regulation 45 CFR Part 75.430 states that budget estimates alone do not qualify as support for charges to federal awards. Condition: Personnel expenses were charged to the federal award based on the application budget and no after-the-fact review was performed to ensure amounts were properly allocated. Perspective Information: Not applicable. Questioned Costs: None. Cause: Documentation of personnel expenses are not supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Effect: The Federal Government may require personnel activity reports, including prescribed certifications, or equivalent documentation that support the records as required in the Uniform Guidance. Identification of Repeat Findings: Not applicable. Recommendation: Documentation should be maintained to support personnel expenses in the application budget. After-the-fact reviews should be performed to ensure amounts are properly allocated. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP?s corrective action plan.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 2020-010. Head Start Cluster - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2020. Criteria: Controls should be properly designed and implemented to ensure required reports for federal awards are submitted by due dates. Condition: Reports were filed after the due date. Perspective Information: 1 out of 3 reports selected for testing were submitted after the due dates. Questioned Costs: None. Cause: Reports were not ready to be filed. Effect: STEP is not in compliance with grant reporting requirements. Identification of Repeat Findings: 2019-006 Recommendation: Reports should be filed by the due date. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP?s corrective action plan.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 2020-011. Head Start Cluster - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2020. Criteria: Required reports for federal awards should be reviewed prior to submittal. Condition: Reports did not contain a documented review. Perspective Information: 3 out of 3 reports tested did not contain a documented review. Questioned Costs: None. Cause: STEP?s policies are not designed to provide a documented review of reports. Effect: Intentional or unintentional errors could occur and not be detected. Identification of Repeat Findings: 2019-007 Recommendation: A documented review and approval of all reports submitted should be performed. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP?s corrective action plan.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 2020-012. Head Start Cluster - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2020. Criteria: Real property acquired or improved with a federal award requires a physical inventory and the results reconciled with the property records at least once every two years. Condition: Real property improved with a federal award did not reconcile to the property records. Perspective Information: Not applicable. Questioned Costs: None. Cause: Reconciliation was not performed. Effect: STEP is not in compliance with grant requirements to reconcile property records. Identification of Repeat Findings: 2019-008 Recommendation: Property records should be reconciled at least once every two years. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP?s corrective action plan.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES U.S. DEPARTMENT OF TRANSPORTATION 2019-003. Enhanced Mobility of Seniors and Individuals with Disabilities - Transit Services Programs Cluster - CFDA No. 20.513; Passed through Pennsylvania Department of Transportation; Pass-through Grantor?s Number - EG00002655; TANF Cluster - CFDA No. 93.558; Passed through Pennsylvania Department of Human Services; Pass-through Grantor?s Number - SAP DC18-79943 and SAP4100064759; Head Start - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2019. Significant deficiency: See deficiency 2019-001 in Section II.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES U.S. DEPARTMENT OF TRANSPORTATION 2019-004. Enhanced Mobility of Seniors and Individuals with Disabilities - Transit Services Programs Cluster - CFDA No. 20.513; Passed through Pennsylvania Department of Transportation; Pass-through Grantor?s Number - EG00002655; TANF Cluster - CFDA No. 93.558; Passed through Pennsylvania Department of Human Services; Pass-through Grantor?s Number - SAP DC18-79943 and SAP4100064759; Head Start - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2019. Criteria: Someone independent of preparing the Schedule of Expenditures of Federal Awards (SEFA) should review and approve the SEFA. Condition: The SEFA was not reviewed by a person independent of preparing the schedule. Cause: Due to turnover in the fiscal department during the year, STEP did not follow their policy to perform a review. Effect: The SEFA could be misstated. Perspective Information: Not applicable. Identification of Repeat Findings: Not applicable. Recommendation: Someone independent of preparing the SEFA should review and document their review of the SEFA. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP?s corrective action plan.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 2019-005. TANF Cluster - CFDA No. 93.558; Passed through Pennsylvania Department of Human Services; Pass-through Grantor?s Number - SAP DC18-79943 and SAP4100064759; Head Start - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2019. Significant deficiency: See deficiency 2019-002 in Section II.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 2019-006. Head Start - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2019. Criteria: Controls should be properly designed and implemented to ensure required reports for federal awards are submitted by due dates. Condition: Reports were filed after the due date. Questioned Costs: None. Cause: Reports were not ready to be filed. Effect: STEP is not in compliance with grant reporting requirements. Perspective Information: 1 out of 5 reports selected for testing were submitted after the due dates. Identification of Repeat Findings: Not applicable. Recommendation: Reports should be filed by the due date. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP?s corrective action plan.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 2019-007. Head Start - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2019. Criteria: Required reports for federal awards should be reviewed prior to submittal. Condition: Reports did not contain a documented review. Questioned Costs: None. Cause: STEP?s policies are not designed to provide a documented review of reports. Effect: Intentional or unintentional errors could occur and not be detected. Perspective Information: 5 out of 5 reports tested did not contain a documented review. Identification of Repeat Findings: Not applicable. Recommendation: A documented review and approval of all reports submitted should be performed. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP?s corrective action plan.

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 2019-008. Head Start - CFDA No. 93.600; Grant Period - Fiscal Year Ended June 30, 2019. Criteria: Real property acquired or improved with a federal award requires a physical inventory and the results reconciled with the property records at least once every two years. Condition: Real property improved with a federal award did not reconcile to the property records. Questioned Costs: None. Cause: Reconciliation did not occur. Effect: STEP is not in compliance with grant requirements to reconcile property records. Perspective Information: Information reported to Head Start was fairly stated. Prior year federal awards for real property improvements were not capitalized in the general ledger. Identification of Repeat Findings: Not applicable. Recommendation: Property records should be reconciled at least once every two years. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See STEP?s corrective action plan.

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