COUNTY COMMISSIONERS ASSOCIATION OF PENNSYLVANIA

2024-001 - (Noncompliance) Uniform Guidance Written Policies/Procedures Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758 Condition/Context: While the Organization has informal policies and procedures surrounding the administration of its federal programs, these policies and procedures have not been formally documented to ensure compliance with the areas of allowability of costs, cash management, procurement, travel, conflict of interest or subrecipient monitoring as required under the Uniform Guidance. Corrective Action Plan: To address this finding and strengthen our internal controls and compliance framework, CCAP will be implementing the following corrective actions: 1. Policy Development and Documentation: o We will be initiating a project to develop and formalize comprehensive written policies and procedures in the following required areas:  Allowability of Costs (2 CFR §200.403–§200.405)  Cash Management (2 CFR §200.305)  Procurement Standards (2 CFR §200.317–§200.326)  Travel Costs (2 CFR §200.474)  Conflict of Interest (2 CFR §200.112)  Subrecipient Monitoring (2 CFR §200.331–§200.333) o These policies will reference relevant Uniform Guidance sections and incorporate internal controls, approval processes, and documentation standards. 2. Internal Review and Approval: o Draft policies will be reviewed by senior leadership, legal counsel (if necessary), and the finance and grants teams to ensure alignment with regulatory requirements and operational realities. 3. Training and Dissemination: o Once finalized, all relevant staff (including program managers, finance personnel, and procurement staff) will receive training on the new policies. o Policies will be made available on CCAP’s intranet. 4. Ongoing Maintenance and Review: o A process will be established for annual review and update of these policies to incorporate regulatory changes and feedback from internal audits or grantor reviews.

2024-002 - Subrecipient Monitoring - Material Weakness/Noncompliance Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758 Condition/Context: The Organization does not have a formal risk assessment or oversight program in place to monitor its subrecipients as required under the Uniform Guidance, including ensuring that financial information reconciles between the underlying expenditure reports and the subrecipient/Organization audit reports. Corrective Action Plan: CCAP will be implementing the following corrective actions: 1. Formalization of Subaward Documentation: o We will revise our subaward agreement templates to ensure that all required elements (as outlined in 2 CFR §200.331(a)) are explicitly included. o All subawards will clearly identify the agreement as a “subaward” and specify required data elements such as the Federal Award Identification Number (FAIN), CFDA/Assistance Listing number, period of performance, and applicable federal terms and conditions. 2. Subrecipient Risk Assessment Framework: o A standardized risk assessment tool is being developed and will be implemented for all subrecipients prior to executing a subaward. o This tool will evaluate prior audit history, organizational capacity, experience with federal funds, and other risk indicators as required by §200.331(b). 3. Monitoring and Oversight Procedures: o We are enhancing our subrecipient monitoring policy to include a tiered approach based on the results of the risk assessment. o Monitoring activities will include regular desk reviews, periodic programmatic and financial reporting, and site visits for high-risk subrecipients as per §200.331(d)-(e). 4. Audit Verification: o Our grants team will verify annually that each subrecipient subject to audit under Subpart F has completed the required Single Audit. o We will obtain and review audit reports and maintain documentation of our review in accordance with §200.331(f). 5. Results Review and Adjustments: o Any issues identified through audits, site visits, or other monitoring will be evaluated to determine if they necessitate changes in our records, subaward terms, or overall monitoring strategy (§200.331(g)). 6. Enforcement Procedures: o We are formalizing a process for escalating issues of noncompliance, including written warnings, corrective action plans, suspension of funds, or termination of subawards, as appropriate and consistent with §200.338.

2024-003 – Reporting – Significant Deficiency Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758 Condition/Context: The Organization identified during the preparation of its second quarter 2024 expenditure report approximately $25,000 in costs incurred during November 2022 that had not previously been included in a submitted expenditure report to PCCD and which were included in the second quarter 2024 expenditure report. While such costs were incurred during the overall program performance period and were allowable and attributable to the program, such costs were not timely identified and reported on the correct expenditure report. Corrective Action Plan: To strengthen our internal controls and ensure full compliance with grantor reporting requirements, we are implementing the following corrective measures: 1. Review and Update of Reporting Procedures: o We will review and revise our existing grant expenditure reporting procedures to ensure that all expenditures are properly captured, reviewed, and reconciled before submission to the grantor. o Revised procedures will clearly define roles and responsibilities for program staff, grants management, and accounting. 2. Monthly Reconciliation Process: o A monthly reconciliation process will be implemented to match recorded expenditures in the general ledger with grant budgets and program activity. o Variances will be reviewed and resolved in advance of quarterly reporting deadlines to prevent errors in submitted reports. 3. Dual Review and Approval: o All quarterly expenditure reports will be subject to dual review by the grant’s accountant and the accounting operations manager prior to submission. o This control will ensure that reports are complete, accurate, and supported by accounting records. 4. Training and Communication: o Finance and program staff involved in grant administration and reporting will receive training on updated procedures and internal control expectations. o Ongoing communication between departments will be encouraged to ensure awareness of allowable costs, budget constraints, and reporting timelines. 5. System Enhancements: o We are evaluating our current financial system and looking for a system that will allow better tracking of grant-specific expenditures, including improved reporting functionality and coding accuracy.

GSA_MIGRATION

GSA_MIGRATION