EIN: 236003116
UEI: CLFPC66PJC16
Audited by: MAHER DUESSEL, CPAS
Oversight agency: 21 [Department of the Treasury]
View federal awards & risk assessment →
Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 19, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 19, 2026 (74 days ago).
What is a management decision? →The City’s payroll charging process for the CDBG program relies on budgeted percentages during the year and lacks a documented, operating after‑the‑fact review and reconciliation control that compares interim allocations to biweekly timesheets and records timely adjustments. Although biweekly timesheets reflect actual time worked on CDBG, the control structure does not ensure interim postings are periodically trued up to actual effort. Out of 27 payrolls, we sampled seven pay periods and determined excess CDBG expenses of $11,727 were charged to the program based upon actual time worked versus the budgeted allocations. Criteria: The City should maintain an effective system of internal control over Federal awards that is established, documented, and operating to provide reasonable assurance that financial activity is properly recorded and managed. Cause: The City does not have adequate procedures in place to verify that payroll costs are allocated in an equitable manner in accordance with the Uniform Guidance. Effect: The City overstated CDBG payroll charges and is not allocating CDBG payroll costs equitably. Repeat Finding: Yes. Questioned costs known and likely: Total of $45,477, $11,727 known and $33,750 likely. Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements, which should include a periodic analysis comparing actual time spent on the CDBG program versus the budgeted allocations and evaluating need for adjustments. View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2024-002 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development (HUD) – CDBG – Entitlement/Special Grants Cluster: Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City’s payroll charging process for the CDBG program relies on budgeted percentages during the year and lacks a documented, operating after‑the‑fact review and reconciliation control that compares interim allocations to biweekly timesheets and records timely adjustments. Although biweekly timesheets reflect actual time worked on CDBG, the control structure does not ensure interim postings are periodically trued up to actual effort. Out of 27 payrolls, we sampled seven pay periods and determined excess CDBG expenses of $11,727 were charged to the program based upon actual time worked versus the budgeted allocations. Criteria: The City should maintain an effective system of internal control over Federal awards that is established, documented, and operating to provide reasonable assurance that financial activity is properly recorded and managed. Cause: The City does not have adequate procedures in place to verify that payroll costs are allocated in an equitable manner in accordance with the Uniform Guidance. Effect: The City overstated CDBG payroll charges and is not allocating CDBG payroll costs equitably. Repeat Finding: Yes. Questioned costs known and likely: Total of $45,477, $11,727 known and $33,750 likely. Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements, which should include a periodic analysis comparing actual time spent on the CDBG program versus the budgeted allocations and evaluating need for adjustments. View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2024-002—Activities Allowed or Unallowed Repeat Finding—See Finding 2023-003, 2022-004 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements, which should include a periodic analysis comparing actual time spent on the CDBG program versus the budgeted allocations and evaluating need for adjustments. Action Taken: Effective June 30, 2025, the City adopted additional procedures for the review of payroll-related reimbursements by the Grants Accountant and Grants Manager prior to funds being drawn. Time spent on the CDBG program will be evaluated at least annually by the Grants Manager and Grants Accountant as part of the budget process.
2023-003
FAC accepted this audit on January 24, 2025 — management decision was due July 24, 2025.
The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2023 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: Yes Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023-002 – Special Tests and Provisions – Citizen Participation Repeat Finding – See Finding 2022-003 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2023 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: Yes Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-002-SpecialTests and Provisions-Citizen Participation Repeat Finding-See Finding 2022-003 Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. Action Taken: The City has adopted HUD regulations to comply with all citizen participation requirements (24 CFR 91.105). These were implemented January 1, 2024.
2022-003
There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $1,095,919 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $2,066 of expenditures that the City was unable to provide supporting documentation and $2,352 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. Repeat Finding: Yes Questioned costs known and likely: $8,179 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023-003 – Activities Allowed or Unallowed Repeat Finding – See Finding 2022-004 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $1,095,919 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $2,066 of expenditures that the City was unable to provide supporting documentation and $2,352 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. Repeat Finding: Yes Questioned costs known and likely: $8,179 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-003-Activities Allowed or Unallowed Repeat Finding-See Finding 2022-004 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. Action Taken: Effective June 30, 2024, the City implemented procedures to ensure funds are not drawn down until all required documentation is provided to the Grants Manager. By June 30, 2025, the City is planning to adopt additional procedures for the review of payroll-related reimbursements by the Grants Accountant and Grants Manager prior to funds being drawn.
2022-004
The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023-004 – Reporting Repeat Finding – See Finding 2022-005 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-004-Reporting Repeat Finding-See Finding 2022-005 Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. Action Taken: The Grants Accountant reconciles all required reports to the general ledger prior to submission. The Grants Manager reviews and approves the Grants Accountant's reconciliations. These procedures were implemented effective June 30, 2024.
2022-005
The City could not provide evidence that the water main replacement project totaling $3,104,970 for the year ended December 31, 2023 followed formal procurement procedures. The water main replacement contract exceeds the Uniform Guidance formal procurement methods. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. Repeat Finding: Yes Questioned costs: Unknown Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023-005 – Procurement Repeat Finding – See Finding 2022-007 US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City could not provide evidence that the water main replacement project totaling $3,104,970 for the year ended December 31, 2023 followed formal procurement procedures. The water main replacement contract exceeds the Uniform Guidance formal procurement methods. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. Repeat Finding: Yes Questioned costs: Unknown Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-005 - Procurement Repeat Finding- See Finding 2022-007 Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. Action Taken: The City does follow Uniform Guidance procurement standards. In this instance, a vendor was selected under an emergency contract basis utilizing our waiver of bids policy. The entire country was awarded ARPA funds with water and sewer lining replacement being an allowable use of these funds. Due to the fact that there are a very limited number of vendors who provide this service, and the fact that there would be a significant number of municipalities seeking this service with the influx of ARPA dollars, as well as the fact that due to supply and demand, the cost for these services were escalating rapidly, the City wanted to be one of the first to engage with a contractor in order to secure a vendor in a timely manner before we would be unable to do so since the projects are long term projects and there was a time limit on when this money would need to be spent. Therefore, we knew it would not be possible to conduct our own bid. We chose a vendor off the COSTARS contract. I have attached a copy of the ordinance where we explained to Council our concern for our securing a vendor and our need to act quickly, which is why we originally initiated the purchase from City funds, before ARPA funds were distributed, and then replaced the City funds with ARPA funds once they were received.
2022-007
The City did not have a documented risk assessment process for evaluating subrecipient’s risk of non-compliance. Additionally, as part of the monitoring process, the City did not have controls in place to obtain and review the annual audit report of the subrecipient in a timely manner with documentation of such review. Criteria: The 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 City’s assessment of risk for the subrecipient. In addition, the City does not have procedures in place to adequately review the subrecipient’s audit received. Effect: The deficiencies in subrecipient monitoring could result in the City not identifying unallowable expenses being incurred by the City’s subrecipient. 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 City 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 View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2023-006 – Subrecipient Monitoring US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City did not have a documented risk assessment process for evaluating subrecipient’s risk of non-compliance. Additionally, as part of the monitoring process, the City did not have controls in place to obtain and review the annual audit report of the subrecipient in a timely manner with documentation of such review. Criteria: The 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 City’s assessment of risk for the subrecipient. In addition, the City does not have procedures in place to adequately review the subrecipient’s audit received. Effect: The deficiencies in subrecipient monitoring could result in the City not identifying unallowable expenses being incurred by the City’s subrecipient. 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 City 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 View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-006-Subrecipient Monitoring Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the City should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies to be followed up on, if applicable. Action Taken: The City will develop and implement procedures to perform formal risk assessments of all subrecipients. The City will also implement procedures and processes to ensure that subrecipients are monitored throughout the duration of their grant cycle. Audit documents will be obtained annually and reviewed. Concerns will be noted, and formal follow-up will be conducted by the Grants team. The target implementation date is March 30, 2025.
FAC accepted this audit on May 6, 2024 — management decision was due November 6, 2024.
The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2022-003 – Special Tests and Provisions – Citizen Participation U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City failed to demonstrate compliance with citizen participation requirements at 24 CFR 91.105. Criteria: At the time of submission to HUD for its annual grant, the grantee must certify to HUD that it has met the citizen participation requirements in 24 CFR section 91.105. Cause: Procedures in place to ensure the City was in compliance with the citizen participation requirements were not adequate. Effect: HUD disapproved the City’s 2022 Annual Action Plan submission as it was determined the plan was substantially incomplete and failed to include all required elements of 24 CFR Part 91. Repeat Finding: No Questioned costs: Unknown Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. View of Responsible Official: The City agrees. See the corrective action plan.
U.S. Department of Housing and Urban Development (HUD) - CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Recommendation: We recommend the City implement internal control procedures to ensure compliance with citizen participation requirements and such documentation is maintained for annual HUD submission. Action Taken: The city has adopted all HUD regulations in order to comply with all Citizen Participation requirements (24 CFR 91.105). This has already been implemented as of January 1, 2024.
There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2022-004 – Activities Allowed or Unallowed Repeat Finding – See Finding 2021-002 U.S. Department of Housing and Urban Development (HUD) – CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: There were not adequate internal controls in place to ensure unallowable costs were not charged to the program. Our allowability sample totaling $6,781,416 yielded the following unallowable costs charged to the Community Development Block Grant/Entitlement Grants (CDBG) program: $70,370 of expenditures that the City was unable to provide supporting documentation, $29,228 of administration and planning costs in excess of the 20% limitation cap, and $257 of wages in excess of actual CDBG program hours worked. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that documentation is maintained to support such charges. Per 24 CFR 570.200(g)(2), no more than 20 percent of any grant shall be expended for planning and program administrative costs. Cause: The City’s procedures to ensure only allowable costs are charged to the CDBG program were not adequate and the City did not have appropriate controls in place to ensure documentation was maintained for all CDBG expenditures. The City also did not have adequate monitoring controls in place to make sure planning and program administrative costs charged to CDBG were not in excess of 20%. Effect: The City does not have adequate internal controls to ensure only allowable costs are charged to the CDBG program. The City was required to return $29,228 to HUD in 2023 for the planning and program administrative costs in excess of the 20% costs cap and may be liable to return additional funds to HUD. Repeat Finding: Yes Questioned costs known and likely: $112,594 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. View of Responsible Official: The City agrees. See the corrective action plan.
U.S. Department of Housing and Urban Development (HUD) - CDBG - Entitlement Grants Cluster: COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that all relevant documentation is maintained. We also recommend the City establish monitoring procedures for the planning and program administrative costs requirement. Action Taken: The city will implement policies to ensure we have not gone over the 20% administrative cap. In addition, funds will not be drawn until all required documentation has been provided to the Grants Manager. This will be completed by June 30, 2024.
2021-002
The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2022-005 - Reporting Repeat Finding – See Finding 2021-001 U.S. Department of Housing and Urban Development (HUD) – COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Condition: The City did not have adequate internal controls in place to ensure required reports are reviewed prior to submission. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to HUD. Cause: The City does not have procedures in place to ensure that SF-425 and the PR-26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: Without adequate internal controls in place, the City risks not being in compliance with HUD reporting requirements. Failure to comply with grant award requirements could jeopardize future funding. Repeat Finding: Yes Questioned Costs: Unknown Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. View of Responsible Official: The City agrees. See the corrective action plan.
U.S. Department of Housing and Urban Development (HUD) - COVID-19 - Community Development Block Grant/Entitlement Grants (ALN 14.218) Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger and that such reporting reflects actual expenditures for the specific reporting periods. Action Taken: The city will work to develop and implement internal controls related to the reporting which will be reconciled with the general ledger prior to submission. It will be prepared by the Grants Accountant and approved by the Grants Manager. This will be completed by June 30, 2024.
2021-001
Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2022-006 – Activities Allowed or Unallowed U.S. Department of Housing and Urban Development – COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Condition: Our allowability sample totaling $461,175 yielded the following unallowable costs charged to the Emergency Solutions Grants Program (ESG) program: $37,950 of 2020 expenditures that the City didn’t draw down and record on the Schedule of Expenditures of Federal Awards until the year ended December 31, 2022 and $54,565 of expenditures that should have been drawn down and charged to the City’s CDBG grant instead of ESG. Criteria: The City is required to have controls in place to ensure only actual allowable costs are charged to federal programs and that drawdowns from the HUD Integrated Disbursement and Information System (IDIS) are performed timely. Cause: The City’s procedures to ensure only allowable costs are charged to the ESG program were not adequate and the City did not have appropriate controls in place to ensure accurate and timely IDIS drawdowns. Effect: The City is not in compliance with allowable cost requirements and may be liable to return funds to HUD. Repeat Finding: No Questioned costs known and likely: $175,115 Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. View of Responsible Official: The City agrees. See the corrective action plan.
U.S. Department of Housing and Urban Development - COVID-19 - Emergency Solutions Grants Program (ALN 14.231) Recommendation: We recommend the City implement internal control procedures to ensure compliance with allowable cost requirements and that IDIS drawdowns are performed timely and accurately. Action Taken: Grant compliance administrators will review each invoice for eligibility prior to the invoice being paid. The Grants Manager will approve the eligible activities prior to the drawdown in IDIS. This will be completed by June 30, 2024.
The City could not provide evidence that the stormwater project totaling $1,783,033 for the year ended December 31, 2022 followed formal procurement procedures. The stormwater contract exceeds the Uniform Guidance formal procurement methods. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. Repeat Finding: Yes Questioned costs: Unknown Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. View of Responsible Official: The City agrees. See the corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2022-007 – Procurement US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City could not provide evidence that the stormwater project totaling $1,783,033 for the year ended December 31, 2022 followed formal procurement procedures. The stormwater contract exceeds the Uniform Guidance formal procurement methods. In addition, in accordance with the Uniform Guidance, a purchase price from the Commonwealth of Pennsylvania COSTARS cooperative purchasing program is considered to be only one competitive price proposal and it cannot replace a full procurement process. Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.327, the City is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Cause: Procedures in place to ensure that the proper procurement process is followed were not adequate. Effect: The City was not in compliance with the procurement requirements of the Uniform Guidance. Repeat Finding: Yes Questioned costs: Unknown Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. View of Responsible Official: The City agrees. See the corrective action plan.
US Department of the Treasury - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. Action Taken: The City does follow Uniform Guidance procurement standards. In this instance, a vendor was selected under an emergency contract basis utilizing our waiver of bids policy. The entire country was awarded ARPA funds with water and sewer lining replacement being an allowable use of these funds. Due to the fact that there are a very limited number of vendors who provide this service, and the fact that there would be a significant number of municipalities seeking this service with the influx of ARPA dollars, as well as the fact that due to supply and demand, the cost for these services were escalating rapidly, the City wanted to be one of the first to engage with a contractor in order to secure a vendor in a timely manner before we would be unable to do so since the projects are long term projects and there was a time limit on when this money would need to be spent. Therefore, we knew it would not be possible to conduct our own bid. We choose a vendor off the COSTARS contract. I have attached a copy of the ordinance where we explained to Council our concern for our securing a vendor and our need to act quickly, which is why we originally initiated the purchase from City funds, before ARPA funds were distributed, and then replaced the City funds with ARPA funds once they were received.
2018-004
FAC accepted this audit on January 5, 2023 — management decision was due July 5, 2023.
The City did not accurately report amounts on the Form SF-425 for the year ended December 31, 2021. The City did not provide a reconciliation to the general ledger for the C04PR26 ? CDBG Financial Summary for the year. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to U.S. Department of Housing and Urban Development. Cause: The City does not have procedures in place to ensure that SF-425 and the C04PR26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: The City did not accurately report amounts on the SF-425 and the C04PR26 for the year ended December 31, 2021. Questioned Costs: This finding does not result in questioned costs. Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger. Management?s Response: The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements.
Show full finding ▾Hide full finding ▴Finding 2021-001 Reporting Repeat Finding ? See Finding 2020-001 U.S. Department of Housing and Urban Development ? Community Development Block Grants/Entitlement Grants (Assistance Listing #14.218). Condition: The City did not accurately report amounts on the Form SF-425 for the year ended December 31, 2021. The City did not provide a reconciliation to the general ledger for the C04PR26 ? CDBG Financial Summary for the year. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to U.S. Department of Housing and Urban Development. Cause: The City does not have procedures in place to ensure that SF-425 and the C04PR26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: The City did not accurately report amounts on the SF-425 and the C04PR26 for the year ended December 31, 2021. Questioned Costs: This finding does not result in questioned costs. Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger. Management?s Response: The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements.
US Department of Housing and Urban Development - Community Development Block Grants/Entitlement Grants (Assistance Listing #14.128) Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the General Ledger. Corrective Action: The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements. Finance Director Seth O'Neill will be responsible for resolving this finding by December 31, 2023.
2020-001
The City did not accurately charge payroll costs for personnel charged to the grant. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to U.S. Department of Housing and Urban Development. Cause: The City does not have procedures in place to ensure that amounts charged to the program are accurate. Effect: The City did not accurately charge payroll costs for the year ended December 31, 2021. Questioned Costs: $166 Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger. Management?s Response: The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements.
Show full finding ▾Hide full finding ▴Finding 2021-001 Activities Allowed or Unallowed U.S. Department of Housing and Urban Development ? Community Development Block Grants/Entitlement Grants (Assistance Listing #14.218). Condition: The City did not accurately charge payroll costs for personnel charged to the grant. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to U.S. Department of Housing and Urban Development. Cause: The City does not have procedures in place to ensure that amounts charged to the program are accurate. Effect: The City did not accurately charge payroll costs for the year ended December 31, 2021. Questioned Costs: $166 Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger. Management?s Response: The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements.
US Department of Housing and Urban Development - Community Development Block Grant/Entitlement Grants (Assistance Listing #14.218) Recommendation - We recommend that the City implement procedures to ensure that all required provisions are included in contracts and contract policies. Corrective Action - The City will amend contract language moving forward to include all necessary requirements. Finance Director Seth O'Neill will be responsible for resolving this finding by December 31, 2023.
FAC accepted this audit on January 19, 2022 — management decision was due July 19, 2022.
The City did not accurately report amounts on the Form SF-425 for the year ended December 31, 2020. The City did not provide a reconciliation to the general ledger for the C04PR26 ? CDBG Financial Summary for the year. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to U.S. Department of Housing and Urban Development. Cause: The City does not have procedures in place to ensure that SF-425 and the C04PR26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: The City did not accurately report amounts on the SF-425 and the C04PR26 for the year ended December 31, 2020. Questioned Costs: This finding does not result in questioned costs. Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger. Management?s Response: The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements.
Show full finding ▾Hide full finding ▴U.S. Department of Housing and Urban Development ? Community Development Block Grants/Entitlement Grants (Assistance Listing #14.218). Condition: The City did not accurately report amounts on the Form SF-425 for the year ended December 31, 2020. The City did not provide a reconciliation to the general ledger for the C04PR26 ? CDBG Financial Summary for the year. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to U.S. Department of Housing and Urban Development. Cause: The City does not have procedures in place to ensure that SF-425 and the C04PR26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: The City did not accurately report amounts on the SF-425 and the C04PR26 for the year ended December 31, 2020. Questioned Costs: This finding does not result in questioned costs. Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger. Management?s Response: The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements.
The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements. Responsible individual: Seth O'Neill, Finance Director, Corrective Action Planned by December 31, 2021 year-end.
2019-002
FAC accepted this audit on August 31, 2020 — management decision was due March 3, 2021.
The City did not properly account for program income in their general ledger. Criteria: Pursuant to 24 CFR the grantee must accurately account for any program income generated from the use of CDBG funds. Cause: There were not adequate procedures in place to ensure that program income was recorded accurately. Effect: The City is not in compliance with program income requirements. Questioned Costs: This finding does not result in questioned costs. Recommendation: We recommend that the City implement procedures to periodically evaluate the accurate recording of program income in the general ledger. Management?s Response: The City will take this recommendation and establish protocols to ensure program income is properly recorded. These protocols will include reconciling the general ledger to PR 26 reports submitted to the Department of Housing and Urban Development.
Show full finding ▾Hide full finding ▴U.S. Department of Housing and Urban Development ? Community Development Block Grants/Entitlement Grants (CFDA #14.218). Condition: The City did not properly account for program income in their general ledger. Criteria: Pursuant to 24 CFR the grantee must accurately account for any program income generated from the use of CDBG funds. Cause: There were not adequate procedures in place to ensure that program income was recorded accurately. Effect: The City is not in compliance with program income requirements. Questioned Costs: This finding does not result in questioned costs. Recommendation: We recommend that the City implement procedures to periodically evaluate the accurate recording of program income in the general ledger. Management?s Response: The City will take this recommendation and establish protocols to ensure program income is properly recorded. These protocols will include reconciling the general ledger to PR 26 reports submitted to the Department of Housing and Urban Development.
The City will take this recommendation and establish protocols to ensure program income is properly recorded. These protocols will include reconciling the general ledger to PR 26reports submitted to Department of Housing and Urban Development. Responsible Individual: Luisa Follweiler, Treasury and Accounting Manager, Corrective Action Planned by December 31, 2020 year-end.
2018-002
The City did not accurately report amounts on the Form SF-425 for the year ended December 31, 2019. The City did not provide a reconciliation to the general ledger for the C04PR26 ? CDBG Financial Summary for the year. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to U.S. Department of Housing and Urban Development. Cause: The City does not have procedures in place to ensure that SF-425 and the C04PR26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: The City did not accurately report amounts on the SF-425 and the C04PR26 for the year ended December 31, 2019. Questioned Costs: This finding does not result in questioned costs. Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger. Management?s Response: The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements.
Show full finding ▾Hide full finding ▴U.S. Department of Housing and Urban Development ? Community Development Block Grants/Entitlement Grants (CFDA #14.218). Condition: The City did not accurately report amounts on the Form SF-425 for the year ended December 31, 2019. The City did not provide a reconciliation to the general ledger for the C04PR26 ? CDBG Financial Summary for the year. Criteria: Pursuant to 24 CFR the grantee must accurately report amounts to U.S. Department of Housing and Urban Development. Cause: The City does not have procedures in place to ensure that SF-425 and the C04PR26 reconcile to the general ledger in accordance with federal reporting requirements. Effect: The City did not accurately report amounts on the SF-425 and the C04PR26 for the year ended December 31, 2019. Questioned Costs: This finding does not result in questioned costs. Recommendation: We recommend that the City implement procedures to ensure that all required reports are reconciled to the general ledger. Management?s Response: The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements.
The City will take this recommendation and review current procedures and implement revised procedures based on the reporting requirements. Responsible Individual: Luisa Follweiler, Treasury and Accounting Manager, Corrective Action Planned by December 31, 2020 year-end.
2018-003
FAC accepted this audit on September 17, 2019 — management decision was due March 17, 2020.
GSA_MIGRATION
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GSA_MIGRATION
2017-002
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2017-003
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GSA_MIGRATION
FAC accepted this audit on August 9, 2018 — management decision was due February 9, 2019.
GSA_MIGRATION
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2016-001
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2016-002
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GSA_MIGRATION
FAC accepted this audit on August 15, 2017 — management decision was due February 15, 2018.
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2015-003
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2015-004
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2015-005
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