EIN: 237423599
UEI: PJ9FF6GKA4X9
Audited by: BARBACANE, THORNTON & COMPANY LLP
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 18, 2026. 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 December 18, 2026 (110 days from today).
What is a management decision? →FAC accepted this audit on August 29, 2024 — management decision was due March 1, 2025.
2023-001: Significant Deficiency – Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Federal Program: Adult Education - Basic Grants to States ALN: 84.002A Award Period: 07/01/2022 - 06/30/2023 Type of Finding: Significant Deficiency The Council did not implement an established and accurate cost allocation plan during the fiscal year ending June 30, 2023. Therefore, not all costs were shared among different grants consistently and accurately. Criteria: Under the U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, PART 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart E – Cost Principles Sec. 200.405 Allocable Costs – the cost must be allocated to the grants/projects based on the proportional benefit. If a cost benefits two or more grants/projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on a reasonable documented basis. Condition & Context: During the prior year audit as well as during a monitoring visit by PDE, it was discovered that certain expenses were allocated to grants on an unsupported basis. Based on our testing of expenditures performed for the current year, an accurate cost allocation plan was not accurately developed or implemented during the fiscal year ending June 30, 2023. Cause: The Council did not create or implement an accurate cost allocation plan during the current or prior fiscal year. Effect: The Council is not in compliance with 2 CFR Sec. 200.405 – Allocable Costs. Repeat Finding: Yes Recommendation: We recommend that the Council work to develop and implement a written allocation plan including calculations for all direct and indirect costs that benefit two or more grants or programs. Specifically, the Council should review actual expenses on an ongoing basis and make any necessary adjustments to the allocated expenses.
Show full finding ▾Hide full finding ▴2023-001: Significant Deficiency – Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Federal Program: Adult Education - Basic Grants to States ALN: 84.002A Award Period: 07/01/2022 - 06/30/2023 Type of Finding: Significant Deficiency The Council did not implement an established and accurate cost allocation plan during the fiscal year ending June 30, 2023. Therefore, not all costs were shared among different grants consistently and accurately. Criteria: Under the U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, PART 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart E – Cost Principles Sec. 200.405 Allocable Costs – the cost must be allocated to the grants/projects based on the proportional benefit. If a cost benefits two or more grants/projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on a reasonable documented basis. Condition & Context: During the prior year audit as well as during a monitoring visit by PDE, it was discovered that certain expenses were allocated to grants on an unsupported basis. Based on our testing of expenditures performed for the current year, an accurate cost allocation plan was not accurately developed or implemented during the fiscal year ending June 30, 2023. Cause: The Council did not create or implement an accurate cost allocation plan during the current or prior fiscal year. Effect: The Council is not in compliance with 2 CFR Sec. 200.405 – Allocable Costs. Repeat Finding: Yes Recommendation: We recommend that the Council work to develop and implement a written allocation plan including calculations for all direct and indirect costs that benefit two or more grants or programs. Specifically, the Council should review actual expenses on an ongoing basis and make any necessary adjustments to the allocated expenses.
The Council has implemented and followed a cost allocation plan to share costs among different grants consistently. The Council has instituted a timekeeping and reporting system that properly allocates the cost of salaries and benefits to programs and grants. Data gathered from this system includes the ratio of hours worked in each program to hours worked overall which is used to allocate other expenditures that are attributable to more than one program or grant. The Council will be within compliance of U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, Part 200 – Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E – Cost Principles Sec. 200.405 Allocable Costs.
2022-001
FAC accepted this audit on April 11, 2024 — management decision was due October 11, 2024.
During our prior year audit as well as during a monitoring visit by PDE, it was discovered that certain expenses were allocated to grants on an unsupported basis. Based on testing of expenditures performed for current year an accurate cost allocation plan was not accurately developed or implemented during the fiscal year ended June 30, 2022. Questioned Costs: None Cause: The Organization did not create or implement an accurate cost allocation plan during the current or prior or fiscal year. Effect: DCLC is not in compliance with 2 CFR Sec. 200.405 - Allocable Costs. Recommendation: We recommend that DCLC work to develop and implement a written allocation plan including calculations for all direct and indirect costs that benefit two or more grants or programs. Specifically, DCLC should review actual expenses on an ongoing basis and make any necessary adjustments to the allocated expenses.
Show full finding ▾Hide full finding ▴Finding 2022-001: Significant Deficiency – Allowable Costs/Cost Principles Repeat Finding: 2021-001 Organization did not implement an established and accurate cost allocation plan during the fiscal year ending June 30, 2022. Therefore, not all costs were shared among different grants consistently and accurately. Criteria: Under the U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, PART 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart E - Cost Principles Sec. 200.405 Allocable Costs - the cost must be allocated to the grants/projects based on the proportional benefit. If a cost benefits two or more grants/projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on a reasonable documented basis. Condition: During our prior year audit as well as during a monitoring visit by PDE, it was discovered that certain expenses were allocated to grants on an unsupported basis. Based on testing of expenditures performed for current year an accurate cost allocation plan was not accurately developed or implemented during the fiscal year ended June 30, 2022. Questioned Costs: None Cause: The Organization did not create or implement an accurate cost allocation plan during the current or prior or fiscal year. Effect: DCLC is not in compliance with 2 CFR Sec. 200.405 - Allocable Costs. Recommendation: We recommend that DCLC work to develop and implement a written allocation plan including calculations for all direct and indirect costs that benefit two or more grants or programs. Specifically, DCLC should review actual expenses on an ongoing basis and make any necessary adjustments to the allocated expenses.
CORRECTIVE ACTION PLAN 2021‐2022‐ Finding 1: Significant Deficiency – Allowable Costs/Cost Principles Management’s Response: Delaware County Literacy Council has implemented and followed a cost allocation plan to share costs among different grants consistently. DCLC has instituted a timekeeping and reporting system that properly allocates the cost of salaries and benefits to programs and grants. Data gathered from this system includes the ratio of hours worked in each program to hours worked overall which is used to allocate other expenditures that are attributable to more than one program or grant. DCLC will be within compliance of U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, Part 200 – Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E – Cost Principles Sec. 200.405 Allocable Costs Completion Date: April 8, 2024 Name(s) of Person(s) Responsible: Colleen Duran, Executive Director
2021-001
FAC accepted this audit on October 3, 2022 — management decision was due April 3, 2023.
During our prior year audit as well as during a monitoring visit by PDE, it was discovered that certain expenses were allocated to grants on an unsupported basis. Based on testing performed for current year expenditures, the new cost allocation plan was not fully implemented prior to fiscal year end June 30, 2021. Questioned Costs: None Cause: Certain expenses were inconsistently allocated to several grants, with no documented basis for the allocation early during fiscal year prior to implementation of new cost allocation plan. Delaware County Literacy Council was unable to fully implement new cost allocation plan until after the year end. Effect: DCLC is not in compliance with 2 CFR Sec. 200.405 - Allocable Costs. Recommendation: We recommend that DCLC work to implement the prepared written supported allocation calculations for all direct and indirect costs that benefit two or more grants or programs. Specifically, DCLC should review actual expenses and make any necessary adjustments to the allocated expenses.
Show full finding ▾Hide full finding ▴Significant Deficiency ? Allowable Costs/Cost Principles Repeat Finding: 2020-001 Organization did not fully implement the established cost allocation plan during the fiscal year ending June 30, 2021. Therefore, not all costs were shared among different grants consistently. Criteria: Under the U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, PART 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart E - Cost Principles Sec. 200.405 Allocable Costs - the cost must be allocated to the grants/projects based on the proportional benefit. If a cost benefits two or more grants/projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on a reasonable documented basis. Condition: During our prior year audit as well as during a monitoring visit by PDE, it was discovered that certain expenses were allocated to grants on an unsupported basis. Based on testing performed for current year expenditures, the new cost allocation plan was not fully implemented prior to fiscal year end June 30, 2021. Questioned Costs: None Cause: Certain expenses were inconsistently allocated to several grants, with no documented basis for the allocation early during fiscal year prior to implementation of new cost allocation plan. Delaware County Literacy Council was unable to fully implement new cost allocation plan until after the year end. Effect: DCLC is not in compliance with 2 CFR Sec. 200.405 - Allocable Costs. Recommendation: We recommend that DCLC work to implement the prepared written supported allocation calculations for all direct and indirect costs that benefit two or more grants or programs. Specifically, DCLC should review actual expenses and make any necessary adjustments to the allocated expenses.
August 2022 CORRECTIVE ACTION PLAN 2020-2021 ? Finding 1: Significant Deficiency ? Allowable Costs/Cost Principles Management?s Response: Despite a transitional change in organizational leadership in early FY2020, and the challenges of COVID-19, DCLC instituted a process to allocate costs based on a time study. The allocable costs include salaries and benefits. We will be within compliance of U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, PART 200 - Uniform Administrative Requirements, Cost. Principles, and Audit Requirements for Federal Awards, Subpart E - Cost Principles Sec. 200.405 Allocable Costs Completion Date: September 2021. Name(s) of Person(s) Responsible: Patrick Gunnin
2020-001
Our testing of matching found one local matching cost reported on the Final Expenditure Report was not included on the original budget submitted to and approved by the Pennsylvania Department of Education. Questioned Costs: None Cause: Because of restrictions resulting from COVID-19, local matching amounts submitted on the approved budget were not reached. The final grant expenditure report submitted to Pennsylvania Department of Education included one local matching amount for a cost not included on the approved budget. Effect: DCLC is not in compliance with 2 CFR Sec. 200.306 ? Cost Sharing or Matching. Recommendation: We recommend that DCLC only include local match amounts that were included in the approved budget. DCLC should monitor Local Match during the grant year and request approval from Pennsylvania Department of Education, for changes to budgeted local match line items and amounts.
Show full finding ▾Hide full finding ▴Significant Deficiency - Matching Organization included a Local Match amount in Final Expenditure Report that was not included in the approved budget. Criteria: Under the U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, PART 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements Sec. 200.306 Cost Sharing or Matching ? Acceptable costs and contributions for matching are provided for in the approved budget. Condition: Our testing of matching found one local matching cost reported on the Final Expenditure Report was not included on the original budget submitted to and approved by the Pennsylvania Department of Education. Questioned Costs: None Cause: Because of restrictions resulting from COVID-19, local matching amounts submitted on the approved budget were not reached. The final grant expenditure report submitted to Pennsylvania Department of Education included one local matching amount for a cost not included on the approved budget. Effect: DCLC is not in compliance with 2 CFR Sec. 200.306 ? Cost Sharing or Matching. Recommendation: We recommend that DCLC only include local match amounts that were included in the approved budget. DCLC should monitor Local Match during the grant year and request approval from Pennsylvania Department of Education, for changes to budgeted local match line items and amounts.
2020-2021 ? Finding 2: Organization included a Local Match account in Final Expenditure Report that was not included in the approved budget. Management?s Response: Going forward, in order to meet U.S. code of Federal Regulations (CFR), Title 2: Grants and Agreements, PART 200 ? Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements Sec. 200.306 Cost Sharing or Matching ? management will seek approval from funder to modify Local Match budgets prior to submitting expenditures for submission in Final Expenditure Reports in all Federal grants. Expenses will align with Pennsylvania Department of Education guidelines. Completion Date: August 2022 Name(s) of Person(s) Responsible: Patrick Gunnin
FAC accepted this audit on March 24, 2021 — management decision was due September 24, 2021.
During our prior year audit as well as during a monitoring visit by PDE, it was discovered that certain expenses were allocated to grants on an undocumented basis. Based on testing performed for current year expenditures, the new cost allocation plan was not fully implemented prior to fiscal year end June 30, 2020. Questioned Costs: None Cause: Certain expenses were evenly allocated to several grants, with no documented basis for the allocation early during fiscal year prior to implementation of new cost allocation plan. Delaware County Literacy Council was unable to fully implement new cost allocation plan by end of fiscal year. Effect: DCLC is not in compliance with 2 CFR Sec. 200.405 - Allocable Costs. Recommendation: We recommend that DCLC work to implement the prepared written supported allocation calculations for all direct and indirect costs that benefit two or more grants or programs. Specifically, DCLC should review expenses prior to full implementation of cost allocation plan and make any necessary adjustments.
Show full finding ▾Hide full finding ▴Finding 2020-001: Organization did not fully implement the established cost allocation plan during the fiscal year ending June 30, 2020. Therefore, not all costs were shared among different grants consistently. Criteria: Under the U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, PART 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart E - Cost Principles Sec. 200.405 Allocable Costs - the cost must be allocated to the grants/projects based on the proportional benefit. If a cost benefits two or more grants/projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on a reasonable documented basis. Condition: During our prior year audit as well as during a monitoring visit by PDE, it was discovered that certain expenses were allocated to grants on an undocumented basis. Based on testing performed for current year expenditures, the new cost allocation plan was not fully implemented prior to fiscal year end June 30, 2020. Questioned Costs: None Cause: Certain expenses were evenly allocated to several grants, with no documented basis for the allocation early during fiscal year prior to implementation of new cost allocation plan. Delaware County Literacy Council was unable to fully implement new cost allocation plan by end of fiscal year. Effect: DCLC is not in compliance with 2 CFR Sec. 200.405 - Allocable Costs. Recommendation: We recommend that DCLC work to implement the prepared written supported allocation calculations for all direct and indirect costs that benefit two or more grants or programs. Specifically, DCLC should review expenses prior to full implementation of cost allocation plan and make any necessary adjustments.
Management has a process to review costs charged to awards to ensure that they are appropriate, reasonable and allocable. However, as noted, there was no formal approved policy and procedure to consistently allocable costs that supported multiple awards until midway through fiscal year 2020. Challenges with remote work due to COVID-19 delayed full implementation and consistent documentation was not maintained. Management has taken action to ensure the policy and procedures are communicated to all responsible employees and that allocations of all direct and indirect costs that impact two or more grants or programs are fully documented accordingly.
2019-002
FAC accepted this audit on August 12, 2020 — management decision was due February 12, 2021.
During a monitoring visit by the PDE, it was discovered that additional computers had been purchased and charged to the IELCE and Adult Basic Education Direct Service grants without permission. Our audit findings concur with this finding. Questioned Costs: $7,448.58 of unapproved computer costs. Cause: Budget revisions were not prepared because the Executive Director did not think the moving of funds between Object and Function codes would amount to greater than 10%. Effect: The unapproved additional computer costs in the amount of $7,448.58 were disallowed by the PDE. This amount was returned to PDE. Recommendation: We recommend that the Executive Director develop a system of monitoring actual grant expenses to budgeted expenses on a frequent interim basis. We recommend that a budget change form be developed and used to request approval for budget revisions. Management Response: See Management Response.
Show full finding ▾Hide full finding ▴Federal Program: Adult Education ? Basic Grants to States Federal Agency: U.S. Department of Education Pass-Through Entity: Pennsylvania Department of Education CFDA Number: 84.002 Finding 2019-001: Unapproved computer costs charged to grants Criteria: Delaware County Literacy Council (DCLC) has grants from the Division of Adult Education of the Pennsylvania Department of Education (PDE). Under the PDE's Adult Education and Family Literacy Guidelines Program Year 2018-19, when a recipient anticipates moving greater than 10 percent of the approved budget between Object Codes or Function Codes, they are required to submit a budget revision. Requests for budget revisions must be submitted and approved by PDE prior to implementation. DCLC moved costs between codes and charged unapproved computer costs to contracts. Condition: During a monitoring visit by the PDE, it was discovered that additional computers had been purchased and charged to the IELCE and Adult Basic Education Direct Service grants without permission. Our audit findings concur with this finding. Questioned Costs: $7,448.58 of unapproved computer costs. Cause: Budget revisions were not prepared because the Executive Director did not think the moving of funds between Object and Function codes would amount to greater than 10%. Effect: The unapproved additional computer costs in the amount of $7,448.58 were disallowed by the PDE. This amount was returned to PDE. Recommendation: We recommend that the Executive Director develop a system of monitoring actual grant expenses to budgeted expenses on a frequent interim basis. We recommend that a budget change form be developed and used to request approval for budget revisions. Management Response: See Management Response.
Corrective Action Plan Summary In response to the monitoring visit and subsequent issuance of findings by the Pennsylvania Department of Education (PDE), DCLC has created a Corrective Action Plan to address those findings. This Corrective Action Plan was approved by the Pennsylvania Department of Education, has been implemented by DCLC staff, and is expected to be completed by June 30, 2020. Finding 1 With the new programming for this fiscal year DCLC estimates related to equipment needs required adjustment and we did not have a process to ensure formal approval to reallocate budgeted funds in excess of 10% was obtained prior to making the related purchases, resulting in the 2% spend in excess of allowed threshold. The funds have been repaid and a new policy has been created to ensure the Executive director obtains approval in advance of any necessary reallocations of budgeted funds. Additionally, the Executive Director and Board of Directors continue to review monthly financial performance and projections to identify the need for a budget reallocation in a timely manner. This corrective action plan has been implemented.
During our audit, as well as during a monitoring visit by PDE, it was discovered that certain expenses were allocated to grants on an undocumented basis. Our finding concurs with the finding of the PDE's monitoring visit. Questioned Costs: None Cause: Certain expenses were evenly allocated to several grants, with no documented basis for the allocation. Effect: DCLC is not in compliance with 2 CFR Sec. 200.405 - Allocable Costs. Recommendation: We recommend that DCLC prepare written supported allocation calculations for all direct and indirect costs that benefit two or more grants or programs. Management Response: See Management Response.
Show full finding ▾Hide full finding ▴Federal Program: Adult Education ? Basic Grants to States Federal Agency: U.S. Department of Education Pass-Through Entity: Pennsylvania Department of Education CFDA Number: 84.002 Finding 2019-002: Organization does not have a specific allocation basis for certain costs shared among different grants. Criteria: Under the U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, PART 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart E - Cost Principles Sec. 200.405 Allocable Costs - the cost must be allocated to the grants/projects based on the proportional benefit. If a cost benefits two or more grants/projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, the costs may be allocated or transferred to benefitted projects on a reasonable documented basis. Condition: During our audit, as well as during a monitoring visit by PDE, it was discovered that certain expenses were allocated to grants on an undocumented basis. Our finding concurs with the finding of the PDE's monitoring visit. Questioned Costs: None Cause: Certain expenses were evenly allocated to several grants, with no documented basis for the allocation. Effect: DCLC is not in compliance with 2 CFR Sec. 200.405 - Allocable Costs. Recommendation: We recommend that DCLC prepare written supported allocation calculations for all direct and indirect costs that benefit two or more grants or programs. Management Response: See Management Response.
Corrective Action Plan Summary In response to the monitoring visit and subsequent issuance of findings by the Pennsylvania Department of Education (PDE), DCLC has created a Corrective Action Plan to address those findings. This Corrective Action Plan was approved by the Pennsylvania Department of Education, has been implemented by DCLC staff, and is expected to be completed by June 30, 2020. Finding 2 With the increased programming received in this fiscal year a formalized cost allocation policy was necessary to document the methodology being used where costs were incurred in support of multiple programs. Although a process was being followed under the supervision of the Executive Director, it was not documented. DCLC has adopted a formal cost allocation policy that has been approved by the Board of Directors. The Executive Director will ensure continued adherence to the policy through the monthly review of financial performance. This action is complete.
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