COUNTY OF COLUMBIA, PENNSYLVANIALocal Government

2024-002 - (Noncompliance) Uniform Guidance Written Policies/Procedures Federal Program: Assistance Listing #14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000073444, C000075689, C000082264, C000086078, C000089804, C000080637 and PEMA-2022-007 Prior Year Finding Number: 2023-003 Criteria: The Uniform Guidance requires written policies and/or procedures in the areas of allowability of costs, cash management and subrecipient monitoring. Condition/Context: While the County 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 or subrecipient monitoring as required under the Uniform Guidance. Questioned Costs: N/A Cause: The County has not yet prepared its written policies/procedures required by the Uniform Guidance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance and as such, employees do not currently have the benefit of these written policies and/or procedures to assist in managing and directing its federal award programs. Recommendation: We recommend that County management prepare the required written policies/procedures related to allowability of costs, cash management and subrecipient monitoring outlined with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to formally document the required elements of its policies and procedures pursuant to the Uniform Guidance.

2024-003 - (Noncompliance) Completion of Single Audit Federal Program: Assistance Listing #14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000073444, C000075689, C000082264, C000086078, C000089804, C000080637 and PEMA-2022-007 Prior Year Finding Number: 2023-004 Criteria: Pursuant to the provisions of the Uniform Guidance, section 200.512(a), the County is required to undergo and complete its Single Audit and file the Single Audit and related Data Collection Form within 9 months of its year-end. Condition/Context: The County's December 31, 2023 Single Audit was not completed and submitted within the required time period. Questioned Costs: N/A Cause: During the period when the audit was being conducted, the County was in the process of converting its accounting system to a new product, which delayed the completion of the County's Single Audit as certain information was not readily available as anticipated in the audit schedule. Effect: The County is not in compliance with the Uniform Guidance Single Audit reporting requirements. Recommendation: We recommend that as the County gets up and running on the new accounting system, the audit be prioritized in future periods. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to better anticipate the needs and timing and availability of staff/information to complete the audit.

2024-004 - Subrecipient Monitoring - Material Weakness/Noncompliance Federal Program: Assistance Listing #14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000073444, C000075689, C000082264, C000086078, C000089804, C000080637 and PEMA-2022-007 Prior Year Finding Number: 2023-005 Criteria: The Uniform Guidance outlines various requirements for pass-through entities in Section 200.331, including the following items: (a) ensuring all subawards are clearly identify to the subrecipient as a subaward and include certain required information; (b) evaluate each subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring; (c) consider imposing specific subaward conditions upon a subrecipient, if appropriate; (d) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations and the terms and conditions of the subaward; (e) depending on the pass-through entity's assessment of risk posed by the subrecipient, perform appropriate monitoring of the subrecipient; (f) verify that every subrecipient is audited as required by Subpart F of the Uniform Guidance; (g) consider whether the results of the subrecipient's audits, on-site reviews or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records and; (h) consider taking enforcement actions against noncompliance subrecipients as described in Uniform Guidance Section 200.338. Condition/Context: The County 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/County audit reports. Questioned Costs: N/A Cause: The County has not prepared or adopted the written policies / procedures required by Uniform Guidance and as such, the County personnel overseeing subrecipients did not understand their responsibilities in regards to monitoring subrecipients. Effect: The County cannot be assured that subrecipients are appropriately understanding and complying with the requirements of the funding stream passed through to them. Recommendation: We recommend that the County revisit its policies and procedures related to subrecipient monitoring and ensure that there are formal subaward agreements with all subrecipients, prepare a formal, initial, risk assessment of each potential subrecipient and document its monitoring activities of each subrecipient. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to implement these policies, procedures and activities on a prospective basis.

2023-003 - (Noncompliance) Uniform Guidance Written Policies/Procedures Federal Program: Assistance Listing #14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000073444, C000075689, C000082264, C000086078 and PEMA-2022-007 Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Assistance Listing #93.658, Foster Care - Title IV-E, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: 2022-003 Criteria: The Uniform Guidance requires written policies and/or procedures in the areas of allowability of costs, cash management and subrecipient monitoring. Condition/Context: While the County 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 or subrecipient monitoring as required under the Uniform Guidance. Questioned Costs: N/A Cause: The County has not yet prepared its written policies/procedures required by the Uniform Guidance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance and as such, employees do not currently have the benefit of these written policies and/or procedures to assist in managing and directing its federal award programs. Recommendation: We recommend that County management prepare the required written policies/procedures related to allowability of costs, cash management and subrecipient monitoring outlined with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to formally document the required elements of its policies and procedures pursuant to the Uniform Guidance.

2023-004 - (Noncompliance) Completion of Single Audit Federal Program: Assistance Listing #14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000073444, C000075689, C000082264, C000086078 and PEMA-2022-007 Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Assistance Listing #93.658, Foster Care - Title IV-E, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: 2022-004 Criteria: Pursuant to the provisions of the Uniform Guidance, section 200.512(a), the County is required to undergo and complete its Single Audit and file the Single Audit and related Data Collection Form within 9 months of its year-end. Condition/Context: The County's December 31, 2022 Single Audit was not completed and submitted within the required time period. Questioned Costs: N/A Cause: During the period when the audit was being conducted, the County was in the process of converting its accounting system to a new product, which delayed the completion of the County's Single Audit as certain information was not readily available as anticipated in the audit schedule. Effect: The County is not in compliance with the Uniform Guidance Single Audit reporting requirements. Recommendation: We recommend that as the County gets up and running on the new accounting system, the audit be prioritized in future periods. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to better anticipate the needs and timing and availability of staff/information to complete the audit.

2023-005 - Subrecipient Monitoring - Material Weakness/Noncompliance Federal Program: Assistance Listing #14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000073444, C000075689, C000082264, C000086078 and PEMA-2022-007 Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: 2022-005 Criteria: The Uniform Guidance outlines various requirements for pass-through entities in Section 200.331, including the following items: (a) ensuring all subawards are clearly identify to the subrecipient as a subaward and include certain required information; (b) evaluate each subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring; (c) consider imposing specific subaward conditions upon a subrecipient, if appropriate; (d) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations and the terms and conditions of the subaward; (e) depending on the pass-through entity's assessment of risk posed by the subrecipient, perform appropriate monitoring of the subrecipient; (f) verify that every subrecipient is audited as required by Subpart F of the Uniform Guidance; (g) consider whether the results of the subrecipient's audits, on-site reviews or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records and; (h) consider taking enforcement actions against noncompliance subrecipients as described in Uniform Guidance Section 200.338. Condition/Context: The County 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/County audit reports. Questioned Costs: N/A Cause: The County has not prepared or adopted the written policies / procedures required by Uniform Guidance and as such, the County personnel overseeing subrecipients did not understand their responsibilities in regards to monitoring subrecipients. Effect: The County cannot be assured that subrecipients are appropriately understanding and complying with the requirements of the funding stream passed through to them. Recommendation: We recommend that the County revisit its policies and procedures related to subrecipient monitoring and ensure that there are formal subaward agreements with all subrecipients, prepare a formal, initial, risk assessment of each potential subrecipient and document its monitoring activities of each subrecipient. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to implement these policies, procedures and activities on a prospective basis.

2023-006 - Reporting - Significant Deficiency/Noncompliance Federal Program: Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: 2022-006 Criteria: The Coronavirus State and Local Fiscal Recovery Final Rule (the Final Rule) and Title 2, Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, require that as a condition of receiving federal awards, nonfederal entities agree to maintain internal control processes to provide reasonable assurance of compliance with the requirements. The Final Rule requires periodic reporting at the end of each calendar quarter with a reporting due date 1 month after the end of the calendar quarter. Condition/Context: The County's required reports for the quarters ended June 30, 2023, September 30, 2023 and December 31, 2023, were due to be filed by the end of the month after the report end date (July 31, 2023, October 31, 2023 and January 31, 2024, respectively). The County filed its report on August 23, 2023, November 17, 2023 and February 15, 2024 (23, 17 and 15 days, respectively), after the required due date. Questioned Costs: N/A Cause: The County's reporting process did not include the specificity necessary to ensure that the reporting due dates were flagged and followed. Effect: The County did not comply with its reporting requirements, which may impact future awards. Recommendation: We recommend that the County revisit its policies and procedures related to reporting to ensure future reports are completed and submitted within the appropriate time period. Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted timely.

Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000071546, C000073444, C000075689, C000075284, C000080637, and PEMA-2022-007 Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Assistance Listing #93.658, Foster Care - Title IV-E, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: 2021-003 Criteria: The Uniform Guidance requires written policies and/or procedures in the areas of allowability of costs, cash management and subrecipient monitoring. Condition/Context: While the County 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 or subrecipient monitoring as required under the Uniform Guidance. Questioned Costs: N/A Cause: The County has not yet prepared its written policies/procedures required by the Uniform Guidance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance and as such, employees do not currently have the benefit of these written policies and/or procedures to assist in managing and directing its federal award programs. Recommendation: We recommend that County management prepare the require written policies/procedures related to allowability of costs, cash management and subrecipient monitoring outlined with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to formally document the required elements of its policies and procedures pursuant to the Uniform Guidance.

Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000071546, C000073444, C000075689, C000075284, C000080637, and PEMA-2022-007 Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Assistance Listing #93.658, Foster Care - Title IV-E, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: 2021-004 Criteria: Pursuant to the provisions of the Uniform Guidance, section 200.512(a), the County is required to undergo and complete its Single Audit and file the Single Audit and related Data Collection Form within 9 months of its year-end. Condition/Context: The County’s December 31, 2022 Single Audit was not completed and submitted within the required time period. Questioned Costs: N/A Cause: During the period when the audit was being conducted, the County was in the process of converting its accounting system to a new product, which delayed the completion of the County’s Single Audit as certain information was not readily available as anticipated in the audit schedule. Effect: The County is not in compliance with the Uniform Guidance Single Audit reporting requirements. Recommendation: We recommend that as the County gets up and running on the new accounting system, the audit be prioritized in future periods. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to better anticipate the needs and timing and availability of staff/information to complete the audit.

Federal Program: Assistance Listing #14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development and Pennsylvania Emergency Management Agency, Pass-Through Entity Identifying Numbers: C000071546, C000073444, C000075689, C000075284, C000080637, and PEMA-2022-007 Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: 2021-005 Criteria: The Uniform Guidance outlines various requirements for pass-through entities in Section 200.331, including the following items: (a) ensuring all subawards are clearly identify to the subrecipient as a subaward and include certain required information; (b) evaluate each subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring; (c) consider imposing specific subaward conditions upon a subrecipient, if appropriate; (d) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations and the terms and conditions of the subaward; (e) depending on the pass-through entity's assessment of risk posed by the subrecipient, perform appropriate monitoring of the subrecipient; (f) verify that every subrecipient is audited as required by Subpart F of the Uniform Guidance; (g) consider whether the results of the subrecipient's audits, on-site reviews or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records, and; (h) consider taking enforcement actions against noncompliance subrecipients as described in Uniform Guidance Section 200.338. Condition/Context: The County 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/County audit reports. Questioned Costs: N/A Cause: The County has not prepared or adopted the written policies / procedures required by Uniform Guidance and as such, the County personnel overseeing subrecipients did not understand their responsibilities in regards to monitoring subrecipients. Effect: The County cannot be assured that subrecipients are appropriately understanding and complying with the requirements of the funding stream passed through to them. Recommendation: We recommend that the County revisit its policies and procedures related to subrecipient monitoring and ensure that there are formal subaward agreements with all subrecipients, prepare a formal, initial, risk assessment of each potential subrecipient and document its monitoring activities of each subrecipient. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to implement these policies, procedures and activities on a prospective basis.

Federal Program: Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: N/A Criteria: The Coronavirus State and Local Fiscal Recovery Final Rule (the Final Rule) and Title 2, Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, require that as a condition of receiving federal awards, nonfederal entities agree to maintain internal control processes to provide reasonable assurance of compliance with the requirements. The Final Rule requires periodic reporting at the end of each calendar quarter with a reporting due date 1 month after the end of the calendar quarter. Condition/Context: The County’s required report for the quarter ended December 31, 2022 was due to be filed by January 31, 2023. The County filed its report on March 23, 2023, 48 days after the required due date. Questioned Costs: N/A Cause: The County did not file its report within the required due date. Effect: The County did not comply with its reporting requirements, which may impact future awards. Recommendation: We recommend that the County revisit its policies and procedures related to reporting to ensure future reports are completed and submitted within the appropriate time period. Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted timely.

Federal Program: Assistance Listing #14.239 HOME Investment Partnerships Program, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: C000074088 Assistance Listing #21.027, COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: 2020-004 Criteria: The Uniform Guidance requires written policies and/or procedures in the areas of allowability of costs, cash management, procurement, subrecipient monitoring and conflict of interest. Condition/Context: While the County has adequate informal policies and procedures surrounding the administration of federal programs, these policies and procedures have not been formally documented to ensure compliance with the areas of allowability of costs, cash management, procurement or subrecipient monitoring as required under the Uniform Guidance. Questioned Costs: N/A Cause: The County was still in the process of acclimating itself to the required written policies/procedures within the Uniform Guidance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance and as such, employees do not currently have the benefit of these written policies and/or procedures to assist in managing and directing its federal award programs. Recommendation: We recommend that County management prepare the require written policies/procedures related to allowability of costs, cash management, procurement, subrecipient monitoring and conflict of interest outlined with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to formally document the required elements of its policies and procedures pursuant to the Uniform Guidance.

Federal Program: Assistance Listing #14.239 HOME Investment Partnerships Program, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: C000074088 Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: N/A Criteria: Pursuant to the provisions of the Uniform Guidance, section 200.512(a), the County is required to undergo and complete its Single Audit and file the Single Audit and related Data Collection Form within 9 months of its year-end. Condition/Context: The County?s December 31, 2021 Single Audit was not completed and submitted within the required time period. Questioned Costs: N/A Cause: During the period when the audit was being conducted, the County was in the process of converting its accounting system to a new product, which delayed the completion of the County?s Single Audit as certain information was not readily available as anticipated in the audit schedule. Effect: The County is not in compliance with the Uniform Guidance Single Audit reporting requirements. Recommendation: We recommend that as the County gets up and running on the new accounting system, the audit be prioritized in future periods. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to better anticipate the needs and timing and availability of staff/information to complete the audit.

Federal Program: Assistance Listing #14.239 HOME Investment Partnerships Program, U.S. Department of Housing and Urban Development, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: C000074088 Assistance Listing #21.023, COVID-19 Emergency Rental Assistance Program, U.S. Department of Treasury, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available Prior Year Finding Number: N/A Criteria: The Uniform Guidance outlines various requirements for pass-through entities in Section 200.331, including the following items: (a) ensuring all subawards are clearly identify to the subrecipient as a subaward and include certain required information; (b) evaluate each subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring; (c) consider imposing specific subaward conditions upon a subrecipient, if appropriate; (d) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations and the terms and conditions of the subaward; (e) depending on the pass-through entity's assessment of risk posed by the subrecipient, perform appropriate monitoring of the subrecipient; (f) verify that every subrecipient is audited as required by Subpart F of the Uniform Guidance; (g) consider whether the results of the subrecipient's audits, on-site reviews or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records, and; (h) consider taking enforcement actions against noncompliance subrecipients as described in Uniform Guidance Section 200.338. Condition/Context: The County does not have a formal risk assessment or oversight program in place to monitor its subrecipients as required under the Uniform Guidance. Questioned Costs: N/A Cause: The County was still in the process of acclimating itself to the required written policies / procedures within the Uniform Guidance and as such, the County personnel overseeing subrecipients did not understand their responsibilities in regards to monitoring subrecipients. Effect: The County cannot be assured that subrecipients are appropriately understanding and complying with the requirements of the funding stream passed through to them. Recommendation: We recommend that the County revisit its policies and procedures related to subrecipient monitoring and ensure that there are formal subaward agreements with all subrecipients, prepare a formal, initial, risk assessment of each potential subrecipient and document its monitoring activities of each subrecipient. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to implement these policies, procedures and activities on a prospective basis.

Federal Program: Assistance Listing #21.019, Coronavirus Relief Fund, U.S. Department of Treasury, Passed through the Pennsylvania Department of Community and Economic Development, Pennsylvania Department of Human Services and Pennsylvania Department of Agriculture, Pass-Through Entity Identifying Numbers: C000073949 and others not available Prior year finding number 2019-005 Criteria: The Uniform Guidance requires written policies and/or procedures in the areas of allowability of costs, cash management, procurement, subrecipient monitoring and conflict of interest. Condition/Context: While the County has adequate informal policies and procedures surrounding the administration of federal programs, these policies and procedures have not been formally documented to ensure compliance with the areas of allowability of costs, cash management, procurement or subrecipient monitoring as required under the Uniform Guidance. Questioned Costs: N/A Cause: The County was still in the process of acclimating itself to the required written policies/procedures within the Uniform Guidance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance and as such, employees do not currently have the benefit of these written policies and/or procedures to assist in managing and directing its federal award programs. Recommendation: We recommend that County management prepare the require written policies/procedures related to allowability of costs, cash management, procurement, subrecipient monitoring and conflict of interest outlined with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to formally document the required elements of its policies and procedures pursuant to the Uniform Guidance.

Finding 2019-005 (Noncompliance) Uniform Guidance Written Policies/Procedures Federal Program: U.S. Department of Housing and Urban Development, passed through the Pennsylvania Department of Community and Economic Development, Community Development Block Grant (CFDA #14.228), Years 2013 - 2019 U.S. Department of Health and Human Services, passed through the Pennsylvania Department of Human Services, Foster Care - Title IV-E (CFDA #93.658), Year 2019 Repeat Finding: Repeat of finding 2018-005 Criteria: The Uniform Guidance requires written policies and/or procedures in the areas of allowability of cost, cash management, procurement, subrecipient monitoring and conflict of interest. Condition/Context: We noted during our audit of the County's Community Development Block Grant and Foster Care - Title IV-E programs that, while the County has informal policies and procedures surrounding the administration of federal programs, these policies and procedures have not been formally documented to ensure compliance with the areas of allowability of costs, cash management, or procurement as required under the Uniform Guidance. Effect: County personnel involved with the administration of federal award programs have not had the benefit of current written procedures to assist them with compliance. Cause: These written requirements became effective for federal grants dated on or after December 26, 2014; during 2019, the County was still in the process of acclimating itself to these Uniform Guidance requirements. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the County draft and adopt all of the written policies required by the Uniform Guidance, as applicable to its federal programs. Views of Responsible Officials and Planned Corrective Actions: Management understands its responsibilities and is working to formally document the required elements of its policies and procedures pursuant to the Uniform Guidance.

Finding 2019-006 (Material Weakness/Noncompliance) Completion and Submission of Annual Single Audit Federal Program: U.S. Department of Housing and Urban Development, passed through the Pennsylvania Department of Community and Economic Development, Community Development Block Grant (CFDA #14.228), Years 2013 - 2019 U.S. Department of Health and Human Services, passed through the Pennsylvania Department of Human Services, Foster Care - Title IV-E (CFDA #93.658), Year 2019 Repeat Finding: Repeat of Finding 2018-006 Criteria: Pursuant to the provisions of the Uniform Guidance, section 200.512(a), the County is required to undergo and complete its Single Audit and file the Single Audit and related Data Collection Form within 9 months of its year-end. Condition/Context: The County's Single Audit and reporting package was delayed for the years ended December 31, 2017 and 2018, as a result in delays in the completion of its pension actuarial valuation, beyond the 9-month due date. Effect: The County is not in compliance with the Uniform Guidance Single Audit reporting requirements. Cause: The County's 2017 and 2018 audits were delayed beyond the 9-month filing deadline as a result of delays in the completion of the County's pension actuarial valuation. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that management implement procedures to ensure that its internal books and records are closed and that all outside reports are completed and provided within a timely period after year-end to enable the County to complete and file its audit within the 9-month due date. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to accelerate the timing of its actuarial services and closing processes to meet the single audit filing date.

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