COUNTY OF LYCOMING

2024-008 - Uniform Guidance Subrecipient Monitoring - Significant Deficiency/Noncompliance Federal Program: Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Pass Through Entity Identifying Number: Not Available Prior Year Finding Number 2023-008 Criteria: The requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), §200.331 Requirements for Pass-through Entities, requires entities who pass federal funding through to subrecipients evaluate each subrecipient's risk of noncompliance. As detailed in 2 CFR sections 200.331(d) through (f), the Uniform Guidance requires pass-through entities to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. This includes issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient, as detailed in 2 CFR section 200.521. Condition/Context: As part of our follow-up on previous audit findings and based on our current year testing, it was noted that the County is not formally documenting its monitoring activities over its subrecipients in compliance with the Uniform Guidance. Questioned Costs: N/A Cause: While the County has monitoring processes in place for subrecipients, it is not currently documenting certain of the initial risk assessment decisions or the occurrence of ongoing monitoring activities for its subrecipient, representing a significant deficiency in internal control over compliance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance. Recommendation: We recommend that County management perform and document the various monitoring activities performed with regard to its subrecipients. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to provide better oversight and monitoring of entities that receive pass-through grant dollars. See corrective action plan.

2024-009 - Completion and Submission of Annual Single Audit - Significant Deficiency/Noncompliance Assistance Listing #21.023, Emergency Rental Assistance Program, U.S. Department of Treasury, Passed through the Pennsylvania Department of Human Services, Pass Through Entity Identifying Number: Not Available Assistance Listing #93.778, Medicaid Cluster, U.S Department of Health and Human Services, Pass-Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: N/A Prior Year Finding Number: 2023-009 Criteria: Pursuant to the provisions of the Uniform Guidance, under §200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within nine months of the end of its fiscal period (September 30) of the following year. Condition/Context: The County's Single Audit and reporting package was delayed for the year-ended December 31, 2023, as a result of turnover within its Budget and Finance Office, beyond the nine month due date. Questioned Costs: N/A Cause: The County's 2023 Single Audit was delayed beyond the nine-month filing deadline as a result of turnover within its Budget and Finance Office. Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements. Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit within the prescribed timeframes. Views of Responsible Officials and Planned Corrective Actions: The County is currently working to accelerate its internal year-end close to facilitate a more timely completion of the audit process. See corrective action plan.

2023-008 - Uniform Guidance Subrecipient Monitoring - Significant Deficiency/Noncompliance Federal Program: Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Pass Through Entity Identifying Number: Not Available Assistance Listing #21.023, Emergency Rental Assistance Program, U.S. Department of Treasury, Passed through the Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: N/A Prior Year Finding Number 2022-004 Criteria: The requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), §200.331 Requirements for Pass-through Entities, requires entities who pass federal funding through to subrecipients evaluate each subrecipient's risk of noncompliance. As detailed in 2 CFR sections 200.331(d) through (f), the Uniform Guidance requires pass-through entities to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. This includes issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient, as detailed in 2 CFR section 200.521. Condition/Context: As part of our follow-up on previous audit findings and based on our current year testing, it was noted that the County is not formally documenting its monitoring activities over its subrecipients in compliance with the Uniform Guidance. Questioned Costs: N/A Cause: While the County has monitoring processes in place for subrecipients, it is not currently documenting certain of the initial risk assessment decisions or the occurrence of ongoing monitoring activities for its subrecipient, representing a significant deficiency in internal control over compliance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance. Recommendation: We recommend that County management perform and document the various monitoring activities performed with regard to its subrecipients. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to provide better oversight and monitoring of entities that receive pass-through grant dollars. See corrective action plan.

2023-009 - Completion and Submission of Annual Single Audit - Significant Deficiency/Noncompliance Federal Program: Assistance Listing #93.563, Title IV-D - Child Support Enforcement, Passed through the Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: Not Available Assistance Listing #21.023, Emergency Rental Assistance Program, U.S. Department of Treasury, Passed through the Pennsylvania Department of Human Services, Pass Through Entity Identifying Number: Not Available Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Pass Through Entity Identifying Number: Not Available Prior Year Finding Number: 2022-005 Criteria: Pursuant to the provisions of the Uniform Guidance, under §200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within nine months of the end of its fiscal period (September 30) of the following year. Condition/Context: The County's Single Audit and reporting package was delayed for the year-ended December 31, 2022, as a result of turnover within its Budget and Finance Office, beyond the nine month due date. Questioned Costs: N/A Cause: The County's 2022 Single Audit was delayed beyond the nine-month filing deadline as a result of turnover within its Budget and Finance Office. Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements. Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit within the prescribed timeframes. Views of Responsible Officials and Planned Corrective Actions: The County is currently interviewing for additional personnel to ensure completion of its audit requirements and responsibilities in a timely manner. See corrective action plan.

Federal Program: Assistance Listing #14.228, Community Development Block Grant, U.S. Department of Housing and Urban Development, Passed through the Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Numbers: C000066177, C000067301, C000070907, C000073805, C000076178, C000075471 and C000062142 Assistance Listing #21.023, Emergency Rental Assistance Program, U.S. Department of Treasury, Passed through the Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: N/A Prior Year Finding Number 2021-004 Criteria: The requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), §200.331 Requirements for Pass-through Entities, requires entities who pass federal funding through to subrecipients evaluate each subrecipient's risk of noncompliance. As detailed in 2 CFR sections 200.331(d) through (f), the Uniform Guidance requires pass-through entities to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. This includes issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient, as detailed in 2 CFR section 200.521. Condition: As part of our follow-up on previous audit findings, it was noted that the County is not performing monitoring activities over its subrecipient in compliance with the Uniform Guidance. Additionally, it was noted that the County did not issue a management decision for an audit finding pertaining to the Federal award provided to the subrecipient in a prior year. Questioned Costs: N/A Cause: The County does not have in place sufficient monitoring activities for its subrecipient, representing a significant deficiency in internal control over compliance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance. Context: Title IV-E funding is passed through to the Lycoming-Clinton Mental Health and Intellectual Disabilities Joinder Board. The governing body of the Joinder consists of the Board of Commissioners of Lycoming and Clinton Counties, which allow each County 50% control. While it has been determined that the County has risk assessment and subrecipient monitoring policies and procedures in place for its pass-through entities related to other federal programs, management at the County has taken the position that the Title IV-E program is being monitored because of the unique nature of the funding being passed through to the Joinder Board. Recommendation: We recommend that County management perform monitoring activities for the Title IV-E program similar to the policies and procedures it has in place for its other pass-through activities. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to provide better oversight and monitoring of entities that receive pass-through grant dollars. See corrective action plan.

Federal Program: Assistance Listing #14.228, Community Development Block Grant, U.S. Department of Housing and Urban Development, Passed through the Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Numbers: C000066177, C000067301, C000070907, C000073805, C000076178, C000075471 and C000062142 Assistance Listing #21.023, Emergency Rental Assistance Program, U.S. Department of Treasury, Passed through the Pennsylvania Department of Human Services, Pass Through Entity Identifying Number: Not Available Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Pass Through Entity Identifying Number: Not Available Prior Year Finding Number: 2021-005 Criteria: Pursuant to the provisions of the Uniform Guidance, under §200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within nine months of the end of its fiscal period (September 30) of the following year. Condition/Context: The County's Single Audit and reporting package was delayed for the year-ended December 31, 2022, as a result of turnover within its Budget and Finance Office, beyond the nine month due date. Questioned Costs: N/A Cause: The County's 2022 Single Audit was delayed beyond the nine-month filing deadline as a result of turnover within its Budget and Finance Office. Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements. Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit within the prescribed timeframes. Views of Responsible Officials and Planned Corrective Actions: The County is currently interviewing for additional personnel to ensure completion of its audit requirements and responsibilities in a timely manner. See corrective action plan.

Federal Program: Assistance Listing #93.658, Title IV-E - Foster Care, U.S. Department of Health and Human Services, Passed through the Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: Not Available Prior Year Finding Number 2020-003 Criteria: The requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), ?200.331 Requirements for Pass-through Entities, requires entities who pass federal funding through to subrecipients evaluate each subrecipient's risk of noncompliance. As detailed in 2 CFR sections 200.331(d) through (f), the Uniform Guidance requires pass-through entities to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. This includes issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient, as detailed in 2 CFR section 200.521. Condition: As part of our follow-up on previous audit findings, it was noted that the County is not performing monitoring activities over its subrecipient in compliance with the Uniform Guidance. Additionally, it was noted that the County did not issue a management decision for an audit finding pertaining to the Federal award provided to the subrecipient in the current year. Questioned Costs: N/A Cause: The County does not have in place sufficient monitoring activities for its subrecipient, representing a significant deficiency in internal control over compliance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance. Context: Title IV-E funding is passed through to the Lycoming-Clinton Mental Health and Intellectual Disabilities Joinder Board. The governing body of the Joinder consists of the Board of Commissioners of Lycoming and Clinton Counties, which allow each County 50 percent control. While it has been determined that the County has risk assessment and subrecipient monitoring policies and procedures in place for its pass-through entities related to other federal programs, management at the County has taken the position that the Title IV-E program is being monitored because of the unique nature of the funding being passed through to the Joinder Board. Recommendation: We recommend that County management perform monitoring activities for the Title IV-E program similar to the policies and procedures it has in place for its other pass-through activities. Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to provide better oversight and monitoring of entities that receive pass-through grant dollars. See corrective action plan.

Federal Program: Assistance Listing #21.023, Emergency Rental Assistance Program, U.S. Department of Treasury, Passed through the 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, under ?200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within 9 months of the end of its fiscal period (September 30) of the following year. Condition/Context: The County?s Single Audit and reporting package was delayed for the year-ended December 31, 2021, as a result of turnover within its Budget and Finance Office, beyond the 9-month due date. Questioned Costs: N/A Cause: The County?s 2021 Single Audit was delayed beyond the 9-month filing deadline as a result of turnover within its Budget and Finance Office. Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements. Recommendation: We recommend that County management review its staffing and budget and finance personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes. Views of Responsible Officials and Planned Corrective Actions: The County is currently interviewing for additional personnel to staff the budget and finance office, including completion of its audit requirements and responsibilities. See corrective action plan.

Criteria: The requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), ?200.331 "Requirements for Pass-through Entities", requires entities who pass federal funding through to subrecipients evaluate each subrecipient's risk of noncompliance. As detailed in 2 CFR sections 200.331(d) through (f), the Uniform Guidance requires pass-through entities to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. This includes issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient, as detailed in 2 CFR section 200.521. Condition: As part of our follow-up on previous audit findings, it was noted that the County is not performing monitoring activities over its subrecipient in compliance with the Uniform Guidance. Additionally, it was noted that the County did not issue a management decision for an audit finding pertaining to the Federal award provided to the subrecipient in the current year. Questioned Costs: N/A Cause: The County does not have in place sufficient monitoring activities for its subrecipient, representing a significant deficiency in internal control over compliance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance. Context: Title IV-E funding is passed through to the Lycoming-Clinton Mental Health and Intellectual Disabilities Joinder Board. The governing body of the Joinder consists of the Board of Commissioners of Lycoming and Clinton Counties, which allow each County 50% control. While it has been determined that the County has risk assessment and subrecipient monitoring policies and procedures in place for its pass-through entities related to other federal programs, management at the County has taken the position that the Title IV-E program is being monitored because of the unique nature of the funding being passed through to the Joinder Board. Recommendation: We recommend that County management perform monitoring activities for the Title IV-E program similar to the policies and procedures it has in place for its other pass-through activities. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.

Criteria: The requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), ?200.331, ?Subrecipient and Contractor Determinations,? include requirements pertaining to the pass-through entity?s responsibilities to determine, on a case-by-case basis, whether lower tier entities receiving funding are contractors or as subrecipients. Further, when a lower tier entity receives funding as a subrecipient, ?200.332 sections (a) through (h) "Requirements for Pass-through Entities" outlines various pass-through entity responsibilities, which include: (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 200.339. Condition/Context: The County?s process for determining whether a lower-tier entity receiving funding as a contractor or a subrecipient was not documented within the program files. Further, when contracting with various entities, the County utilized a singular agreement that identified each entity that received funding as a subrecipient, when certain entities may have been either contractors or beneficiaries of the funding and not true subrecipients. Questioned Costs: N/A Cause: The County had limited time to (May ? December 2020) to award the funds to lower tier entities and utilized its existing subrecipient contract for all entities regardless of whether they were contractors, beneficiaries or sub-recipients. Effect: Contractually, all lower-tier entities were identified as ?sub-recipients,? wherein certain of these entities might have met the criteria of a ?contractor? or ?beneficiary.? Recommendation: We recommend that the County implement a formal process to evaluate and document its considerations as to whether an entity receiving funding is a contractor, beneficiary or a subrecipient under the provisions of ?200.331 of the Uniform Guidance. We also recommend that the County utilize different contractual agreements for entities that are contractors/beneficiaries and those who are subrecipients. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.

Federal Program: CFDA #93.658, Title IV-E ? Foster Care, U.S. Department of Health and Human Services, Passed through the Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: Not Available Prior year finding number 2018-002 Criteria: The requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance"), ?200.331 "Requirements for pass-through entities", requires that entities that pass federal funding through to subrecipients evaluate each subrecipient?s risk of non-compliance. As detailed in 2 CFR sections 200.331(d) through (f), the Uniform Guidance requires pass-through entities to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. This includes issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient, as detailed in 2 CFR section 200.521. Condition: As part of our audit procedures, it was noted that the County is not performing monitoring activities over its subrecipient in compliance with the Uniform Guidance. Additionally, it was noted that the County did not issue a management decision for an audit finding pertaining to the Federal award provided to the subrecipient in the current year. Questioned Costs: N/A Cause: The County does not have in place sufficient monitoring activities for its subrecipient, representing a significant deficiency in internal control over compliance. Effect: The County is not in compliance with certain requirements of the Uniform Guidance. Context: Title IV-E funding is passed through to the Lycoming-Clinton Mental Health and Intellectual Disabilities Joinder Board. The governing body of the Joinder consists of the Board of Commissioners of Lycoming and Clinton Counties, which allow each County 50% control. While it has been determined that the County has risk assessment and subrecipient monitoring policies and procedures in place for its pass-through entities related to other federal programs, management at the County has taken the position that the Title IV-E program is being monitored because of the unique nature of the funding being passed through to the Joinder Board. Recommendation: We recommend that County management perform monitoring activities for the Title IV-E program similar to the policies and procedures it has in place for its other pass-through activities. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.

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