COUNTY OF DELAWARELocal Government

2 C.F.R. ? 1000 gives regulatory effect to the Department of Treasury for 2 C.F.R. ? 200.302(b)(2) which states, in part, the financial management system of each non-Federal entity must provide for the accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ? 200.328. 2 C.F.R. ? 200.328 states, in part, this information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 C.F.R. ? 200.208(c) states, in part, additional Federal award conditions may include items such as requiring additional, more detailed financial reports. H.R. 133, Consolidated Appropriations Act, Public Law 116-260; Division N Sec. 501 describes the enactment of the Emergency Rental Assistance (ERA) program. Sect. 501(g) describes the reporting requirements regarding such funds and provides, in relevant part, that the Secretary, in consultation with the Secretary of Housing and Urban Development, shall provide public reports (not less frequently than quarterly) regarding the use of funds made available under this section, which shall include, with respect to each eligible grantee under this section: (A) the number of eligible households that receive assistance from such payments; (B) the acceptance rate of applicants for assistance; (C) the type or types of assistance provided to each eligible household; (D) the average amount of funding provided per eligible household receiving assistance; (E) household income level and; (F) the average number of monthly rental or utility payments that were covered by the funding amount that a household received, as applicable. Additionally, Sec. 501(g) indicates that the Secretary may establish alternative reporting requirements for grantees. The Department of Treasury's award terms for the Emergency Rental Assistance Program 1 states, in part, that a Recipient agrees to comply with any reporting obligations established by Treasury, including the Treasury Office of Inspector General, as relates to this award, including but not limited to: (i) reporting of information to be used by Treasury to comply with its public reporting obligations under section 501(g) and (ii) any reporting to Treasury and the Pandemic Response Accountability Committee that may be required pursuant to section 15011(b)(2) of Division B of the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136), as amended by Section 801 of Division O of the Consolidated Appropriations Act, 2021 (Pub. L. No. 116-260). See Archived Grantee Award Terms for ERA 1. Additionally, a Recipient acknowledges that any such information required to be reported pursuant to this section may be publicly disclosed. The Department of Treasury also requires Emergency Rental Assistance recipients to certify and submit monthly and quarterly reports. See Emergency Rental Assistance Program, Reporting Guidance. As a result, the Department required recipients to submit 15 reports, 6 of which were quarterly and 9 monthly, for Emergency Rental Assistance Program 1 throughout calendar year 2021. The County did not submit the Q1 2021 Partial report for the Interim 1 cycle as required by Treasury, resulting in an observed error rate of 6.67%. The County also reported March 2021 activity within the April 2021 monthly report, causing the March disbursements to households of $125,516 to be reported twice. Lastly, during our review of each submitted quarterly report, we noted numerous errors affecting completeness and accuracy; including missing subrecipient reporting information tabs, inaccurate administrative expenditures, and payments to households expenditures. The County lacked procedures to help ensure all reports were submitted as required by the grant agreement and that submitted reports were accurate. Not submitting all reports or inaccurate reports could lead to inaccurate tracking of grants by the County. Treasury also relies on the reports submitted by the County to complete Federal Subaward Reporting System requirements as required by 2 C.F.R. ? 170. We recommend the County review the federal award agreement and implement procedures to ensure they are meeting all compliance requirements as prescribed by the awarding agency. We further recommend the County implement procedures to maintain information in the event there is employee turnover regarding those tasked with grant management.

45 CFR 96.126(a) requires that the State shall establish a capacity management program which reasonably implements this section - that is, which enables any such program to readily report to the State when it reaches 90 percent of its capacity - and which ensures the maintenance of a continually updated record of all such reports and which makes excess capacity information available to such programs. 96.126(g) also indicates that the State shall develop effective strategies for monitoring programs compliance with this section. States shall report under the requirements of ? 96.122(g) on the specific strategies to be used to identify compliance problems and corrective actions to be taken to address those problems. 2021 Ohio MHAS Agreement and Assurance #43 states that a sub-awardee must submit quarterly to the Department?s Division of Treatment and Recovery Services a listing of providers that reach 90 percent of capacity. In the event that no providers reach 90 percent of capacity, the sub-awardee should submit the quarterly reporting indicating such. Those quarterly reports are to be submitted to the Department by the following dates: January 31, April 30, July 31 and October 31. During 90 percent Capacity Report testing, we identified: ? Two instances of the Delaware Morrow Mental Health and Recovery Services Board (the Board) failing to meet the deadline to submit their reports by the appropriate dates (January 31, 2022 and October 31, 2021) of which, both reports were submitted on July 22nd, 2022. ? Two instances of the Board failing to submit the 90 percent Capacity reports to Ohio Mental Health and Addiction Services. In total, the Board failed to properly comply with reporting compliance requirements for all four of the required reports during 2021. The Board did not have effective internal control procedures in place to help ensure that all reporting requirements were met as required by the grant agreement. The lack of internal controls could result in the Board failing to track grants appropriately, as well as, submitting late and/or inaccurate reports leading to further noncompliance. The Board should ensure they have proper internal control procedures developed and operating effectively to comply with all grant compliance requirements.

2 C.F.R. ? 1000 gives regulatory effect to the Department of Treasury for 2 C.F.R. ? 200.302(b)(2) which states, in part, the financial management system of each non-Federal entity must provide for the accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ? 200.328. 2 C.F.R. ? 200.328 states, in part, this information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 C.F.R. ? 200.208(c) states, in part, additional Federal award conditions may include items such as requiring additional, more detailed financial reports. H.R. 133, Consolidated Appropriations Act, Public Law 116-260; Division N Sec. 501 describes the enactment of the Emergency Rental Assistance (ERA) program. Sect. 501(g) describes the reporting requirements regarding such funds and provides, in relevant part, that the Secretary, in consultation with the Secretary of Housing and Urban Development, shall provide public reports (not less frequently than quarterly) regarding the use of funds made available under this section, which shall include, with respect to each eligible grantee under this section: (A) the number of eligible households that receive assistance from such payments; (B) the acceptance rate of applicants for assistance; (C) the type or types of assistance provided to each eligible household; (D) the average amount of funding provided per eligible household receiving assistance; (E) household income level and; (F) the average number of monthly rental or utility payments that were covered by the funding amount that a household received, as applicable. Additionally, Sec. 501(g) indicates that the Secretary may establish alternative reporting requirements for grantees. The Department of Treasury's award terms for the Emergency Rental Assistance Program 1 states, in part, that a Recipient agrees to comply with any reporting obligations established by Treasury, including the Treasury Office of Inspector General, as relates to this award, including but not limited to: (i) reporting of information to be used by Treasury to comply with its public reporting obligations under section 501(g) and (ii) any reporting to Treasury and the Pandemic Response Accountability Committee that may be required pursuant to section 15011(b)(2) of Division B of the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136), as amended by Section 801 of Division O of the Consolidated Appropriations Act, 2021 (Pub. L. No. 116-260). See Archived Grantee Award Terms for ERA 1. Additionally, a Recipient acknowledges that any such information required to be reported pursuant to this section may be publicly disclosed. The Department of Treasury also requires Emergency Rental Assistance recipients to certify and submit monthly and quarterly reports. See Emergency Rental Assistance Program, Reporting Guidance. As a result, the Department required recipients to submit 15 reports, 6 of which were quarterly and 9 monthly, for Emergency Rental Assistance Program 1 throughout calendar year 2021. The County did not submit the Q1 2021 Partial report for the Interim 1 cycle as required by Treasury, resulting in an observed error rate of 6.67%. The County also reported March 2021 activity within the April 2021 monthly report, causing the March disbursements to households of $125,516 to be reported twice. Lastly, during our review of each submitted quarterly report, we noted numerous errors affecting completeness and accuracy; including missing subrecipient reporting information tabs, inaccurate administrative expenditures, and payments to households expenditures. The County lacked procedures to help ensure all reports were submitted as required by the grant agreement and that submitted reports were accurate. Not submitting all reports or inaccurate reports could lead to inaccurate tracking of grants by the County. Treasury also relies on the reports submitted by the County to complete Federal Subaward Reporting System requirements as required by 2 C.F.R. ? 170. We recommend the County review the federal award agreement and implement procedures to ensure they are meeting all compliance requirements as prescribed by the awarding agency. We further recommend the County implement procedures to maintain information in the event there is employee turnover regarding those tasked with grant management.

45 CFR 96.126(a) requires that the State shall establish a capacity management program which reasonably implements this section - that is, which enables any such program to readily report to the State when it reaches 90 percent of its capacity - and which ensures the maintenance of a continually updated record of all such reports and which makes excess capacity information available to such programs. 96.126(g) also indicates that the State shall develop effective strategies for monitoring programs compliance with this section. States shall report under the requirements of ? 96.122(g) on the specific strategies to be used to identify compliance problems and corrective actions to be taken to address those problems. 2021 Ohio MHAS Agreement and Assurance #43 states that a sub-awardee must submit quarterly to the Department?s Division of Treatment and Recovery Services a listing of providers that reach 90 percent of capacity. In the event that no providers reach 90 percent of capacity, the sub-awardee should submit the quarterly reporting indicating such. Those quarterly reports are to be submitted to the Department by the following dates: January 31, April 30, July 31 and October 31. During 90 percent Capacity Report testing, we identified: ? Two instances of the Delaware Morrow Mental Health and Recovery Services Board (the Board) failing to meet the deadline to submit their reports by the appropriate dates (January 31, 2022 and October 31, 2021) of which, both reports were submitted on July 22nd, 2022. ? Two instances of the Board failing to submit the 90 percent Capacity reports to Ohio Mental Health and Addiction Services. In total, the Board failed to properly comply with reporting compliance requirements for all four of the required reports during 2021. The Board did not have effective internal control procedures in place to help ensure that all reporting requirements were met as required by the grant agreement. The lack of internal controls could result in the Board failing to track grants appropriately, as well as, submitting late and/or inaccurate reports leading to further noncompliance. The Board should ensure they have proper internal control procedures developed and operating effectively to comply with all grant compliance requirements.

2 C.F.R. ? 1000 gives regulatory effect to the Department of Treasury for 2 C.F.R. ? 200.302(b)(2) which states, in part, the financial management system of each non-Federal entity must provide for the accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ? 200.328. 2 C.F.R. ? 200.328 states, in part, this information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 C.F.R. ? 200.208(c) states, in part, additional Federal award conditions may include items such as requiring additional, more detailed financial reports. H.R. 133, Consolidated Appropriations Act, Public Law 116-260; Division N Sec. 501 describes the enactment of the Emergency Rental Assistance (ERA) program. Sect. 501(g) describes the reporting requirements regarding such funds and provides, in relevant part, that the Secretary, in consultation with the Secretary of Housing and Urban Development, shall provide public reports (not less frequently than quarterly) regarding the use of funds made available under this section, which shall include, with respect to each eligible grantee under this section: (A) the number of eligible households that receive assistance from such payments; (B) the acceptance rate of applicants for assistance; (C) the type or types of assistance provided to each eligible household; (D) the average amount of funding provided per eligible household receiving assistance; (E) household income level and; (F) the average number of monthly rental or utility payments that were covered by the funding amount that a household received, as applicable. Additionally, Sec. 501(g) indicates that the Secretary may establish alternative reporting requirements for grantees. The Department of Treasury's award terms for the Emergency Rental Assistance Program 1 states, in part, that a Recipient agrees to comply with any reporting obligations established by Treasury, including the Treasury Office of Inspector General, as relates to this award, including but not limited to: (i) reporting of information to be used by Treasury to comply with its public reporting obligations under section 501(g) and (ii) any reporting to Treasury and the Pandemic Response Accountability Committee that may be required pursuant to section 15011(b)(2) of Division B of the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136), as amended by Section 801 of Division O of the Consolidated Appropriations Act, 2021 (Pub. L. No. 116-260). See Archived Grantee Award Terms for ERA 1. Additionally, a Recipient acknowledges that any such information required to be reported pursuant to this section may be publicly disclosed. The Department of Treasury also requires Emergency Rental Assistance recipients to certify and submit monthly and quarterly reports. See Emergency Rental Assistance Program, Reporting Guidance. As a result, the Department required recipients to submit 15 reports, 6 of which were quarterly and 9 monthly, for Emergency Rental Assistance Program 1 throughout calendar year 2021. The County did not submit the Q1 2021 Partial report for the Interim 1 cycle as required by Treasury, resulting in an observed error rate of 6.67%. The County also reported March 2021 activity within the April 2021 monthly report, causing the March disbursements to households of $125,516 to be reported twice. Lastly, during our review of each submitted quarterly report, we noted numerous errors affecting completeness and accuracy; including missing subrecipient reporting information tabs, inaccurate administrative expenditures, and payments to households expenditures. The County lacked procedures to help ensure all reports were submitted as required by the grant agreement and that submitted reports were accurate. Not submitting all reports or inaccurate reports could lead to inaccurate tracking of grants by the County. Treasury also relies on the reports submitted by the County to complete Federal Subaward Reporting System requirements as required by 2 C.F.R. ? 170. We recommend the County review the federal award agreement and implement procedures to ensure they are meeting all compliance requirements as prescribed by the awarding agency. We further recommend the County implement procedures to maintain information in the event there is employee turnover regarding those tasked with grant management.

45 CFR 96.126(a) requires that the State shall establish a capacity management program which reasonably implements this section - that is, which enables any such program to readily report to the State when it reaches 90 percent of its capacity - and which ensures the maintenance of a continually updated record of all such reports and which makes excess capacity information available to such programs. 96.126(g) also indicates that the State shall develop effective strategies for monitoring programs compliance with this section. States shall report under the requirements of ? 96.122(g) on the specific strategies to be used to identify compliance problems and corrective actions to be taken to address those problems. 2021 Ohio MHAS Agreement and Assurance #43 states that a sub-awardee must submit quarterly to the Department?s Division of Treatment and Recovery Services a listing of providers that reach 90 percent of capacity. In the event that no providers reach 90 percent of capacity, the sub-awardee should submit the quarterly reporting indicating such. Those quarterly reports are to be submitted to the Department by the following dates: January 31, April 30, July 31 and October 31. During 90 percent Capacity Report testing, we identified: ? Two instances of the Delaware Morrow Mental Health and Recovery Services Board (the Board) failing to meet the deadline to submit their reports by the appropriate dates (January 31, 2022 and October 31, 2021) of which, both reports were submitted on July 22nd, 2022. ? Two instances of the Board failing to submit the 90 percent Capacity reports to Ohio Mental Health and Addiction Services. In total, the Board failed to properly comply with reporting compliance requirements for all four of the required reports during 2021. The Board did not have effective internal control procedures in place to help ensure that all reporting requirements were met as required by the grant agreement. The lack of internal controls could result in the Board failing to track grants appropriately, as well as, submitting late and/or inaccurate reports leading to further noncompliance. The Board should ensure they have proper internal control procedures developed and operating effectively to comply with all grant compliance requirements.