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Pennsylvania Single Audit Report (FY Ended June 30, 2021)

Issuer
Source documents
Document type
Audit Report
Date
2021-06-30
Case
2022 Single Audit Fye 2021 06 30

Summary

The Commonwealth of Pennsylvania Single Audit Report for the fiscal year ended June 30, 2021, prepared by the Office of the Budget and transmitted to the U.S. Department of Health and Human Services by Secretary of the Budget Gregory Thall on March 18, 2022. The transmittal letter states that the Schedule of Expenditures of Federal Awards reflects $72.5 billion of federal expenditures and that 94 percent, or $68.4 billion, was under programs audited as major programs. The audit was performed jointly by the Department of the Auditor General and CliftonLarsonAllen LLP, whose report states that the financial statements present fairly, in all material respects, the Commonwealth's financial position. The report covers 20 major federal programs, findings and questioned costs, the status of 35 prior findings and corrective action plans.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Commonwealth of Pennsylvania




SINGLE
AUDIT
REPORT
For the Fiscal Year
Ended June 30, 2021




Governor
Tom Wolf
      the




the
         Commonwealth of Pennsylvania
                      Single Audit Report
 For the Fiscal Year Ended June 30, 2021


                        Tom Wolf, Governor




                                    Prepared By:
                          Office of the Budget

                                Gregory Thall
                                  Secretary

                        Brian Lyman, CPA
                      Chief Accounting Officer


            This document is available on the Office of the Budget website at:
https://www.budget.pa.gov/Publications%20And%20Reports/Pages/State-LevelSingleAudit.aspx
THIS PAGE INTENTIONALLY LEFT BLANK
                                                     Commonwealth of Pennsylvania
                                                           Single Audit Report
                                                 For the Fiscal Year Ended June 30, 2021

                                                                TABLE OF CONTENTS
                                                                                                                                                                Page
                                                             INTRODUCTORY SECTION

Title Page ..................................................................................................................................................    1
Table of Contents ......................................................................................................................................         3
Letter of Transmittal .................................................................................................................................          4

                                                   INDEPENDENT AUDITORS’ REPORTS

Independent Auditors’ Report ...................................................................................................................                 8
Independent Auditors’ Report on Internal Control Over Financial Reporting and on Compliance
   and Other Matters Based on an Audit of Financial Statements Performed in Accordance with
   Government Auditing Standards ............................................................................................................                    12
Independent Auditors’ Report on Compliance for Each Major Federal Program; Report on Internal
  Control Over Compliance; and Report on Schedule of Expenditures of Federal Awards Required by
  the Uniform Guidance ............................................................................................................................              15

                                 SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS

Schedule of Expenditures of Federal Awards…………………………………………………………….                                                                                               24
Notes to the Schedule of Expenditures of Federal Awards……………………………………………….                                                                                       40

                                    SCHEDULE OF FINDINGS AND QUESTIONED COSTS

Summary of Auditors’ Results ..................................................................................................................                  44
Index to Basic Financial Statement Findings.............................................................................................                         46
Basic Financial Statement Findings...........................................................................................................                    47
Index to Federal Award Findings and Questioned Costs ..........................................................................                                  53
Matrix of Findings by Federal Agency ......................................................................................................                      56
Federal Award Findings and Questioned Costs ........................................................................................                             57

                  MANAGEMENT’S SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS

June 30, 2020 Single Audit .......................................................................................................................              92
June 30, 2019 Single Audit .......................................................................................................................              97

                                        MANAGEMENT’S CORRECTIVE ACTION PLANS

Corrective Action Plans for June 30, 2021 ................................................................................................                      102

                                                                              APPENDIX

Legend of Abbreviations ..........................................................................................................................              116




                                                                                        3
                                       COMMONWEALTH OF PENNSYLVANIA
                                          OFFICE OF THE GOVERNOR




      GREGORY THALL
          SECRETARY
GOVERNOR’S OFFICE OF THE BUDGET


                                                  March 18, 2022


To the United States Department of Health and Human Services:

        We are pleased to submit the Commonwealth of Pennsylvania's (Commonwealth) Single Audit Report for
the fiscal year ended June 30, 2021. This audit has been performed in accordance with Government Auditing
Standards issued by the Comptroller General of the United States, and satisfies the requirements of the Single Audit
Act Amendments of 1996 and the provisions of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).

         The Commonwealth's Annual Comprehensive Financial Report for the year ended June 30, 2021 has been
issued under separate cover. The auditors’ report on the supplementary schedule of expenditures of federal awards,
and the reports on compliance and internal control over financial reporting and compliance with requirements related
to major federal programs are contained in this document.

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS

The accompanying Schedule of Expenditures of Federal Awards reflects $72.5 billion of federal expenditures by the
Commonwealth during the fiscal year ended June 30, 2021. Most of the federal expenditures occurred in fifteen state
agencies, as follows:

                                                                          FEDERAL
                   AGENCY NAME                                          EXPENDITURES
                                                                           (in thousands)
                  Human Services                                             $32,340,901
                  Labor & Industry                                            30,928,258
                  Education                                                     2,669,176
                  Transportation                                                2,471,396
                  Corrections                                                   1,274,161
                  Community & Economic Development                                594,897
                  Health                                                          542,654
                  Executive Offices                                               299,707
                  State Police                                                    250,748
                  Emergency Management Agency                                     222,877
                  Agriculture                                                     195,299
                  Military & Veterans Affairs                                     175,369
                  Environmental Protection                                        115,809
                  Drug and Alcohol Programs                                       109,119
                  Aging                                                           108,916
                    Subtotal                                                 $72,299,287
                  Other Agencies (14)                                             204,028
                    Grand Total                                              $72,503,315



                                                          4
United States Department of Health and Human Services
March 18, 2022
Page 2


For purposes of the Commonwealth's single audit, a Type A federal program is any program with federal
expenditures of at least $108.8 million. Of the $72.5 billion expended, 94 percent, or $68.4 billion, represents
expenditures under federal programs audited as major programs. The Summary of Auditors’ Results lists the
Commonwealth's 20 major federal programs tested for the fiscal year ended June 30, 2021.

FINDINGS AND RECOMMENDATIONS - CURRENT YEAR

The accompanying report for the fiscal year ended June 30, 2021 contains various findings, as disclosed in the
Schedule of Findings and Questioned Costs. Findings pertaining to the audit of the Commonwealth’s basic financial
statements are detailed in the Basic Financial Statement Findings. Findings pertaining to the audit of the
Commonwealth’s federal programs are detailed in the Federal Award Findings and Questioned Costs. The findings
contain detailed explanations of the compliance issues, questioned costs, the auditors' recommendations, and the
agency responses. This report also includes the Commonwealth's corrective action plan for each finding.

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS

The Summary Schedule of Prior Audit Findings reflects the current status of prior year findings. The status of 35
findings are described from single audits between the years ended June 30, 2019 through June 30, 2020.

INDEPENDENT AUDIT

The Commonwealth's June 30, 2021 single audit and basic financial statement audit were performed jointly by the
Department of the Auditor General and the independent public accounting firm of CliftonLarsonAllen LLP. The
audits were performed pursuant to the authority vested in the Auditor General and the Governor under Section 402
of the Fiscal Code of 1929, and in the Governor under Section 701 of the Administrative Code of 1929.

REPORTS OF OTHER INDEPENDENT AUDITORS

Other auditors performed the single audits of the Pennsylvania Higher Education Assistance Agency, the
Pennsylvania Housing Finance Agency, the State System of Higher Education (component units of the
Commonwealth), the Philadelphia Regional Port Authority, the Commonwealth Financing Authority (blended
component units of the Commonwealth), and the Judicial Department of Pennsylvania (part of the primary
government). Federal programs administered by these agencies are not included in the Commonwealth's Schedule
of Expenditures of Federal Awards. These agencies have sent their single audit reports directly to the Federal Audit
Clearinghouse for distribution to the appropriate federal agencies.

                                            ACKNOWLEDGMENTS

        We wish to express our appreciation to the staff of the various Commonwealth agencies whose time and
dedicated effort made this audit possible and, at the same time, to affirm our commitment to maintaining the highest
standards of accountability in the Commonwealth's management of federal awards.

                                                    Sincerely,



                                                    Gregory Thall
                                                    Secretary of the Budget




                                                          5
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                 6
Independent Auditors’
      Reports




  Commonwealth of Pennsylvania




               7
                                                                                                     CliftonLarsonAllen LLP
                                                                                                     CLAconnect.com

Department of the Auditor General
 Commonwealth of Pennsylvania
Harrisburg, Pennsylvania 17120-0018

                                          INDEPENDENT AUDITORS' REPORT

 The Honorable Tom Wolf, Governor
 Commonwealth of Pennsylvania
 Harrisburg, Pennsylvania

 We have jointly audited the financial statements of the governmental activities, the business-type activities, the
 aggregate discretely presented component units, each major fund, and the aggregate remaining fund information
 of the Commonwealth of Pennsylvania (the Commonwealth), as of and for the year ended June 30, 2021, and the
 related notes to the financial statements, which collectively comprise the Commonwealth’s basic financial
 statements as listed in the table of contents of the separately issued Annual Comprehensive Financial Report.

 Management’s Responsibility for the Financial Statements
 Management is responsible for the preparation and fair presentation of these financial statements in accordance
 with accounting principles generally accepted in the United States of America; this includes the design,
 implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial
 statements that are free from material misstatement, whether due to fraud or error.

 Auditors’ Responsibility
 Our responsibility is to jointly express opinions on these financial statements based on our audit. We did not
 jointly audit the financial statements of certain funds and component units of the Commonwealth, which represent
 the indicated percent of assets and deferred outflows of resources and revenues or additions as presented in the
 table below. Those financial statements were audited by other auditors, including CliftonLarsonAllen LLP and the
 Commonwealth of Pennsylvania’s Department of the Auditor General acting separately, whose reports thereon
 have been furnished to us, and our opinions, insofar as they relate to the amounts included for those funds and
 component units, are based solely on the reports of the other auditors.

                                                                                                       Percent of Opinion Unit's Total
         Opinion Unit                                        Entity                                  Assets / Deferred
                                                                                                                              Revenues /
                                                                                                        Outflow of
                                                                                                                              Additions
                                                                                                        Resources
  Business-Type Activities   Tuition Payment Fund; State Stores Fund; Commonwealth Financing               52%                   9%
                                       Authority; Philadelphia Regional Port Authority
  Major Proprietary Fund                             Tuition Payment Fund                                  100%                 100%
  Major Proprietary Fund                               State Stores Fund                                   100%                 100%
  Major Proprietary Fund                     Commonwealth Financing Authority                              100%                 100%
  Aggregate Discretely        Pennsylvania Turnpike Commission; Pennsylvania Housing Finance               100%                 100%
  Presented Component Units       Agency; Pennsylvania Higher Education Assistance Agency;
                               Pennsylvania Infrastructure Investment Authority; State System of
                            Higher Education; State Public School Building Authority; Philadelphia
                             Shipyard Development Corporation; Port of Pittsburgh Commission;
                                 Pennsylvania Industrial Development Authority; Pennsylvania
                            Convention Center Authority; Thaddeus Stevens College of Technology;
                              Pennsylvania Higher Educational Facilities Authority, Pennsylvania
                            Rural Health Redesign Center Authority, Pennsylvania Health Insurance
                                                      Exchange Authority


                                                                   8
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania



                                                                                                  Percent of Opinion Unit's Total
       Opinion Unit                                      Entity                                 Assets / Deferred
                                                                                                                     Revenues /
                                                                                                   Outflow of
                                                                                                                     Additions
                                                                                                   Resources
Aggregate Remaining Fund    Philadelphia Regional Port Authority; State Employees' Retirement         92%               77%
Information                  System; Deferred Compensation Fund; Public School Employees'
                            Retirement System; Tuition Account Investment Program; INVEST
                                                        Program

We conducted our audit in accordance with auditing standards generally accepted in the United States of America
and the standards applicable to the financial audits contained in Government Auditing Standards, issued by the
Comptroller General of the United States. Those standards require that we plan and perform the audit to obtain
reasonable assurance about whether the financial statements are free from material misstatement. The financial
statements of the State System of Higher Education, State Employees’ Retirement System, the Deferred
Compensation Fund, the Public School Employees’ Retirement System, the Pennsylvania Higher Education
Assistance Agency, the Pennsylvania Higher Educational Facilities Authority, the State Public School Building
Authority, the Port of Pittsburgh Commission, the Pennsylvania Turnpike Commission, the Philadelphia Regional
Port Authority and the Pennsylvania Rural Health Redesign Center Authority were not audited in accordance with
Government Auditing Standards.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the
financial statements. The procedures selected depend on the auditors’ judgment, including the assessment of the
risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk
assessments, the auditor considers internal control relevant to the entity’s preparation and fair presentation of the
financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the
purpose of expressing an opinion on the effectiveness of the entity’s internal control. Accordingly, we express no
such opinion. An audit also includes evaluating the appropriateness of accounting policies used and the
reasonableness of significant accounting estimates made by management, as well as evaluating the overall
presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit
opinions.

Opinions
In our opinion, based on our audit and the reports of other auditors, the financial statements referred to above
present fairly, in all material respects, the respective financial position of the governmental activities, the
business-type activities, the aggregate discretely presented component units, each major fund, and the aggregate
remaining fund information of the Commonwealth of Pennsylvania as of June 30, 2021, and the respective
changes in financial position and, where applicable, cash flows thereof for the year then ended in accordance with
accounting principles generally accepted in the United States of America.

Emphasis of Matters
Change in Accounting Principle
During fiscal year ended June 30, 2021, the Commonwealth adopted GASB Statement No. 87 Leases. As a result
of the implementation of this standard, the Commonwealth reported a restatement for the change in accounting
principle (see Note 18). Our auditors’ opinion was not modified with respect to the restatement.




                                                               9
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania



Pennsylvania Turnpike Commission
The Pennsylvania Turnpike Commission, a discretely presented component unit, has committed to making
significant payments under an Amended Lease and Funding Agreement as required under the terms of Act 44 of
2007 and Act 89 of 2013. The Pennsylvania Turnpike Commission’s ability to make such payments is dependent
on its continuing capability to issue bonds to fund such payments and ultimately to raise tolls sufficient to repay
its bonded debt and current lease payments (see Note 16). Our auditors’ opinion was not modified with respect to
this matter.

Other Matters
Required Supplementary Information
Accounting principles generally accepted in the United States of America require that the management’s
discussion and analysis on pages 20-44, and the schedules of pension and OPEB amounts, the budgetary
comparison schedules, as listed in the table of contents and notes to the required supplementary information on
pages 202-212, included in the separately issued Annual Comprehensive Financial Report, be presented to
supplement the basic financial statements. Such information, although not a part of the basic financial statements,
is required by the Governmental Accounting Standards Board who considers it to be an essential part of financial
reporting for placing the basic financial statements in an appropriate operational, economic, or historical context.
We and other auditors have applied certain limited procedures to the required supplementary information in
accordance with auditing standards generally accepted in the United States of America, which consisted of
inquiries of management about the methods of preparing the information and comparing the information for
consistency with management’s responses to our inquiries, the basic financial statements, and other knowledge
we obtained during our audit of the basic financial statements. We do not express an opinion or provide any
assurance on the information because the limited procedures do not provide us with sufficient evidence to express
an opinion or provide any assurance.

Supplementary and Other Information
Our audit was conducted for the purpose of forming opinions on the financial statements that collectively
comprise the Commonwealth’s basic financial statements. The introductory section, combining non-major fund
and component unit financial statements, budgetary comparison schedules for budgeted non-major special
revenue funds, and statistical section are presented for purposes of additional analysis and are not a required part
of the basic financial statements.

The combining non-major fund and component unit financial statements, and the budgetary comparison schedules
for budgeted non-major special revenue funds, as listed in the table of contents of the separately issued Annual
Comprehensive Financial Report, are the responsibility of management and were derived from and relate directly
to the underlying accounting and other records used to prepare the basic financial statements. Such information
has been subjected to the auditing procedures applied by us and the other auditors in the audit of the basic
financial statements and certain additional procedures, including comparing and reconciling such information
directly to the underlying accounting and other records used to prepare the basic financial statements or to the
basic financial statements themselves, and other additional procedures in accordance with auditing standards
generally accepted in the United States of America by us and other auditors. In our opinion based on our audit, the
procedures performed as described below and the reports of the other auditors, the supplementary information is
fairly stated, in all material respects, in relation to the basic financial statements as a whole.

The introductory section and statistical section have not been subjected to the auditing procedures applied in the
audit of the basic financial statements, and accordingly, we do not express an opinion or provide any assurance on
them.




                                                        10
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania



Other Reporting Required by Government Auditing Standards
In accordance with Government Auditing Standards, we have also issued our report dated December 10, 2021, on
our consideration of the Commonwealth's internal control over financial reporting and on our tests of its
compliance with certain provisions of laws, regulations, contracts, and grant agreements and other matters. The
purpose of that report is solely to describe the scope of our testing of internal control over financial reporting and
compliance and the results of that testing, and not to provide an opinion on the effectiveness of the
Commonwealth’s internal control over financial reporting or on compliance. That report is an integral part of an
audit performed in accordance with Government Auditing Standards in considering the Commonwealth’s internal
control over financial reporting and compliance.




Harrisburg, Pennsylvania                                           Baltimore, Maryland
December 10, 2021                                                  December 10, 2021




                                                         11
                                                                                                  CliftonLarsonAllen LLP
                                                                                                  CLAconnect.com

Department of the Auditor General
 Commonwealth of Pennsylvania
Harrisburg, Pennsylvania 17120-0018




               Independent Auditors’ Report on Internal Control Over Financial Reporting and on
                   Compliance and Other Matters Based on an Audit of Financial Statements
                        Performed in Accordance with Government Auditing Standards


 The Honorable Tom Wolf, Governor
 Commonwealth of Pennsylvania
 Harrisburg, Pennsylvania


 We have jointly audited, in accordance with the auditing standards generally accepted in the United States of
 America and the standards applicable to financial audits contained in Government Auditing Standards issued by
 the Comptroller General of the United States, the financial statements of the governmental activities, the business-
 type activities, the aggregate discretely presented component units, each major fund, and the aggregate remaining
 fund information of the Commonwealth of Pennsylvania (the Commonwealth), as of and for the year ended June
 30, 2021, and the related notes to the financial statements, which collectively comprise the Commonwealth’s
 basic financial statements, and have issued our report thereon dated December 10, 2021. Our report includes a
 reference to other auditors, including CliftonLarsonAllen LLP and the Commonwealth of Pennsylvania’s
 Department of the Auditor General acting separately, who audited the financial statements of certain funds and
 component units of the Commonwealth, which represent the indicated percent of assets and deferred outflows of
 resources and revenues or additions as presented in the table below and as described in our report on the
 Commonwealth’s financial statements. This report does not include the results of the other auditors’ testing of
 internal control over financial reporting or compliance and other matters that are reported on separately by those
 auditors.

                                                                                                   Percent of Opinion Unit's Total

         Opinion Unit                                      Entity                                Assets / Deferred
                                                                                                                       Revenues /
                                                                                                    Outflow of
                                                                                                                       Additions
                                                                                                    Resources
  Business-Type Activities    Tuition Payment Fund; State Stores Fund; Commonwealth Financing          52%                 9%
                                         Authority; Philadelphia Regional Port Authority
  Major Proprietary Fund                             Tuition Payment Fund                             100%                 100%
  Major Proprietary Fund                                State Stores Fund                             100%                 100%
  Major Proprietary Fund                      Commonwealth Financing Authority                        100%                 100%
  Aggregate Discretely        Pennsylvania Turnpike Commission; Pennsylvania Housing Finance          100%                 100%
  Presented Component Units       Agency; Pennsylvania Higher Education Assistance Agency;
                               Pennsylvania Infrastructure Investment Authority; State System of
                                    Higher Education; State Public School Building Authority;
                               Philadelphia Shipyard Development Corporation; Port of Pittsburgh
                                 Commission; Pennsylvania Industrial Development Authority;
                                 Pennsylvania Convention Center Authority; Thaddeus Stevens
                               College of Technology; Pennsylvania Higher Educational Facilities
                                Authority, Pennsylvania Rural Health Redesign Center Authority,
                                       Pennsylvania Health Insurance Exchange Authority




                                                                    12
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania



                                                                                                 Percent of Opinion Unit's Total
       Opinion Unit                                     Entity                                 Assets / Deferred
                                                                                                                    Revenues /
                                                                                                  Outflow of
                                                                                                                    Additions
                                                                                                  Resources
Aggregate Remaining Fund   Philadelphia Regional Port Authority; State Employees' Retirement         92%                77%
Information                 System; Deferred Compensation Fund; Public School Employees'
                           Retirement System; Tuition Account Investment Program; INVEST
                                                       Program

The financial statements of the State System of Higher Education, State Employees’ Retirement System, the
Deferred Compensation Fund, the Public School Employees’ Retirement System, the Pennsylvania Higher
Education Assistance Agency, the Pennsylvania Higher Educational Facilities Authority, the State Public School
Building Authority, the Port of Pittsburgh Commission, the Pennsylvania Turnpike Commission, the
Pennsylvania Rural Health Redesign Center Authority and the Philadelphia Regional Port Authority were not
audited in accordance with Government Auditing Standards.

Internal Control Over Financial Reporting
In planning and performing our audit of the financial statements, we considered the Commonwealth's internal
control over financial reporting (internal control) as a basis for designing audit procedures that are appropriate in
the circumstances for the purpose of expressing our opinions on the financial statements, but not for the purpose
of expressing an opinion on the effectiveness of the Commonwealth’s internal control. Accordingly, we do not
express an opinion on the effectiveness of the Commonwealth’s internal control.

A deficiency in internal control exists when the design or operation of a control does not allow management or
employees, in the normal course of performing their assigned functions, to prevent, or detect and correct,
misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal
control such that there is a reasonable possibility that a material misstatement of the entity’s financial statements
will not be prevented, or detected and corrected on a timely basis. A significant deficiency is a deficiency, or a
combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough
to merit attention by those charged with governance.

Our consideration of internal control was for the limited purpose described in the first paragraph of this section
and was not designed to identify all deficiencies in internal control that might be material weaknesses or
significant deficiencies and therefore, material weaknesses or significant deficiencies may exist that have not been
identified. Given these limitations, during our audit we did not identify any deficiencies in internal control that we
consider to be material weaknesses. We did identify certain deficiencies in internal control, described in the
accompanying findings and questioned costs as items 2021-001 and 2021-002 that we consider to be significant
deficiencies.

Compliance and Other Matters
As part of obtaining reasonable assurance about whether the Commonwealth's financial statements are free from
material misstatement, we performed tests of its compliance with certain provisions of laws, regulations,
contracts, and grant agreements, noncompliance with which could have a direct and material effect on the
financial statements. However, providing an opinion on compliance with those provisions was not an objective of
our audit, and accordingly, we do not express such an opinion. The results of our tests disclosed no instances of
noncompliance or other matters that are required to be reported under Government Auditing Standards.




                                                                 13
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania



Commonwealth’s Response to Findings
The Commonwealth’s responses to the findings identified in our audit are described in the accompanying
schedule of findings and questioned costs. The Commonwealth’s responses were not subjected to the auditing
procedures applied in the audit of the financial statements and, accordingly, we express no opinion on them.

Purpose of this Report
The purpose of this report is solely to describe the scope of our testing of internal control and compliance and the
results of that testing, and not to provide an opinion on the effectiveness of the Commonwealth’s internal control
or on compliance. This report is an integral part of an audit performed in accordance with Government Auditing
Standards in considering the Commonwealth’s internal control and compliance. Accordingly, this communication
is not suitable for any other purpose.




Harrisburg, Pennsylvania                                          Baltimore, Maryland
December 10, 2021                                                 December 10, 2021




                                                        14
                                                                                         CliftonLarsonAllen LLP
                                                                                         CLAconnect.com



Department of the Auditor General
 Commonwealth of Pennsylvania
Harrisburg, Pennsylvania 17120-0018




         Independent Auditors’ Report on Compliance for Each Major Federal Program; Report on
       Internal Control Over Compliance; and Report on Schedule of Expenditures of Federal Awards
                                   Required by the Uniform Guidance



     The Honorable Tom Wolf, Governor
     Commonwealth of Pennsylvania
     Harrisburg, Pennsylvania


     Report on Compliance for Each Major Federal Program

     We have jointly audited the Commonwealth of Pennsylvania’s (Commonwealth) compliance with the types
     of compliance requirements described in the OMB Compliance Supplement that could have a direct and
     material effect on each of the Commonwealth’s major federal programs for the year ended June 30, 2021.
     The Commonwealth’s major federal programs are identified in the summary of auditors’ results section of
     the accompanying schedule of findings and questioned costs.

     The Commonwealth’s basic financial statements include the operations of the State System of Higher
     Education, the Pennsylvania Higher Education Assistance Agency, the Philadelphia Shipyard Development
     Corporation, the Pennsylvania Housing Finance Agency, the Philadelphia Regional Port Authority, the
     Pennsylvania Convention Center Authority, the Commonwealth Financing Authority, and the Judicial
     Department of Pennsylvania, which received approximately $5.1 billion in federal awards and $18.2 billion
     of federal loan guarantees that are not included in the schedule of expenditures of federal awards for the
     year ended June 30, 2021. Our audit, described below, did not include the operations of these eight entities
     because other auditors were engaged to perform audits (when required) in accordance with the Uniform
     Guidance.

     Management’s Responsibility

     Management is responsible for compliance with federal statutes, regulations, and the terms and conditions
     of its federal awards applicable to its federal programs.

     Auditors’ Responsibility

     Our responsibility is to express an opinion on compliance for each of the Commonwealth’s major federal
     programs based on our audit of the types of compliance requirements referred to above. We conducted




                                                         15
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania



our audit of compliance in accordance with auditing standards generally accepted in the United States of
America; the standards applicable to financial audits contained in Government Auditing Standards, issued
by the Comptroller General of the United States; and the audit 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). Those standards and the Uniform Guidance require that we plan and
perform the audit to obtain reasonable assurance about whether noncompliance with the types of
compliance requirements referred to above that could have a direct and material effect on a major federal
program occurred. An audit includes examining, on a test basis, evidence about the Commonwealth’s
compliance with those requirements and performing such other procedures as we considered necessary in
the circumstances.

We believe that our audit provides a reasonable basis for our qualified and unmodified opinions on
compliance for major federal programs. However, our audit does not provide a legal determination of the
Commonwealth’s compliance.

Basis for Qualified Opinion on the 9 Major Federal Programs Identified in the Following Table

As identified in the following table and as described in the accompanying schedule of findings and
questioned costs, the Commonwealth did not comply with requirements regarding the following:


 State Administering      Finding       Assistance             Federal                 Compliance
       Agency             Number          Listing          Program/Cluster             Requirement
                                         Number
                                       (C = COVID-
                                            19)

 Department of            2021-004     15.252            Abandoned Mine          Subrecipient Monitoring
 Environmental                                           Land Reclamation
 Protection
 Department of            2021-005     10.551 – C        Supplemental            Special Tests and
 Human Services                        10.561            Nutrition Assistance    Provisions related to
                                                         Program (SNAP)          Electronic Benefits
                                                         Cluster                 Transfer (EBT) Card
                                                                                 Security
                                       93.558            Temporary
                                                         Assistance for Needy
                                                         Families
 Department of            2021-008     93.558            Temporary               Subrecipient Monitoring
 Human Services                                          Assistance for Needy
                                                         Families
                                       93.658 – C        Foster Care – Title
                                                         IV-E
                                       93.659 – C        Adoption Assistance




                                                    16
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania



 State Administering       Finding       Assistance             Federal                   Compliance
       Agency              Number          Listing          Program/Cluster               Requirement
                                          Number
                                        (C = COVID-
                                             19)

 Various Agencies          2021-015     15.252            Abandoned Mine            Subrecipient Monitoring
                                                          Land Reclamation
                                        16.575            Crime Victim
                                                          Assistance
                                        93.558            Temporary
                                                          Assistance for Needy
                                                          Families
                                        93.563            Child Support
                                                          Enforcement
                                        93.575 – C        Child Care and
                                        93.596            Development Fund
                                                          (CCDF) Cluster
                                        93.658 – C        Foster Care – Title
                                                          IV-E
                                        93.659 – C        Adoption Assistance

                                        97.036 – C        Disaster Grants –
                                                          Public Assistance
                                                          (Presidentially
                                                          Declared Disasters)


Compliance with such requirements is necessary, in our opinion, for the Commonwealth to comply with
the requirements applicable to those programs.

Qualified Opinion on the 9 Major Federal Programs Identified Above

In our opinion, except for the noncompliance described in the Basis for Qualified Opinion paragraph, the
Commonwealth complied, in all material respects, with the types of compliance requirements referred to
above that could have a direct and material effect on the identified major federal programs for the year
ended June 30, 2021.

Unmodified Opinion on Each of the Other Major Federal Programs

In our opinion, the Commonwealth complied, in all material respects, with the types of compliance
requirements referred to above that could have a direct and material effect on each of its other major federal
programs identified in the summary of auditors’ results section of the accompanying schedule of findings
and questioned costs for the year ended June 30, 2021.




                                                     17
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania




Other Matters

The results of our auditing procedures disclosed other instances of noncompliance, which are required to
be reported in accordance with the Uniform Guidance and which are identified in the following table and
described in the accompanying schedule of findings and questioned costs. Our opinion on each major
federal program is not modified with respect to these matters.


 State Administering      Finding      Assistance            Federal                   Compliance
       Agency             Number         Listing         Program/Cluster               Requirement
                                        Number
                                      (C = COVID-
                                           19)

 Department of           2021-003    84.425 – C         Education                Reporting
 Education                                              Stabilization Fund
 Department of           2021-006    21.023 – C         Emergency Rental         Reporting
 Human Services                                         Assistance Program
 Department of           2021-007    93.558             Temporary                Subrecipient Monitoring
 Human Services                                         Assistance for Needy
                                                        Families
 Department of           2021-009     93.775            Medicaid Cluster         Special Tests and
 Human Services                       93.777 – C                                 Provisions related to the
                                      93.778 – C                                 Medicaid National
                                                                                 Correct Coding Initiative
                                                                                 (NCCI)
 Department of           2021-010     93.775            Medicaid Cluster         Special Tests and
 Human Services                       93.777 – C                                 Provisions related to the
                                      93.778 – C                                 Managed Care Financial
                                                                                 Audit
 Department of Labor     2021-011    17.225 – C         Unemployment             Eligibility
 and Industry                                           Insurance
                                      97.050 – C        Presidential Declared
                                                        Disaster Assistance to
                                                        Individuals and
                                                        Households – Other
                                                        Needs




                                                   18
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania




 State Administering       Finding       Assistance            Federal                  Compliance
       Agency              Number          Listing         Program/Cluster              Requirement
                                          Number
                                        (C = COVID-
                                             19)

 Various Agencies         2021-014     20.205 – C        Highway Planning         Subrecipient Monitoring
                                       20.219            and Construction
                                                         Cluster
                                       93.558            Temporary
                                                         Assistance for Needy
                                                         Families
                                       93.658 – C        Foster Care – Title
                                                         IV-E
                                       93.659 – C        Adoption Assistance

 Department of            2021-015     93.775            Medicaid Cluster         Subrecipient Monitoring
 Human Services                        93.777 – C
                                       93.778 – C


The Commonwealth’s responses to the noncompliance findings identified in our audit are described in the
accompanying schedule of findings and questioned costs. The Commonwealth’s responses were not
subjected to the auditing procedures applied in the audit of compliance and, accordingly, we express no
opinion on the responses.

Report on Internal Control Over Compliance

Management of the Commonwealth is responsible for establishing and maintaining effective internal
control over compliance with the types of compliance requirements referred to above. In planning and
performing our audit of compliance, we considered the Commonwealth’s internal control over compliance
with the types of requirements that could have a direct and material effect on each major federal program
to determine the auditing procedures that are appropriate in the circumstances for the purpose of expressing
an opinion on compliance for each major federal program and to test and report on internal control over
compliance in accordance with the Uniform Guidance, but not for the purpose of expressing an opinion on
the effectiveness of internal control over compliance. Accordingly, we do not express an opinion on the
effectiveness of the Commonwealth’s internal control over compliance.
Our consideration of internal control over compliance was for the limited purpose described in the
preceding paragraph and was not designed to identify all deficiencies in internal control over compliance
that might be material weaknesses or significant deficiencies and therefore, material weaknesses or
significant deficiencies may exist that have not been identified. However, as discussed below, we did
identify certain deficiencies in internal control over compliance that we consider to be material weaknesses
and significant deficiencies.




                                                    19
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania




A deficiency in internal control over compliance exists when the design or operation of a control over
compliance does not allow management or employees, in the normal course of performing their assigned
functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a
federal program on a timely basis. A material weakness in internal control over compliance is a deficiency,
or a combination of deficiencies, in internal control over compliance, such that there is a reasonable
possibility that material noncompliance with a type of compliance requirement of a federal program will
not be prevented, or detected and corrected, on a timely basis. We consider the deficiencies in internal
control over compliance described in the accompanying schedule of findings and questioned costs as items
2021-004, 2021-005, 2021-008, and 2021-015 to be material weaknesses.

A significant deficiency in internal control over compliance is a deficiency, or a combination of
deficiencies, in internal control over compliance with a type of compliance requirement of a federal program
that is less severe than a material weakness in internal control over compliance, yet important enough to
merit attention by those charged with governance. We consider the deficiencies in internal control over
compliance described in the accompanying schedule of findings and questioned costs as items 2021-003,
2021-006, 2021-007, 2021-009, 2021-010, 2021-011, 2021-012, 2021-013, 2021-014, and 2021-015 to be
significant deficiencies.

The Commonwealth’s responses to the internal control over compliance findings identified in our audit are
described in the accompanying schedule of findings and questioned costs. The Commonwealth’s responses
were not subjected to the auditing procedures applied in the audit of compliance and, accordingly, we
express no opinion on the responses.

The purpose of this report on internal control over compliance is solely to describe the scope of our testing
of internal control over compliance and the results of that testing based on the requirements of the Uniform
Guidance. Accordingly, this report is not suitable for any other purpose.

Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance

We have jointly audited the financial statements, issued under separate cover, of the governmental
activities, the business-type activities, the aggregate discretely presented component units, each major fund,
and the aggregate remaining fund information of the Commonwealth as of and for the year ended June 30,
2021, and the related notes to the financial statements, which collectively comprise the Commonwealth’s
basic financial statements. We issued our report thereon dated December 10, 2021, which includes a
reference to other auditors and contained unmodified opinions on those financial statements. Our audit was
conducted for the purpose of forming opinions on the financial statements that collectively comprise the
basic financial statements. The accompanying schedule of expenditures of federal awards is presented for
purposes of additional analysis as required by the Uniform Guidance and is not a required part of the basic
financial statements. Such information is the responsibility of management and was derived from and
relates directly to the underlying accounting and other records used to prepare the basic financial statements.




                                                      20
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania




The information has been subjected to the auditing procedures applied in the audit of the basic financial
statements and certain additional procedures, including comparing and reconciling such information
directly to the underlying accounting and other records used to prepare the basic financial statements or to
the basic financial statements themselves, and other additional procedures in accordance with auditing
standards generally accepted in the United States of America. In our opinion, the schedule of expenditures
of federal awards is fairly stated in all material respects in relation to the basic financial statements as a
whole.




                                                           a
Harrisburg, Pennsylvania                                   Baltimore, Maryland
March 18, 2022                                             March 18, 2022




                                                     21
THIS PAGE INTENTIONALLY LEFT BLANK




                 22
Schedule of Expenditures
   of Federal Awards




   Commonwealth of Pennsylvania




                23
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                                    Passed
                                                                                                                                                                    Federal       Through to
      Assistance                                                                                                                                                  Expenditures   Subrecipients
      Listing #     Assistance Listing Program Name                                                                                                                  (000's)        (000's)

      U.S. Department of Agriculture
                   SNAP Cluster:                                                                                                                  `
        10.551     Supplemental Nutrition Assistance Program                                                                          2,768,077
        10.551     COVID-19 - Supplemental Nutrition Assistance Program                                                               2,083,766
                      Total Supplemental Nutrition Assistance Program                                                                                 4,851,843
        10.561     State Administrative Matching Grants for Supplemental Nutrition Assistance Program                                                   194,812                         21,577
                         Total SNAP Cluster                                                                                                                          5,046,655

                    Child Nutrition Cluster:
       10.553       School Breakfast Program                                                                                            64,721                                          64,582
       10.553       COVID-19 - School Breakfast Program                                                                                 37,620                                          37,620
                       Total School Breakfast Program                                                                                                  102,341
       10.555       National School Lunch Program (Cash Assistance)                                                                    173,412                                         173,160
       10.555       COVID-19 - National School Lunch Program (Cash Assistance)                                                          83,383                                          83,383
24     10.555       National School Lunch Program (Food Commodities)                                                                    48,292                                          48,292
                       Total National School Lunch Program                                                                                             305,087
       10.556       Special Milk Program for Children                                                                                       24                                                 24
       10.556       COVID-19 - Special Milk Program for Children                                                                            13                                                 13
                       Total Special Milk Program for Children                                                                                              37
       10.559       Summer Food Service Program for Children (Cash Assistance)                                                         124,441                                         123,998
       10.559       COVID-19 - Summer Food Service Program for Children (Cash Assistance)                                               41,647                                          41,647
       10.559       Summer Food Service Program for Children (Food Commodities)                                                            587                                             587
                       Total Summer Food Service Program for Children                                                                                  166,675
       10.579       Child Nutrition Discretionary Grants Limited Availability                                                                            1,130                           1,130
                          Total Child Nutrition Cluster                                                                                                                575,270

                    Food Distribution Cluster:
       10.565       Commodity Supplemental Food Program (Cash Assistance)                                                                3,719                                           3,715
       10.565       Commodity Supplemental Food Program (Food Commodities)                                                               8,045                                           8,045
                      Total Commodity Supplemental Food Program                                                                                         11,764
       10.568       Emergency Food Assistance Program (Administrative Costs)                                                             4,928                                           3,668
       10.568       COVID-19 - Emergency Food Assistance Program (Administrative Costs)                                                  5,539                                           5,539
                      Total Emergency Food Assistance Program (Administrative Costs)                                                                    10,467
       10.569       Emergency Food Assistance Program (Food Commodities)                                                                                78,416                          78,416
                         Total Food Distribution Cluster                                                                                                               100,647

                    Forest Service Schools and Roads Cluster:
       10.665       Schools and Roads - Grants to States                                                                                                                 2,642           2,642



                                                                        - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                   Passed
                                                                                                                                                 Federal         Through to
      Assistance                                                                                                                               Expenditures     Subrecipients
      Listing #    Assistance Listing Program Name                                                                                                (000's)          (000's)

       10.025        Plant and Animal Disease, Pest Control, and Animal Care                                                                          6,946               260
       10.170        Specialty Crop Block Grant Program - Farm Bill                                                                                   1,335             1,188
       10.171        Organic Certification Cost Share Programs                                                                                          176
       10.178        Trade Mitigation Program Eligible Recipient Agency Operational Funds                                                             1,180             1,180
       10.304        Homeland Security - Agricultural                                                                                                   143
       10.534        Child and Adult Care Food Program (CACFP) Meal Training Grants                                                                      32
       10.541        Child Nutrition- Technology Innovation Grant                                                                                       124
       10.545        Farmers’ Market SNAP Support Grants                                                                                                  2
       10.557        WIC Special Supplemental Nutrition Program for Women, Infants, and Children                                     105,729                           37,263
       10.557        COVID-19 - WIC Special Supplemental Nutrition Program for Women, Infants, and Children                           15,197                            4,000
                        Total WIC Special Supplemental Nutrition Program for Women, Infants, and Children                                           120,926
        10.558       Child and Adult Care Food Program (Cash Assistance)                                                              52,547                           51,641
        10.558       COVID-19 - Child and Adult Care Food Program (Cash Assistance)                                                   25,980                           25,980
        10.558       Child and Adult Care Food Program (Food Commodities)                                                                 76                               76
25                      Total Child and Adult Care Food Program                                                                                      78,603
        10.560       State Administrative Expenses for Child Nutrition                                                                                9,932                 318
        10.572       WIC Farmers' Market Nutrition Program (FMNP)                                                                                     1,190                 213
        10.574       Team Nutrition Grants                                                                                                               31
        10.575       Farm to School Grant Program                                                                                                        55
        10.576       Senior Farmers Market Nutrition Program                                                                                          1,028
        10.578       WIC Grants to States (WGS)                                                                                                       2,153               512
        10.582       Fresh Fruit and Vegetable Program                                                                                                3,043             3,043
        10.649       COVID-19 - Pandemic EBT Administrative Costs                                                                                       342
        10.664       Cooperative Forestry Assistance                                                                                                    257
        10.675       Urban and Community Forestry Program                                                                                                 1
        10.676       Forest Legacy Program                                                                                                                7                     7
        10.678       Forest Stewardship Program                                                                                                           7
        10.680       Forest Health Protection                                                                                                           589                   12
        10.691       Good Neighbor Authority                                                                                                              3
        10.698       State & Private Forestry Cooperative Fire Assistance                                                                             1,392                 678
      Passed through: National Fish and Wildlife Foundation
        10.902       Soil And Water Conservation (Award ID 060217057473)                                                                                   43
       10.931       Agricultural Conservation Easement Program                                                                                          257

                    Total - U.S. Department of Agriculture                                                                                       $5,955,011          $824,409




                                                                       - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                Passed
                                                                                                                                                Federal       Through to
      Assistance                                                                                                                              Expenditures   Subrecipients
      Listing #    Assistance Listing Program Name                                                                                               (000's)        (000's)

      U.S. Department of Commerce
                   Economic Development Cluster
        11.307     Economic Adjustment Assistance                                                                                                      240

       11.407       Interjurisdictional Fisheries Act of 1986                                                                                           22
       11.419       Coastal Zone Management Administration Awards                                                                                    1,728               723
       11.474       Atlantic Coastal Fisheries Cooperative Management Act                                                                               13

                    Total - U.S. Department of Commerce                                                                                             $2,003            $723

      U.S. Department of Defense
        12.112     Payments to States in Lieu of Real Estate Taxes                                                                                     401               401
        12.400     Military Construction, National Guard                                                                                             5,066
        12.401     National Guard Military Operations and Maintenance (O&M) Projects                                                 69,997
26      12.401     COVID-19 - National Guard Military Operations and Maintenance (O&M) Projects                                       1,207
                      Total National Guard Military Operations and Maintenance (O&M) Projects                                                       71,204
        12.404     National Guard Challenge Program                                                                                                  1,335
        12.617     Economic Adjustment Assistance for State Governments                                                                              1,031               924
        12.620     Troops to Teachers Grant Program                                                                                                     71

                    Total - U.S. Department of Defense                                                                                             $79,108          $1,325

      U.S. Department of Housing and Urban Development
                   CDBG - Disaster Recovery Grants - Pub. L. No. 113-2 Cluster:
        14.269     Hurricane Sandy Community Development Block Grant Disaster Recovery Grants                                                        3,444           3,362

       14.228       Community Development Block Grants/State's Program                                                               39,379                         38,343
       14.228       COVID-19 - Community Development Block Grants/State's Program                                                     2,667                          2,313
                       Total Community Development Block Grants/State's Program                                                                     42,046
       14.231       Emergency Solutions Grant Program                                                                                 5,566                          5,313
       14.231       COVID-19 - Emergency Solutions Grant Program                                                                      5,232                          4,943
                       Total Emergency Solutions Grant Program                                                                                      10,798
       14.239       Home Investment Partnerships Program                                                                                             9,277           8,279
       14.241       Housing Opportunities for Persons with AIDS                                                                       2,290                          2,287
       14.241       COVID-19 - Housing Opportunities for Persons with AIDS                                                              391                            391
                       Total Housing Opportunities for Persons with AIDS                                                                             2,681
       14.267       Continuum of Care Program                                                                                                          828
       14.401       Fair Housing Assistance Program - State and Local                                                                                  371


                                                                       - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                Passed
                                                                                                                                                Federal       Through to
      Assistance                                                                                                                              Expenditures   Subrecipients
      Listing #    Assistance Listing Program Name                                                                                               (000's)        (000's)
       14.900      Lead-Based Paint Hazard Control in Privately-Owned Housing                                                                          377               340

                    Total - U.S. Department of Housing and Urban Development                                                                       $69,822         $65,571

      U.S. Department of the Interior
                   Fish and Wildlife Cluster:
        15.605     Sport Fish Restoration                                                                                             8,648
        15.611     Wildlife Restoration and Basic Hunter Education                                                                   25,000
                         Total Fish and Wildlife Cluster                                                                                            33,648

       15.250       Regulation of Surface Coal Mining and Surface Effects of Underground Coal Mining                                                12,046              15
       15.252       Abandoned Mine Land Reclamation (AMLR)                                                                                          57,712           8,783
       15.433       Flood Control Act Lands                                                                                                              5               5
       15.608       Fish and Wildlife Management Assistance                                                                                             66
       15.615       Cooperative Endangered Species Conservation Fund                                                                                   167
27     15.634       State Wildlife Grants                                                                                                            1,540
       15.667       Highlands Conservation                                                                                                             693
       15.808       U.S. Geological Survey - Research and Data Collection                                                                               19
       15.810       National Cooperative Geologic Mapping                                                                                               79
       15.904       Historic Preservation Fund Grants-In-Aid                                                                                         2,010               126
       15.916       Outdoor Recreation Acquisition, Development and Planning                                                                           839               831
       15.925       National Maritime Heritage Grants                                                                                                   10                10
       15.928       Battlefield Land Acquisition Grants                                                                                                948               948
       15.957       Emergency Supplemental Historic Preservation Fund                                                                                  186
       15.981       Water Use and Data Research                                                                                                         34

                    Total - U.S. Department of the Interior                                                                                       $110,002         $10,718

      U.S. Department of Justice
        16.004     Law Enforcement Assistance - Narcotics and Dangerous Drugs Training                                                               2,462
        16.017     Sexual Assault Services Formula Program                                                                                             582             582
        16.034     COVID-19 - Coronavirus Emergency Supplemental Funding Program                                                                    10,395           5,285
        16.321     Antiterrorism Emergency Reserve                                                                                                   1,854           1,854
        16.540     Juvenile Justice and Delinquency Prevention                                                                                         552             399
        16.550     State Justice Statistics Program for Statistic Analysis Centers                                                                     233
        16.554     National Criminal History Improvement Program (NCHIP)                                                                             2,121             388
        16.575     Crime Victim Assistance                                                                                                          83,352          79,847
        16.576     Crime Victim Compensation                                                                                                         4,168
        16.582     Crime Victim Assistance/Discretionary Grants                                                                                        217



                                                                       - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                 Passed
                                                                                                                                                Federal        Through to
      Assistance                                                                                                                              Expenditures    Subrecipients
      Listing #    Assistance Listing Program Name                                                                                               (000's)         (000's)
       16.588      Violence Against Women Formula Grants                                                                                             4,843            4,469
       16.593      Residential Substance Abuse Treatment for State Prisoners                                                                           372              134
       16.606      State Criminal Alien Assistance Program                                                                                           1,639
       16.609      Project Safe Neighborhoods                                                                                                          598                278
       16.710      Public Safety Partnership and Community Policing Grants                                                                           1,623
       16.734      Special Data Collections and Statistical Studies                                                                                    138              131
       16.738      Edward Byrne Memorial Justice Assistance Grant Program                                                                            5,778            3,756
       16.741      DNA Backlog Reduction Program                                                                                                     1,004
       16.742      Paul Coverdell Forensic Sciences Improvement Grant Program                                                                          815                417
       16.745      Criminal and Juvenile Justice and Mental Health Collaboration Program                                                                 3
       16.750      Support for Adam Walsh Act Implementation Grant Program                                                                             256
       16.752      Economic, High-Tech, and Cyber Crime Prevention                                                                                      26
       16.754      Harold Rogers Prescription Drug Monitoring Program                                                                                  666                  59
       16.812      Second Chance Act Reentry Initiative                                                                                                348                  16
       16.813      NICS Act Record Improvement Program                                                                                                 144
28     16.816      John R. Justice Prosecutors and Defenders Incentive Act                                                                              56
       16.825      Smart Prosecution Initiative                                                                                                        192                136
       16.827      Justice Reinvestment Initiative                                                                                                      (2)                (2)
       16.835      Body Worn Camera Policy and Implementation                                                                                          514                516
       16.838      Comprehensive Opioid Abuse Site-Based Program                                                                                       578                565
       16.839      STOP School Violence                                                                                                                 60                 59
       16.922      Equitable Sharing Program                                                                                                           196

                    Total - U.S. Department of Justice                                                                                            $125,783          $98,889
      U.S. Department of Labor
                   Employment Service Cluster:
        17.207     Employment Service/Wagner-Peyser Funded Activities                                                                22,491
        17.801     Jobs for Veterans State Grants                                                                                     5,966
                          Total Employment Service Cluster                                                                                          28,457

                    WIOA Cluster:
       17.258       WIOA Adult Program                                                                                               28,349                          25,072
       17.259       WIOA Youth Activities                                                                                            30,851                          29,082
       17.278       WIOA Dislocated Worker Formula Grants                                                                            52,012                          46,608
                        Total WIOA Cluster                                                                                                         111,212

       17.002       Labor Force Statistics                                                                                                           2,388
       17.005       Compensation and Working Conditions                                                                                                300



                                                                       - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                                  Passed
                                                                                                                                                                  Federal       Through to
      Assistance                                                                                                                                                Expenditures   Subrecipients
      Listing #    Assistance Listing Program Name                                                                                                                 (000's)        (000's)

       17.225       Unemployment Insurance                                                                                                          5,271,655                              366
       17.225       COVID-19 - Unemployment Insurance                                                                                              23,321,031
                       Total Unemployment Insurance                                                                                                               28,592,686
       17.235       Senior Community Service Employment Program                                                                                                        3,962           3,835
       17.245       Trade Adjustment Assistance                                                                                                                       23,639           8,205
       17.271       Work Opportunity Tax Credit Program (WOTC)                                                                                                         1,122
       17.273       Temporary Labor Certification for Foreign Workers                                                                                                    386
       17.277       WIOA National Dislocated Worker Grants / WIA National Emergency Grants                                                              2,116                          2,086
       17.277       COVID-19 - WIOA National Dislocated Worker Grants / WIA National Emergency Grants                                                     498                            460
                       Total WIOA National Dislocated Worker Grants / WIA National Emergency Grants                                                                    2,614
       17.280       WIOA Dislocated Worker National Reserve Demonstration Grants                                                                                       1,544           1,438
       17.285       Apprenticeship USA Grants                                                                                                                          1,192             597
       17.600       Mine Health and Safety Grants                                                                                                                        420

29                  Total - U.S. Department of Labor                                                                                                             $28,769,922        $117,749

      U.S. Department of Transportation
                   Highway Planning and Construction Cluster:
        20.205     Highway Planning and Construction                                                                                   1,914,213                                     158,348
        20.205     COVID-19 - Highway Planning and Construction                                                                          407,152
                      Total Highway Planning and Construction                                                                                       2,321,365
        20.219     Recreational Trails Program                                                                                                          2,515                          2,288
                          Total Highway Planning and Construction Cluster                                                                                          2,323,880

                    Federal Motor Carrier Safety Assistance Cluster:
       20.218       Motor Carrier Safety Assistance                                                                                                                    8,325

                    Federal Transit Cluster:
       20.500       Federal Transit - Capital Investment Grants                                                                                        1,027                             310
       20.507       Federal Transit - Formula Grants                                                                                                  21,525                           1,349
       20.525       State of Good Repair Grants Program                                                                                                4,793                           3,858
                           Total Federal Transit Cluster                                                                                                              27,345

                    Transit Services Programs Cluster:
       20.513       Enhanced Mobility of Seniors & Individuals with Disabilities                                                                                      10,355           9,939

                    Research and Development Cluster:
       20.530       Public Transportation Innovation (Award ID PA202005800)                                                                                              178               178



                                                                         - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                               Passed
                                                                                                                                               Federal       Through to
      Assistance                                                                                                                             Expenditures   Subrecipients
      Listing #    Assistance Listing Program Name                                                                                              (000's)        (000's)

                   Highway Safety Cluster:
       20.600      State and Community Highway Safety                                                                               12,730                          5,862
       20.616      National Priority Safety Programs                                                                                 5,873                          3,589
                          Total Highway Safety Cluster                                                                                             18,603

       20.106      Airport Improvement Program                                                                                      17,041                         16,623
       20.106      COVID-19 - Airport Improvement Program                                                                            2,057                          2,057
                      Total Airport Improvement Program                                                                                            19,098
       20.200      Highway Research and Development Program                                                                                           357                 11
       20.215      Highway Training and Education                                                                                                      72
       20.232      Commercial Driver's License Program Implementation Grant                                                                           367
       20.240      Fuel Tax Evasion-Intergovernmental Enforcement Effort                                                                               69
       20.505      Metropolitan Trans Planning & State & Non-Metropolitan Planning & Research                                                       5,188
       20.509      Formula Grants for Rural Areas and Tribal Transit Program                                                        25,946                         25,487
30     20.509      COVID-19 - Formula Grants for Rural Areas and Tribal Transit Program                                             36,054                         36,054
                      Total Formula Grants for Rural Areas and Tribal Transit Program                                                              62,000
       20.520      Paul S. Sarbanes Transit in the Parks                                                                                               55                 55
       20.528      Rail Fixed Guideway Public Trans. System State Safety Oversight Form. Grant Program                                                741
       20.614      National Highway Traffic Safety Admin Discretionary Safety Grants & Cooperative Agreements                                         164
       20.615      E-911 Grant Program                                                                                                              2,120
       20.700      Pipeline Safety Program State Base Grant                                                                                         2,212
       20.703      Interagency Hazardous Materials Training and Planning Grants                                                                       551             155
       20.933      National Infrastructure Investments                                                                                              9,682           7,659

                   Total - U.S. Department of Transportation                                                                                   $2,491,362        $273,822

      U.S. Department of the Treasury
        21.016     Equitable Sharing                                                                                                                  431
        21.019     COVID-19 - Coronavirus Relief Fund                                                                                           2,764,742         823,479
        21.023     COVID-19 - Emergency Rental Assistance Program                                                                                 564,535         564,110

                   Total - U.S. Department of the Treasury                                                                                     $3,329,708      $1,387,589

      Appalachian Regional Commission
       23.002      Appalachian Area Development                                                                                                       458               146

                   Total - Appalachian Regional Commission                                                                                           $458            $146



                                                                      - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                  Passed
                                                                                                                                                Federal         Through to
      Assistance                                                                                                                              Expenditures     Subrecipients
       Listing #  Assistance Listing Program Name                                                                                                (000's)          (000's)
      Equal Employment Opportunity Commission
        30.001    Employment Discrimination Title VII of the Civil Rights Act of 1964                                                                  549

                    Total - Equal Employment Opportunity Commission                                                                                   $549                   $0

      General Services Administration
       39.003       Donation of Federal Surplus Personal Property                                                                                      648                 648

                    Total - General Services Administration                                                                                           $648              $648

      National Foundation on the Arts and Humanities
       45.025      Promotion of the Arts - Partnership Agreements                                                                      800
       45.025      COVID-19 - Promotion of the Arts - Partnership Agreements                                                           517                                 517
                      Total Promotion of the Arts - Partnership Agreements                                                                           1,317
       45.310      Grants to States                                                                                                   4,489                            2,602
31     45.310      COVID-19 - Grants to States                                                                                          134                              132
                      Total Grants to States                                                                                                         4,623
       45.312      COVID-19 - National Leadership Grants                                                                                                82

                    Total - National Foundation on the Arts and Humanities                                                                          $6,022            $3,251

      National Science Foundation
       47.076       Education and Human Resources                                                                                                         15

                    Total - National Science Foundation                                                                                                $15                   $0

      Small Business Administration
       59.061       State Trade Expansion                                                                                                              182

                    Total - Small Business Administration                                                                                             $182                   $0

      U.S. Department of Veterans Affairs
        64.010     Veterans Nursing Home Care                                                                                                          113
        64.014     Veterans State Domiciliary Care                                                                                    3,895
        64.014     COVID-19 - Veterans State Domiciliary Care                                                                            54
                      Total Veterans State Domiciliary Care                                                                                          3,949
        64.015     Veterans State Nursing Home Care                                                                                  47,749
        64.015     COVID-19 - Veterans State Nursing Home Care                                                                       11,092
                      Total Veterans State Nursing Home Care                                                                                        58,841



                                                                       - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                   Passed
                                                                                                                                                   Federal       Through to
      Assistance                                                                                                                                 Expenditures   Subrecipients
      Listing #     Assistance Listing Program Name                                                                                                 (000's)        (000's)
       64.111       Veterans Education Assistance                                                                                                       1,213

                     Total - U.S. Department of Veterans Affairs                                                                                      $64,116                 $0

      Environmental Protection Agency
                   Clean Water State Revolving Fund Cluster:
       66.458      Capitalization Grants for Clean Water State Revolving Funds                                                                         62,947          62,947

                     Drinking Water State Revolving Fund Cluster:
        66.468       Capitalization Grants for Drinking Water State Revolving Funds                                                                    32,328          23,408

        66.001       Air Pollution Control Program Support                                                                                              5,450
        66.032       State Indoor Radon Grants                                                                                                            462                 64
        66.034       Surveys, Studies, Research, Investigations, Demos & Special Purpose Activities - Clean Air Act                                       745
        66.040       Diesel Emissions Reduction Act (DERA) State Grants                                                                                   332               332
32      66.204       Multipurpose Grants to States and Tribes                                                                                             124
        66.419       Water Pollution Control State, Interstate, and Tribal Program Support                                                              6,003
        66.432       State Public Water System Supervision                                                                                              4,957
        66.441       Healthy Watersheds Consortium Grant Program                                                                                           57
        66.444       Lead Testing in School and Child Care Program Drinking Water                                                                         151
        66.454       Water Quality Management Planning                                                                                                    401
        66.460       Nonpoint Source Implementation Grants                                                                                              2,514           1,822
        66.461       Regional Wetland Program Development Grants                                                                                          248
        66.466       Chesapeake Bay Program                                                                                              8,226                          5,545
      Passed through: National Fish and Wildlife Foundation
        66.466       Chesapeake Bay Program (Award ID 060216053407)                                                                       165                               162
        66.466       Chesapeake Bay Program (Award ID 060217057473)                                                                       229
                        Total Chesapeake Bay Program                                                                                                    8,620
        66.469       Great Lakes Program                                                                                                                  275               176
        66.605       Performance Partnership Grants                                                                                                     1,037
        66.608       Environmental Information Exchange Network Grant Program and Related Assistance                                                      240
        66.801       Hazardous Waste Management State Program Support                                                                                   3,796
        66.804       Underground Storage Tank (UST) Prevention, Detection, and Compliance Program                                                         393
        66.805       Leaking Underground Storage Tank Trust Fund Corrective Action Program                                                              1,562
        66.817       State and Tribal Response Program Grants                                                                                             437

                     Total - Environmental Protection Agency                                                                                         $133,079         $94,456




                                                                           - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                   Passed
                                                                                                                                                   Federal       Through to
      Assistance                                                                                                                                 Expenditures   Subrecipients
      Listing #   Assistance Listing Program Name                                                                                                   (000's)        (000's)
      U.S. Department of Energy
        81.041     State Energy Program                                                                                                                 2,276             440
        81.042     Weatherization Assistance for Low-Income Persons                                                                                    14,661          11,541
        81.138     State Heating Oil & Propane Program                                                                                                      9

                    Total - U.S. Department of Energy                                                                                                 $16,946         $11,981

      U.S. Department of Education
                   Special Education Cluster (IDEA):
        84.027     Special Education - Grants to States                                                                                468,327                        454,815
        84.173     Special Education - Preschool Grants                                                                                 13,217                         12,702
                          Total Special Education Cluster (IDEA)                                                                                      481,544

                    TRIO Cluster:
       84.042       TRIO - Student Support Services                                                                                                       325
33
                    Student Financial Assistance Programs Cluster:
       84.007       Federal Supplemental Educational Opportunity Grants                                                                     63
       84.033       Federal Work-Study Program                                                                                               4
       84.063       Federal Pell Grant Program                                                                                           2,803
       84.268       Federal Direct Student Loans                                                                                         3,717
                          Total Student Financial Assistance Programs Cluster                                                                           6,587

       84.002       Adult Education - Basic Grants to States                                                                                           17,588          16,953
       84.010       Title I Grants to Local Educational Agencies                                                                                      642,312         626,405
       84.011       Migrant Education - State Grant Program                                                                                             5,291           4,866
       84.013       Title I State Agency Program for Neglected and Delinquent Children and Youth                                                        1,464           1,145
       84.048       Career and Technical Education - Basic Grants to States                                                                            41,674          39,482
       84.126       Rehabilitation Services - Vocational Rehabilitation Grants to States                                                              107,538
       84.144       Migrant Education - Coordination Program                                                                                               54                 54
       84.177       Rehabilitation Services - Independent Living Services for Older Individuals Who are Blind                                           1,266
       84.181       Special Education - Grants for Infants and Families                                                                                15,298          13,663
       84.187       Supported Employment Services for Individuals with the Most Significant Disabilities                                                  610
       84.196       Education for Homeless Children and Youth                                                                                           3,407           3,132
       84.287       Twenty-First Century Community Learning Centers                                                                                    51,267          48,493
       84.323       Special Education - State Personnel Development                                                                                     1,576           1,403
       84.358       Rural Education                                                                                                                     1,281           1,281
       84.365       English Language Acquisition State Grants                                                                                          15,320          14,543
       84.367       Supporting Effective Instruction State Grants                                                                                      74,665          71,320


                                                                         - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                             Passed
                                                                                                                                                             Federal       Through to
      Assistance                                                                                                                                           Expenditures   Subrecipients
      Listing #     Assistance Listing Program Name                                                                                                           (000's)        (000's)
        84.369      Grants for State Assessments and Related Activities                                                                                          10,955
        84.372      Statewide Longitudinal Data Systems                                                                                                           1,535
        84.377      Title I Grants to Local Educational Agencies                                                                                                  6,059           6,059
        84.424      Student Support and Academic Enrichment Program                                                                                              46,485          45,965
       84.425C      COVID-19 - Education Stabilization Fund - GEER Fund                                                                           63,927                         63,927
       84.425D      COVID-19 - Education Stabilization Fund - ESSER Fund                                                                         479,749                        479,713
       84.425E      COVID-19 - Education Stabilization Fund - HEERF Student Aid Portion                                                              136
       84.425F      COVID-19 - Education Stabilization Fund - HEERF Institutional Portion                                                            134
       84.425R      COVID-19 - Education Stabilization Fund - CRRSA EANS Program                                                                     833                              793
                       Total COVID-19 - Education Stabilization Fund                                                                                            544,779
        84.938      Disaster Recovery Assistance for Education                                                                                                      217               217

                     Total - U.S. Department of Education                                                                                                    $2,079,097      $1,906,931

      Elections Assistance Commission
        90.401       Help America Vote Act Requirements Payments                                                                                                  1,614             401
34
        90.404       2018 HAVA Election Security Grants                                                                                            6,200                          1,934
        90.404       COVID-19 - 2018 HAVA Election Security Grants                                                                                 8,267                          6,393
                        Total 2018 HAVA Election Security Grants                                                                                                 14,467

                     Total - Elections Assistance Commission                                                                                                    $16,081          $8,728

      U.S. Department of Health and Human Services
                   Aging Cluster:
        93.044     Special Programs for the Aging - Title III, Part B, Grants for Supp Svc & Senior Cntrs                               25,533                                   23,775
        93.044     COVID-19 - Special Programs for the Aging - Title III, Part B, Grants for Supp Svc & Senior Cntrs                     6,970                                    6,970
                      Total Special Programs for the Aging - Title III, Part B, Grants for Supp Svc & Senior Cntrs                                32,503
        93.045     Special Programs for the Aging - Title III, Part C, Nutrition Services                                               22,347                                   22,300
        93.045     COVID-19 - Special Programs for the Aging - Title III, Part C, Nutrition Services                                    24,614                                   24,614
                      Total Special Programs for the Aging - Title III, Part C, Nutrition Services                                                46,961
        93.053     Nutrition Services Incentive Program                                                                                            5,933                          5,933
                          Total Aging Cluster                                                                                                                    85,397

                     CCDF Cluster:
        93.575       Child Care and Development Block Grant                                                                            240,740                                  215,679
        93.575       COVID-19 - Child Care and Development Block Grant                                                                 262,441                                  262,441
                       Total Child Care and Development Block Grant                                                                              503,181
        93.596       Child Care Mandatory and Matching Funds of the Child Care and Development Fund                                              110,115                        109,977
                           Total CCDF Cluster                                                                                                                   613,296



                                                                         - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                                 Passed
                                                                                                                                                                 Federal       Through to
      Assistance                                                                                                                                               Expenditures   Subrecipients
      Listing #    Assistance Listing Program Name                                                                                                                (000's)        (000's)

                   Head Start Cluster:
       93.600      Head Start                                                                                                            7,312                                        7,312
       93.600      COVID-19 - Head Start                                                                                                   396                                          396
                     Total Head Start                                                                                                                 7,708
                        Total Head Start Cluster                                                                                                                      7,708

                   Medicaid Cluster:
       93.775      State Medicaid Fraud Control Units                                                                                                 7,667
       93.777      State Survey & Cert. of Health Care Providers & Suppliers (Title XVIII) Medicare                                     16,311
       93.777      COVID-19 - State Survey & Cert. of Health Care Providers & Suppliers (Title XVIII) Medicare                           3,136
                      Total State Survey & Cert. of Health Care Providers & Suppliers (Title XVIII) Medicare                                         19,447
       93.778      Medical Assistance Program                                                                                        22,195,842                                     323,099
       93.778      COVID-19 - Medical Assistance Program                                                                              1,605,735
                      Total Medical Assistance Program                                                                                            23,801,577
35                        Total Medicaid Cluster                                                                                                                 23,828,691

       93.041      Special Programs for the Aging - Title VII, Chapter 3, Programs for Prev of Elder Abuse                                                              200               200
       93.042      Special Programs for the Aging - Title VII, Chapter 2, Long Term Care Om. Services                                                   612                               612
       93.042      COVID-19 - Special Programs for the Aging - Title VII, Chapter 2, Long Term Care Om. Services                                        227                               215
                      Total Special Programs for the Aging - Title VII, Chapter 2, Long Term Care Om. Services                                                          839
       93.043      Special Programs for the Aging - Title III, Part D, Disease Prevent and Health Promo Serv                                                            753             753
       93.048      COVID-19 - Special Programs for the Aging - Title IV and Title II, Discretionary Projects                                                          1,712           1,628
       93.052      National Family Caregiver Support, Title III, Part E                                                                               5,882                           5,882
       93.052      COVID-19 - National Family Caregiver Support, Title III, Part E                                                                    3,995                           3,995
                      Total National Family Caregiver Support, Title III, Part E                                                                                      9,877
       93.069      Public Health Emergency Preparedness                                                                                                              16,909           4,283
       93.070      Environmental Public Health and Emergency Response                                                                                                   239             120
       93.071      Medicare Enrollment Assistance Program                                                                                                               990             594
       93.079      Cooperative Agreements to Promote Adolescent Health                                                                                                   25
       93.090      Guardianship Assistance                                                                                                           13,249                          12,554
       93.090      COVID-19 - Guardianship Assistance                                                                                                 1,416                           1,416
                      Total Guardianship Assistance                                                                                                                  14,665
       93.092      Affordable Care Act (ACA) Personal Responsibility Education Program                                                                                  920               914
       93.103      Food and Drug Administration - Research                                                                                                            2,241
       93.104      Community Mental Health Services for Children with Serious Emotional Disturbances                                                                  2,538           2,538
       93.110      Maternal and Child Health Federal Consolidated Programs                                                                                              130
       93.116      Project Grants and Cooperative Agreements for Tuberculosis Control Programs                                                                          762
       93.127      Emergency Medical Services for Children                                                                                                              183               180


                                                                       - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                        Passed
                                                                                                                                                     Federal          Through to
      Assistance                                                                                                                                   Expenditures      Subrecipients
      Listing #     Assistance Listing Program Name                                                                                                   (000's)           (000's)
       93.130        Coop. Agreements to States/Territories for the Coordination & Dev. of Primary Care Offices                                                145
       93.136        Injury Prevention & Control Research & State & Community Based Programs                                               8,489                             4,386
       93.136        COVID-19 - Injury Prevention & Control Research & State & Community Based Programs                                      124                               124
                        Total Injury Prevention & Control Research & State & Community Based Programs                                                     8,613
        93.150       Projects for Assistance in Transition from Homelessness (PATH)                                                                       2,386              2,292
        93.165       Grants to States for Loan Repayment                                                                                                  1,124
        93.197       Childhood Lead Poisoning Prevention Projects, St and Lcl Childhood Lead Poising Prev                                                   390                 97
        93.226       Research on Healthcare Costs, Quality and Outcomes                                                                                    (463)              (463)
        93.234       Traumatic Brain Injury State Demonstration Grant Program                                                                               356                348
        93.235       Title V State Sexual Risk Avoidance Education (Title V State SRAE) Program                                                           1,140              1,136
        93.236       Grants to States to Support Oral Health Workforce Activities                                                                           389                224
        93.240       State Capacity Building                                                                                                204
        93.240       COVID-19 - State Capacity Building                                                                                      56
                        Total State Capacity Building                                                                                                       260
        93.243       Substance Abuse and Mental Health Services - Projects of Reg. and Nat. Significance                                   8,245                             6,729
36    Passed through: Vibrant Emotional Health
        93.243       Substance Abuse and Mental Health Services - Projects of Reg. and Nat. Significance (Award ID 988 Planning Grant)      127                                  127
                        Total Substance Abuse and Mental Health Services - Projects of Reg. and Nat. Significance                                         8,372
        93.251       Early Hearing Detection and Intervention                                                                                               186                175
        93.268       Immunization Cooperative Agreements (Cash Assistance)                                                                 9,026                             2,601
        93.268       COVID-19 - Immunization Cooperative Agreements (Cash Assistance)                                                      7,417                             2,512
        93.268       Immunization Cooperative Agreements (Vaccines)                                                                      101,717
                        Total Immunization Cooperative Agreements                                                                                       118,160
        93.270       Viral Hepatitis Prevention and Control                                                                                                 149
        93.283       Centers for Disease Control & Prevention - Investigations and Technical Assistance                                                     243
        93.305       PPHF 2018: Office of Smoking and Hlth-Nat State-Based Tobacco Control Programs                                                          73                 45
        93.323       Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)                                                    3,240                               310
        93.323       COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)                                        98,387                            11,266
                        Total Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)                                                        101,627
        93.324       State Health Insurance Assistance Program                                                                                            1,607              1,552
        93.354       Activities to Support STLT Health Dept. Response to Public Health or Healthcare Crises                                   66                                85
        93.354       COVID-19 - Activities to Support STLT Health Dept. Response to Public Health or Healthcare Crises                    19,113                             4,684
                        Total Activities to Support STLT Health Dept. Response to Public Health or Healthcare Crises                                     19,179
        93.366       State Actions to Improve Oral Health Outcomes & Partner Actions to Improve Oral Health Outcomes                                        394                  337
        93.367       Flexible Funding Model - Infrastructure Development & Maintenance for SMFRP                                                            558
        93.369       ACL Independent Living State Grants                                                                                                    750                417
        93.387       National and State Tobacco Control Program                                                                                           1,658                532
        93.426       Improving the Hlth of Americans through Prev & Mgmt of Diab & HD and Stroke                                                          1,882              1,129
        93.434       Every Student Succeeds Act/Preschool Development Grants                                                                                 (6)               (10)


                                                                         - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                 Passed
                                                                                                                                                Federal        Through to
      Assistance                                                                                                                              Expenditures    Subrecipients
      Listing #    Assistance Listing Program Name                                                                                               (000's)         (000's)
       93.436      Well-Integrated Screening and Evaluation for Women Across the Nation (WISEWOMAN)                                                    609                 97
       93.439      State Physical Activity and Nutrition (SPAN)                                                                                        884                390
       93.448      Food Safety and Security Monitoring Project                                                                                         114
       93.478      Preventing Maternal Deaths: Supporting Maternal Mortality Review Committees                                                         232                    4
       93.498      COVID-19 - Provider Relief Fund                                                                                                   2,519
       93.500      Pregnancy Assistance Fund Program                                                                                                   239              237
       93.556      Promoting Safe and Stable Families Program                                                                                       10,266           10,149
       93.558      Temporary Assistance for Needy Families                                                                                         391,359          205,982
       93.563      Child Support Enforcement                                                                                                       163,401          137,399
       93.566      Refugee and Entrant Assistance - State/Replacement Designee Administered Programs                                                 7,589            6,597
       93.568      Low-Income Home Energy Assistance                                                                                174,778                          23,166
       93.568      COVID-19 - Low-Income Home Energy Assistance                                                                      30,604                           4,761
                      Total Low-Income Home Energy Assistance                                                                                      205,382
       93.569      Community Services Block Grant                                                                                    26,267                          25,444
       93.569      COVID-19 - Community Services Block Grant                                                                          9,373                           9,126
37                    Total Community Services Block Grant                                                                                          35,640
       93.576      Refugee and Entrant Assistance - Discretionary Grants                                                                               551              438
       93.590      Community-Based Child Abuse Prevention Grants                                                                                       814              814
       93.599      Chafee Education and Training Vouchers Program (ETV)                                                               1,614                           1,614
       93.599      COVID-19 - Chafee Education and Training Vouchers Program (ETV)                                                    1,818                           1,818
                      Total Chafee Education and Training Vouchers Program (ETV)                                                                     3,432
       93.603      Adoption and :Legal Guardianship Incentive Payments                                                                                 246               27
       93.630      Developmental Disabilities Basic Support and Advocacy Grants                                                                      3,527            2,466
       93.643      Children's Justice Grants to States                                                                                                 176              176
       93.645      Stephanie Tubbs Jones Child Welfare Services Program                                                                              9,205            8,353
       93.658      Foster Care - Title IV-E                                                                                         221,752                         212,073
       93.658      COVID-19 - Foster Care - Title IV-E                                                                                6,020                           6,020
                      Total Foster Care - Title IV-E                                                                                               227,772
       93.659      Adoption Assistance                                                                                              144,850                         107,147
       93.659      COVID-19 - Adoption Assistance                                                                                    11,449                          11,449
                      Total Adoption Assistance                                                                                                    156,299
       93.667      Social Services Block Grant                                                                                                      87,301           73,959
       93.669      Child Abuse and Neglect State Grants                                                                                                871               89
       93.671      Family Violence Prevention & Services/Domestic Violence Shelter & Supportive Services                              4,498                           4,498
       93.671      COVID-19 - Family Violence Prevention & Services/Domestic Violence Shelter & Supportive Services                     746                             746
                      Total Family Violence Prevention & Services/Dom. Violence Shelter & Supportive Services                                        5,244
       93.674      John H. Chafee Foster Care Program for Successful Transition for Adulthood                                                        4,081            4,081
       93.735      State Public Health Approaches for Ensuring Quitline Capacity- Funded in part by PPHF                                                 6                2
       93.747      Elder Abuse Prevention Interventions Program                                                                                        (51)


                                                                      - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                  Passed
                                                                                                                                                 Federal        Through to
      Assistance                                                                                                                               Expenditures    Subrecipients
      Listing #    Assistance Listing Program Name                                                                                                (000's)         (000's)
       93.767      Children's Health Insurance Program                                                                               545,512                         265,780
       93.767      COVID-19 - Children's Health Insurance Program                                                                     36,418                          15,293
                      Total Children's Health Insurance Program                                                                                     581,930
       93.788      Opioid STR                                                                                                                        70,086           51,547
       93.791      Money Follows the Person Rebalancing Demonstration                                                                  3,841                             496
       93.791      COVID-19 - Money Follows the Person Rebalancing Demonstration                                                          33
                      Total Money Follows the Person Rebalancing Demonstration                                                                        3,874
       93.817      Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities                                                     1,315            1,067
       93.829      Section 223 Demonstration Programs to Improve Community Mental Health Services                                                       (40)             (40)
       93.870      Maternal, Infant & Early Childhood Home Visiting Grant Program                                                                    10,020            9,838
       93.876      Antimicrobial Resistance Surveillance in Retail Food Specimens                                                                       128
       93.881      The Health Insurance Enforcement and Consumer Protections Grant Program                                                              257
       93.889      National Bioterrorism Hospital Preparedness Program                                                                 5,138                           3,582
       93.889      COVID-19 - National Bioterrorism Hospital Preparedness Program                                                      2,635                           2,584
                      Total National Bioterrorism Hospital Preparedness Program                                                                       7,773
38     93.898      Cancer Prevention & Control Programs for State, Territorial & Tribal Organizations                                                 5,011            2,861
       93.917      HIV Care Formula Grants                                                                                            34,461                             604
       93.917      COVID-19 - HIV Care Formula Grants                                                                                    537                             537
                      Total HIV Care Formula Grants                                                                                                  34,998
       93.940      HIV Prevention Activities - Health Department Based                                                                                4,804            1,088
       93.944      Human Immunodeficiency Virus (HIV)/AIDS Surveillance                                                                                 299
       93.946      Cooperative Agreements to Support Safe Motherhood and Infant Health Initiative Program                                               263
       93.958      Block Grants for Community Mental Health Services                                                                                 24,104           23,352
       93.959      Block Grants for Prevention and Treatment of Substance Abuse                                                                      65,828           56,534
       93.968      Funding in Support of the Pennsylvania Rural Health Model                                                                          2,150
       93.977      Sexually Transmitted Diseases (STD) Prevention and Control Grants                                                                  1,860              292
       93.982      COVID-19 - Mental Health Disaster Assistance and Emergency Mental Health                                                             622              580
       93.991      Preventive Health and Health Services Block Grant                                                                                  7,064            4,946
       93.994      Maternal and Child Health Services Block Grant to the States                                                                      24,929           15,826

                   Total - U.S. Department of Health and Human Services                                                                         $27,022,230       $2,394,904

      Corporation for National and Community Service
       94.003       State Commissions                                                                                                                   388
       94.006       AmeriCorps                                                                                                                       10,729           10,729
       94.009       Training and Technical Assistance                                                                                                   187               52

                   Total - Corporation for National and Community Service                                                                           $11,304          $10,781




                                                                       - See Notes to Schedule of Expenditures of Federal Awards -
     COMMONWEALTH OF PENNSYLVANIA
     Schedule of Expenditures of Federal Awards - June 30, 2021
                                                                                                                                                                   Passed
                                                                                                                                                  Federal        Through to
      Assistance                                                                                                                                Expenditures    Subrecipients
       Listing #    Assistance Listing Program Name                                                                                                (000's)         (000's)
      Executive Office of the President
        95.001      High Intensity Drug Trafficking Areas Program                                                                                      3,912

                     Total - Executive Office of the President                                                                                        $3,912                  $0

      Social Security Administration
                     Disability Insurance/SSI Cluster:
        96.001       Social Security - Disability Insurance                                                                                          126,571

                     Total - Social Security Administration                                                                                         $126,571                  $0

      U.S. Department of Homeland Security
        97.008     Non-Profit Security Program                                                                                                           429                429
        97.012     Boating Safety Financial Assistance                                                                                                 2,442
        97.023     Community Assistance Program State Support Services Element (CAP-SSSE)                                                                161
39      97.029     Flood Mitigation Assistance                                                                                                            (4)            (264)
        97.032     COVID-19 - Crisis Counseling                                                                                                          269              245
        97.036     Disaster Grants - Public Assist (Presidentially Declared Disasters)                                                 22,408                          10,785
        97.036     COVID-19 - Disaster Grants - Public Assist (Presidentially Declared Disasters)                                     133,337                          60,003
                      Total Disaster Grants - Public Assist (Presidentially Declared Disasters)                                                      155,745
        97.039     Hazard Mitigation Grant                                                                                                             2,430            2,324
        97.041     National Dam Safety Program                                                                                                           197              106
        97.042     Emergency Management Performance Grants                                                                              9,684                           4,825
        97.042     COVID-19 - Emergency Management Performance Grants                                                                     126
                      Total Emergency Management Performance Grants                                                                                    9,810
        97.044     Assistance to Firefighters Grant                                                                                                      135
        97.045     Cooperating Technical Partners                                                                                                         62
        97.047     BRIC: Building Resilient Infrastructure and Communities                                                                               957                901
        97.050     COVID-19 - Presidential Declared Disaster Assistance to Individuals and Households - Other Needs                                1,889,403
        97.067     Homeland Security Grant Program                                                                                                    26,901           21,358
        97.091     Homeland Security Biowatch Program                                                                                                    447

                     Total - U.S. Department of Homeland Security                                                                                 $2,089,384         $100,712

                     GRAND TOTAL                                                                                                                 $72,503,315       $7,313,333




                                                                        - See Notes to Schedule of Expenditures of Federal Awards -
COMMONWEALTH OF PENNSYLVANIA
Notes to the Schedule of Expenditures of Federal Awards - June 30, 2021


Note A: Single Audit Reporting Entity
The Commonwealth of Pennsylvania (the Commonwealth) includes expenditures in its schedule of expenditures of federal
awards (SEFA) for all federal programs administered by the same funds, agencies, boards, commissions, and component
units included in the Commonwealth’s financial reporting entity used for its basic financial statements. However, the State
System of Higher Education (SSHE), the Pennsylvania Higher Education Assistance Agency (PHEAA), the Pennsylvania
Housing Finance Agency (PHFA), the Pennsylvania Convention Center Authority (PCCA), the Philadelphia Shipyard
Development Corporation (PSDC), which are discretely presented component units, the Philadelphia Regional Port Authority
(PRPA) and the Commonwealth Financing Authority (CFA), which are blended component units, elect to have their own
single audits (when required) and their expenditures of federal awards are therefore excluded from the Commonwealth’s
SEFA. These seven component units are required to submit their own single audit reports to the Federal Audit Clearinghouse.
The PCCA and the PSDC are not required to submit a single audit for the year ended June 30, 2021, because their federal
expenditures were below the requirement threshold. In addition, the Judicial Department of Pennsylvania, which is included
in the Primary Government, elected to have its own single audit performed. Their federal expenditures are also excluded from
the Commonwealth’s SEFA.

Note B: Basis of Accounting
All expenditures for each program included in the schedule of expenditures of federal awards are net of applicable program
income and refunds.

Expenditures reported under Assistance Listing Number (ALN) 10.551, Supplemental Nutrition Assistance Program (SNAP),
represent amounts the Electronic Benefits Transfer (EBT) contractor paid to retail outlets for participants’ purchases under
the program during the fiscal year ended June 30, 2021.

Expenditures reported under ALN 10.555, National School Lunch Program, ALN 10.558, Child and Adult Care Food
Program, ALN 10.559, Summer Food Service Program, ALN 10.565, Commodity Supplemental Food Program, and ALN
10.569, Emergency Food Assistance Program, include the value of food commodity distributions calculated using the U.S.
Department of Agriculture, Food and Nutrition Service, commodity price lists in effect as of July 1, 2020 and January 1,
2021.

Subrecipient expenditures reported under ALN 14.228, Community Development Block Grants, ALN 14.231, Emergency
Solutions Grant Program, prior to August 23, 2012 with the exception of FY 2011 subrecipient expenditures reported after
December 31, 2014, and ALN 14.239, Home Investment Partnerships Program, represent funds drawn directly from the
Housing and Urban Development (HUD) Integrated Disbursement and Information System (IDIS) by subrecipients of the
Commonwealth.

Expenditures for ALN 20.200, Highway Research and Development Program, ALN 20.205, Highway Planning and
Construction, ALN 20.215, Highway Training and Education, ALN 20.219, Recreational Trails Program, ALN 20.505,
Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research, and ALN 20.933, National
Infrastructure Investments are presented on the basis that expenditures are reported to the U.S. Department of Transportation.
Accordingly, certain expenditures are recorded when paid and certain other expenditures are recorded when the federal
obligation is determined.

Amounts reported as expenditures for ALN 39.003, Donation of Federal Surplus Personal Property, represent the General
Services Administration’s average fair market value percentage of 23.34 percent of the federal government’s original
acquisition cost (OAC) of the federal property transferred to recipients by the Commonwealth.

Expenditures identified on the SEFA as Vaccines under ALN 93.268, Immunization Cooperative Agreements, represent the
dollar value of the items used.

Expenditures reported by the Pennsylvania Department of Transportation (PennDOT) for ALN 97.036, Disaster Grants-
Public Assistance (Presidentially Declared Disasters), are recorded when the estimated federal obligation is determined and
reimbursed.



                                                             40
COMMONWEALTH OF PENNSYLVANIA
Notes to the Schedule of Expenditures of Federal Awards - June 30, 2021


The remaining expenditures included in the schedule of expenditures of federal awards are presented on the cash plus invoices
payable basis. Invoices payable represent Commonwealth expenditures recorded on the general ledger for which the
Commonwealth Treasury Department has not made cash disbursements.

The Commonwealth has not elected to use the 10% de minimis cost rate referenced in Uniform Guidance § 200.414 Indirect
(F&A) costs.

Note C: Categorization of Expenditures
The schedule of expenditures of federal awards reflects federal expenditures for all individual grants that were active during
the fiscal year ended June 30, 2021. The categorization of expenditures by program included in the SEFA is based on the
Assistance Listing. Changes in the categorization of expenditures occur based on revisions to the ALN, which are issued on
a real-time basis on the Assistance Listing website.

Note D: Unemployment Insurance
In accordance with Department of Labor, Office of Inspector General instructions, the Commonwealth recorded State Regular
Unemployment Compensation (UC) benefits under ALN 17.225 in the schedule of expenditures of federal awards. The
individual state and federal portions are as follows (amounts in thousands):

                                        State Regular UC Benefits            $4,582,709
                                        Federal UC Benefits                  23,767,016
                                        Federal Admin.                          242,961
                                        Total Expenditures                  $28,592,686

Note E: Unaudited Donations

Federally funded COVID-19 related PPE donations with an estimated value of $20 million were received by the
Commonwealth during the fiscal year. This amount is not reflected on the SEFA.




                                                             41
THIS PAGE INTENTIONALLY LEFT BLANK




                 42
Schedule of Findings
and Questioned Costs




 Commonwealth of Pennsylvania




              43
COMMONWEALTH OF PENNSYLVANIA
Summary of Auditors’ Results - June 30, 2021

 Financial Statements

 Type of report the auditors issued on whether
 the financial statements audited were prepared
 in accordance with GAAP:                               Unmodified

 Internal control over financial reporting:

  Material weakness(es) identified?                         yes         X no

  Significant deficiency(ies) identified?               X   yes             none reported

 Noncompliance material to financial
  statements noted?                                         yes         X   no


 Federal Awards

 Internal control over major federal programs:

  Material weakness(es) identified?                     X   yes             no

  Significant deficiency(ies) identified?               X   yes             none reported

 Type of auditors' report issued on compliance
  for major federal programs:

 Qualified for noncompliance in the following major federal programs:

  Supplemental Nutrition Assistance Program (SNAP) Cluster (ALN 10.551 and 10.561)
  Abandoned Mine Land Reclamation (ALN 15.252)
  Crime Victim Assistance (ALN 16.575)
  Temporary Assistance for Needy Families (ALN 93.558)
  Child Support Enforcement (ALN 93.563)
  Child Care and Development Fund (CCDF) Cluster (ALN 93.575 and 93.596)
  Foster Care – Title IV-E (ALN 93.658)
  Adoption Assistance (ALN 93.659)
  Disaster Grants – Public Assistance (Presidentially Declared Disasters) (ALN 97.036)

 Unmodified for the following major federal programs:

  Unemployment Insurance (ALN 17.225)
  WIOA Cluster (ALN 17.258, 17.259, and 17.278)
  Highway Planning and Construction Cluster (ALN 20.205 and 20.219)
  Coronavirus Relief Fund (ALN 21.019)
  Emergency Rental Assistance Program (ALN 21.023)
  Education Stabilization Fund (ALN 84.425)
  Immunization Cooperative Agreements (ALN 93.268)




                                                  44
COMMONWEALTH OF PENNSYLVANIA
Summary of Auditors’ Results - June 30, 2021

 Unmodified for the following major federal programs (continued):

   Low-Income Home Energy Assistance (ALN 93.568)
   Children’s Health Insurance Program (ALN 93.767)
   Medicaid Cluster (ALN 93.775, 93.777, and 93.778)
   Presidential Declared Disaster Assistance to Individuals and Households – Other Needs (ALN 97.050)

  Any audit findings disclosed that are required
   to be reported in accordance with
   2 CFR 200.516(a)?                                         X     yes                  no


Identification of Major Federal Programs:
                                                                                                 Federal
    Assistance Listing                                                                         Expenditures
       Number(s)                           Name of Federal Program or Cluster                     (000s)

    10.551 and 10.561           Supplemental Nutrition Assistance Program (SNAP)                 $5,046,655
                                  Cluster (C)
          15.252                Abandoned Mine Land Reclamation                                      57,712
          16.575                Crime Victim Assistance                                              83,352
          17.225                Unemployment Insurance (C)                                       28,592,686
17.258, 17.259, and 17.278      WIOA Cluster                                                        111,212
    20.205 and 20.219           Highway Planning and Construction Cluster (C)                     2,323,880
          21.019                Coronavirus Relief Fund (C)                                       2,764,742
          21.023                Emergency Rental Assistance Program (C)                             564,535
          84.425                Education Stabilization Fund (C)                                    544,779
          93.268                Immunization Cooperative Agreements (C)                             118,160
          93.558                Temporary Assistance for Needy Families                             391,359
          93.563                Child Support Enforcement                                           163,401
          93.568                Low-Income Home Energy Assistance (C)                               205,382
    93.575 and 93.596           Child Care and Development Fund (CCDF) Cluster (C)                  613,296
          93.658                Foster Care – Title IV-E (C)                                        227,772
          93.659                Adoption Assistance (C)                                             156,299
          93.767                Children’s Health Insurance Program (C)                             581,930
93.775, 93.777, and 93.778      Medicaid Cluster (C)                                             23,828,691
          97.036                Disaster Grants – Public Assistance (Presidentially Declared        155,745
                                  Disasters) (C)
         97.050                 Presidential Declared Disaster Assistance to Individuals and      1,889,403
                                  Households – Other Needs (C)

                               Total Federal Expenditures – Major Programs                      $68,420,991

(C) = COVID-19 Funds included

 Dollar threshold used to distinguish between
  Type A and Type B programs (000s):                       $108,755

 Auditee qualified as low-risk auditee?                      yes           X    no



                                                      45
COMMONWEALTH OF PENNSYLVANIA
Index to Basic Financial Statement Findings - June 30, 2021
                                                                   Impacted
 Finding                                                             State    Finding   CAP
   No.                      Finding Title                           Agency     Page     Page

 2021-001*   Information Technology General Controls Need           OA-OIT      47      102
             Improvement (A Similar Condition Was Noted in Prior
             Year Finding 2020-001)

 2021-002*   Information Technology Control Weaknesses in the        L&I        49      102
             Unemployment     Compensation   and    Pandemic        OA-OIT
             Unemployment Assistance Systems




*      - Significant Deficiency
**     - Material Weakness
CAP    - Corrective Action Plan

                                                    46
COMMONWEALTH OF PENNSYLVANIA
Basic Financial Statement Findings - June 30, 2021

Office of Administration – Office for Information Technology

Finding 2021 – 001:

Information Technology General Controls Need Improvement (A Similar Condition Was Noted in Prior Year
Finding 2020-001)

Type of Finding: Significant Deficiency

Condition: Our review of information technology (IT) general controls in the Office of Administration, Office for
Information Technology (OA-OIT), for the fiscal year ended June 30, 2021, disclosed the following control deficiencies
in applications supported by the Employment, Banking, and Revenue (EBR) and Infrastructure and Economic
Development (I&ED) Delivery Centers:

1.   There was a lack of segregation of duties between application development and promotion of code to production in
     certain applications in the mainframe and client/server environments in the EBR Delivery Center. Developers
     (including contractors) were granted the ability to develop code and to promote code to production. In other cases,
     developers were given the ability to change the operations schedule (while such access may be required in certain
     circumstances, the associated risk should be mitigated with monitoring of production environments for unauthorized
     changes).
2.   In the EBR Delivery Center there were a large number of users with privileged and administrative access to a
     mainframe environment. The use of this access was not logged and/or monitored, and there were no policies or
     procedures governing the granting of powerful user attributes in the mainframe environment. The mainframe in
     question was replaced June 2021 and is no longer considered production. In two client-server environments, certain
     users had access to accounts with shared passwords.
3.   Two system administrators retained access to EBR and I&ED Delivery Center applications after they separated
     employment. Further, during the period when applications were being implemented quickly in response to the
     COVID-19 pandemic, the EBR Delivery Center suspended normal controls over adding and deleting users in two
     systems. New and terminated users were tracked through the use of a shared spreadsheet accessible to a large number
     of people.

A detailed schedule of issues has been provided to the OA-OIT for corrective action.

Criteria: Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the
internal control framework outlined in the United States Government Accountability Office’s Standards for Internal
Control in the Federal Government (Green Book), published in September 2014.

•    Green Book Principle 11 – Design Activities for the Information System, states in part:

     o   11.12 Management designs control activities over access to protect an entity from inappropriate access and
         unauthorized use of the system. These control activities support appropriate segregation of duties. By preventing
         unauthorized use of and changes to the system, data and program integrity are protected from malicious intent
         (e.g., someone breaking into the technology to commit fraud, vandalism, or terrorism) or error.

     o   11.14 Management designs control activities to limit user access to information technology through authorization
         control activities such as providing a unique user identification or token to authorized users. These control
         activities may restrict authorized users to the applications or functions commensurate with their assigned
         responsibilities, supporting an appropriate segregation of duties. Management designs other control activities
         to promptly update access rights when employees change job functions or leave the entity.

A well-designed system of internal controls dictates that effective IT general controls, which include adequate segregation
of duties, access controls to programs and data, and controls over adding and deleting users, be established and functioning
to ensure that overall agency operations are conducted in accordance with management’s intent.




                                                            47
COMMONWEALTH OF PENNSYLVANIA
Basic Financial Statement Findings - June 30, 2021

Finding 2021 – 001: (continued)
Cause: Certain segregation of duties weaknesses, as well as certain privileged user control issues, were noted in legacy
systems in the EBR Delivery Center that have been replaced or are scheduled for replacement during fiscal year end 2022.
The segregation of duties weaknesses in other client-server environments have not been addressed by the EBR Delivery
Center because of the belief that there is not enough staff to separate development of code from promotion to production.

Management in the EBR Delivery Center has not developed policies for granting privileged/administrative access to
systems. The shared accounts in one client-server system were default IDs which were not monitored, despite the
recommendation of the application manufacturer. The shared administrative accounts in another client-server environment
were created during system installation. Management is hesitant to delete the accounts and has not developed controls to
lock the accounts or monitor their use.

A new system designed to remove separated users automatically from an I&ED Delivery Center application was abandoned
when it erroneously removed active users. The I&ED Delivery Center has begun planning for a new automated system;
however, the manual system used in the interim failed to operate effectively when a user’s termination was backdated on
a separation report generated by Human Resources. In the EBR Delivery Center, the informal mechanism used to track
new and terminated users in certain systems was due to the speed at which a large number of users were added to implement
applications to expend Coronavirus Aid, Relief, and Economic Security (CARES) Act funding. The formal process used
to track new and terminated users in these systems was re-implemented in May 2021. Additionally, a designated backup
was not identified to process termination requests.

Effect: Segregation of duties weaknesses, inappropriate and unmonitored privileged access, as well as ineffective controls
over new and separated users, all contribute to the risk that system actions can occur that are not in accordance with
management’s intent. Applications serving the Departments of Revenue, Labor and Industry, Insurance, and
Transportation were impacted by these control weaknesses. Further, without properly functioning controls over
segregation of duties and privileged access, as well as controls over new and terminated users, the auditors are precluded
from reliance on computer controls in these agencies.

Recommendation: We recommend that OA-OIT management continue its efforts to resolve the general computer control
deficiencies noted above. Specific consideration should be given to:

•   Creating controls and procedures that segregate the development of programs from promotion of code to the
    production environment;
•   Preventing developers from having access to the production environment and the operations schedule;
•   Developing policies to govern the granting of privileged/administrative access;
•   Monitoring and controlling the use of privileged accounts, as well as shared user IDs with shared passwords;
•   Continuing efforts to develop an automated system to deactivate separated user accounts in the I&ED Delivery Center;
•   Developing an alert system when employee/contractor user separations are backdated in Human Resource reports;
    and
•   Ensuring controls designed to remove users’ access from systems when employees or contractors no longer need
    access or terminate employment are operating effectively.

As systems are being replaced at the Department of Labor and Industry and the Department of Insurance, we recommend
implementation of controls in the new systems that conform to the criteria listed above.

Agency Response: Office of Administration, Office for Information Technology (OA-OIT), agrees with this finding.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.




                                                           48
COMMONWEALTH OF PENNSYLVANIA
Basic Financial Statement Findings - June 30, 2021

Department of Labor and Industry
Office of Administration – Office for Information Technology

Finding 2021 – 002:

Information Technology Control Weaknesses in the Unemployment Compensation and Pandemic Unemployment
Assistance Systems

Type of Finding: Significant Deficiency

Condition: During the fiscal year ended June 30, 2021, the Department of Labor and Industry (L&I) paid Pandemic
Unemployment Assistance (PUA) and regular Unemployment Compensation (UC) benefits using three systems: 1) the
outsourced PUA system; 2) the legacy UC mainframe system through June 8, 2021; and 3) the UC Benefits Modernization
System (UC Ben Mod) after June 8, 2021. We identified the following control weaknesses in these systems:

•     Issuance of duplicate PUA payments of approximately $304.8 million in July 2020 without adequate controls over
      the outsourced system.
•     Inconsistent application of UC applicant identity verification software and data cross-match procedures without a
      documented fraud risk assessment.
•     Implementation of the UC Ben Mod system without the following:

      o   adherence to the Office of Administration, Office for Information Technology’s (OA-OIT) Enterprise Data
          and Information Management Policy;
      o   a list of known issues provided to one individual responsible for the “go live” decision; and
      o   a signed agreement with OA-OIT for management and governance of the UC Ben Mod servers hosted at the
          Enterprise Data Center (EDC).

•     Creation of large numbers of system administrator accounts granted to vendor personnel in the UC Ben Mod system
      without policies or procedures for granting the access and without documented monitoring of the administrators’
      actions in the system.

Criteria: Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the
internal control framework outlined in the United States Government Accountability Office’s Standards for Internal
Control in the Federal Government (Green Book), published in September 2014:

•    Green Book Principle 1 – Demonstrate Commitment to Integrity and Ethical Values, states in part:

     o    1.04 The oversight body’s and management’s directives, attitudes, and behaviors reflect the integrity and
          ethical values expected throughout the entity. The oversight body and management reinforce the commitment
          to doing what is right, not just maintaining a minimum level of performance necessary to comply with
          applicable laws and regulations, so that these priorities are understood by all stakeholders, such as
          regulators, employees, and the general public.

•    Green Book Principle 8 – Assess Fraud Risk, states in part:

     o    8.02 Management considers the types of fraud that can occur within the entity to provide a basis for
          identifying fraud risks. Types of fraud [include]… Misappropriation of assets - Theft of an entity’s assets.
          This could include … fraudulent payments….




                                                          49
COMMONWEALTH OF PENNSYLVANIA
Basic Financial Statement Findings - June 30, 2021

Finding 2021 – 002: (continued)
         o     8.04 and 8.05 Management considers fraud risk factors…Management uses the fraud risk factors to identify
               fraud risks… Other information provided by internal and external parties can also be used to identify fraud
               risks. This may include allegations of fraud or suspected fraud reported by the office of the inspector general
               or internal auditors, personnel, or external parties that interact with the entity.

         o     8.06 Management analyzes and responds to identified fraud risks so that they are effectively mitigated. Fraud
               risks are analyzed through the same risk analysis process performed for all identified risks. Management
               analyzes the identified fraud risks by estimating their significance, both individually and in the aggregate, to
               assess their effect on achieving the defined objectives.

         o     8.07 Management responds to fraud risks through the same risk response process performed for all analyzed
               risks. Management designs an overall risk response and specific actions for responding to fraud risks. It
               may be possible to reduce or eliminate certain fraud risks by making changes to the entity’s activities and
               processes. …. Further, when fraud has been detected, the risk assessment process may need to be revised.

    •    Green Book Principle 11 – Design Activities for the Information System, states in part:

         o   11.09 Management designs control activities over the information technology infrastructure to support the
             completeness, accuracy, and validity of information processing by information technology. … Management
             evaluates the objectives of the entity and related risks in designing control activities for the information
             technology infrastructure.

         o   11.12 Management designs control activities over access to protect an entity from inappropriate access and
             unauthorized use of the system... By preventing unauthorized use of and changes to the system, data and
             program integrity are protected from malicious intent (e.g., someone breaking into the technology to commit
             fraud, vandalism, or terrorism) or error.

         o   11.14 Management designs control activities to limit user access to information technology through
             authorization control activities such as providing a unique user identification or token to authorized users.
             These control activities may restrict authorized users to the applications or functions commensurate with their
             assigned responsibilities, supporting an appropriate segregation of duties.

         o   11.17 … Management … evaluates the unique risks that using a service organization presents for the
             completeness, accuracy, and validity of information submitted to and received from the service organization

OA-OIT issued the following Information Technology Policies (ITPs) and Operational Document (OPD) to provide
governance and guidance to agencies during implementation of new systems and placement of servers in the Enterprise
Data Center:

•       ITP-INF000 – Enterprise Data and Information Management Policy, provides direction for effectively managing
        data and information life cycles including establishing data migration controls for data sets to be accessed from their
        original sources, and efficiently moved from source to target destinations in an effective and secure manner.

•       OPD-INF000A – Migration Audit Checklist Template, which agencies must use to facilitate data migration as
        delineated in ITP-INF000.

•       ITP-BUS007 – Enterprise Service Catalog, establishes policy that Agency and Delivery Centers under the Governor’s
        jurisdiction are required to utilize all Enterprise Standards that are identified in the Enterprise Service Catalog if that
        Enterprise Standard is needed to support agency/delivery center business needs.




                                                                 50
COMMONWEALTH OF PENNSYLVANIA
Basic Financial Statement Findings - June 30, 2021

Finding 2021 – 002: (continued)
Cause: In response to the economic upheaval caused by the COVID-19 pandemic, L&I management was forced to
implement the PUA program under an extremely compressed timeline. They responded by contracting with the vendor
already tasked with building the UC Ben Mod system. The vendor implemented the PUA system on cloud infrastructure.
The duplicate PUA payments in July 2020 occurred when normal vendor processing was interrupted and the outsourced
system failed to mark 30,000 high-dollar payments as already sent to claimants. While L&I procedures required a manual
review of high-dollar claims, due to time constraints, the payments were processed without the required review. After the
duplicate payments were made, L&I management adjusted the recipients’ claim records to withhold a percentage of future
payments until the overpayments were recouped. After the event, additional controls were implemented to mark payments
as they were paid and verify future payments against those previously paid to prevent duplications.

After the PUA program was implemented, L&I management received information that cyber actors from inside and outside
the United States were mining personally identifiable information (PII) obtained from data breaches external to the
Department and using that PII to file fraudulent claims. L&I management implemented fraud measures including
contracting with an identity verification vendor to prevent fraudulent PUA claims filed after October 20, 2020. L&I
management did not, however, perform a formal fraud risk assessment prior to implementing the new procedures as
required by Federal standards on internal control. L&I management did not apply the new identity verification procedures
to all PUA claims filed prior to October 2020, although certain previously-flagged claims were subjected to review.
Further, L&I management did not apply the new identity verification procedures to regular UC claimants until July 2021.
Finally, while L&I management performed several cross-matches between regular UC claimants and other databases as a
fraud detection measure during the audit period, L&I management excluded PUA claims from certain cross-matches that
were routinely applied to regular UC claims.

When implementing the new UC Ben Mod system in June 2021 as a replacement for the legacy UC mainframe, L&I
management chose to follow the vendor’s data migration plan rather than the OA-OIT policy. While OA-OIT provided
guidance to L&I management during the system implementation, L&I management did not obtain a formal waiver from
the Enterprise Data and Information Management Policy as was required. When questioned about the lack of a list of
known issues provided to the individual who gave the approval to go-live with the new system, L&I management
responded that the go-live decision was not attributable to one individual but was a shared decision based on all available
information at the time. As for the large number of users with administrative access into the UC Ben Mod system, L&I
management relied heavily on the vendor during the initial months of the system implementation and has begun removing
administrative access into the system. L&I management has yet to develop policies for granting and monitoring vendor
access into the system and has not entered into a formal agreement with OA-OIT for administration of the servers at the
Enterprise Data Center.

Finally, during the course of our procedures, we identified additional causes of the duplicate payments that we have
specifically excluded from this finding because of the sensitive nature of this information. This additional information has
been included in a separate communication provided to management and the Commonwealth Audit Committee.

Effect: While L&I management took steps to recoup the duplicate payments from future PUA payments, L&I
management did not provide an estimate of the amount of the $304.8 million in duplicate payments that have not been
recovered. Similarly, there is no estimate of the amount of fraud that could have been prevented had identity verification
procedures and data cross-matches been applied uniformly to PUA and regular UC claims filed during the pandemic.

L&I management’s failure to follow the OA-OIT Enterprise Data and Information Management Policy resulted in the
lack of certain controls over data migration, such as comparison of before and after snapshots of financial balances, which
may have led to data migration errors that may impact the accuracy of payments in the new system. Also, certain
documentation required by the policy has not been developed and retained that would be helpful for the ongoing
administration of the system by L&I management and OA-OIT management. Without procedures for granting and
monitoring administrative access to the UC Ben Mod system, L&I cannot be assured that changes to data and programs
are properly authorized. Without these controls and a formal governance agreement over the system with OA-OIT,
management cannot be assured the system is functioning in accordance with management’s intent.

Recommendations: We recommend that L&I management perform the following:



                                                            51
COMMONWEALTH OF PENNSYLVANIA
Basic Financial Statement Findings - June 30, 2021

Finding 2021 – 002: (continued)

•   Take steps to identify and recover any duplicate PUA payments that have not been recouped through withholding of
    benefits;
•   Continue to monitor the controls over the outsourced PUA system as long as the system continues to pay claims;
•   Perform an additional after-action review of management’s response to the computer operations error that led to the
    duplicate payments and evaluate the need for further corrective actions in the control environment to prevent overrides
    of controls in the future;
•   Establish written procedures for error handling during production processing in the UC Ben Mod system to ensure
    computer operations errors do not result in duplicate payments;
•   Refine the formal risk assessment process to document consideration of various types of fraud risk, including the risk
    of fraudulent payments, so that formal responses and controls can be developed to reduce or eliminate fraud risk;
•   Develop processes to revise the formal fraud risk assessment as needed when additional fraud is detected;
•   Implement identity verification procedures during weekly certifications for regular UC claims filed prior to July 2021
    and for any PUA claims backlogged in the benefit determination process;
•   Fully complete OA-OIT’s Migration Audit Checklist Template to ensure key artifacts are created and retained to
    ensure successful operation of the UC Ben Mod system; and
•   Make a request to OA-OIT to consume Enterprise Standard services from the Enterprise Service Catalog so that a
    written agreement can be made for OA-OIT to document the management and governance of the UC Ben Mod servers
    hosted at the Enterprise Data Center (EDC).

We recommend that OA-OIT management perform the following:

•   Issue guidance to make it clear that the OA-OIT Enterprise Data and Information Management Policy and Migration
    Audit Checklist Template apply to all agencies who implement new systems and migrate data to the new systems.
    When OA-OIT provides guidance to agencies during system implementation, OA-OIT should ensure the agencies
    follow OA-OIT policy so that available resources from OA-OIT can be leveraged for large system implementations;
    and

•   Clarify the responsibility for the “go live” decision on any new system implementation and ensure that the person or
    persons responsible for “go live” have a list of known issues presented in writing so that they have documented
    awareness of the risks of implementation.

We recommend that L&I management and OA-OIT management perform the following:

•   Implement a privileged user management system over the UC Ben Mod system. In the absence of an automated tool,
    implement manual processes to monitor changes to the database, operating system, system files, and application.

Agency Response: Office of Administration, Office for Information Technology (OA-OIT on behalf of Labor & Industry)
agrees with this finding.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


                                                            52
     COMMONWEALTH OF PENNSYLVANIA
     Index to Federal Award Findings and Questioned Costs - June 30, 2021
                                                                                                                                                  Impacted
         Finding                                                                                                        Compliance   Questioned     State    Finding   CAP
         Number        ALN         Assistance Listing Program Name                    Finding Title                     Conclusion     Costs       Agency      Page    Page


         2021-003     84.425     COVID 19 – Education Stabilization   A Significant Deficiency and Noncompliance            NC          ND          PDE         57      103
            *                    Fund                                 Exist at the Department of Education Related to
                                                                      Submission of Elementary and Secondary
                                                                      School Emergency Relief Fund Annual
                                                                      Reporting

         2021-004     15.252     Abandoned Mine Land Reclamation      A    Material    Weakness     and    Material        MNC          ND          DEP         59      105
            **                                                        Noncompliance Exist at the Department of
                                                                      Environmental     Protection    Related    to
                                                                      Subrecipient Monitoring (A Similar Condition
                                                                      Was Noted in Prior Year Finding 2020-004)

         2021-005     10.551     Supplemental Nutrition Assistance    A    Material    Weakness     and    Material        MNC          ND          DHS         61      106
            **        10.561     Program (SNAP) Cluster (including    Noncompliance Exist at the Department of
                                 COVID-19)                            Human Services Related to Electronic Benefits
                      93.558     Temporary Assistance for Needy       Transfer Card Security (A Similar Condition
                                 Families                             Was Noted in Prior Year Finding 2020-005)
53

         2021-006     21.023     COVID 19 – Emergency Rental          A Significant Deficiency and Noncompliance            NC          ND          DHS         64      107
            *                    Assistance Program                   Exist at the Department of Human Services
                                                                      Related to Submission of Emergency Rental
                                                                      Assistance Monthly and Quarterly Reporting

         2021-007     93.558     Temporary Assistance for Needy       Department of Human Services Did Not Validate         NC          ND          DHS         66      107
            *                    Families                             Financial Information as Part of Its On-Site
                                                                      Monitoring of Temporary Assistance for Needy
                                                                      Families Subrecipients (A Similar Condition
                                                                      Was Noted in Prior Year Finding 2020-006)




        *    - Significant Deficiency                                              MNC - Material Noncompliance
        ** - Material Weakness                                                     NC - Noncompliance
        ND - The amount of questioned costs cannot be determined                   N/A - Not Applicable
                                                                                   CAP - Corrective Action Plan
     COMMONWEALTH OF PENNSYLVANIA
     Index to Federal Award Findings and Questioned Costs - June 30, 2021
                                                                                                                                                      Impacted
         Finding                                                                                                            Compliance   Questioned     State    Finding   CAP
         Number        ALN         Assistance Listing Program Name                        Finding Title                     Conclusion     Costs       Agency      Page    Page


         2021-008     93.558     Temporary Assistance for Needy           Material     Weaknesses      and      Material       MNC         ND          DHS          68     108
            **                   Families                                 Noncompliance Exist in Monitoring of Foster
                      93.658     Foster Care – Title IV-E (including      Care, Adoption Assistance, and Temporary
                                 COVID-19)                                Assistance for Needy Families Subrecipients by
                      93.659     Adoption Assistance (including COVID-    the Department of Human Services’ Office of
                                 19)                                      Children, Youth, and Families (A Similar
                                                                          Condition Was Noted in Prior Year Finding
                                                                          2020-007)

         2021-009     93.775     Medicaid Cluster (including COVID-19)    A Significant Deficiency and Noncompliance            NC         None        DHS          71     109
            *         93.777                                              Exist at the Department of Human Services
                      93.778                                              Related to the Medicaid National Correct Coding
                                                                          Initiative (A Similar Condition Was Noted in
                                                                          Prior Year Finding 2020-010)

         2021-010     93.775     Medicaid Cluster (including COVID-19)    A Significant Deficiency and Noncompliance            NC         None        DHS          73     109
            *         93.777                                              Exist at the Department of Human Services
54                    93.778                                              Related to the Managed Care Financial Audit

         2021-011     17.225     Unemployment Insurance (including        A Significant Deficiency and Noncompliance            NC         ND           L&I         75     110
            *                    COVID-19)                                Exist Related to Eligibility of Unemployment
                      97.050     COVID-19 – Presidential Declared         Recipients
                                 Disaster Assistance to Individuals and
                                 Households – Other Needs

         2021-012     17.225     Unemployment Insurance (including        A Significant Deficiency Exists at the               N/A         None         L&I         78     111
            *                    COVID-19)                                Department of Labor and Industry Related to the
                                                                          Reemployment Services and Eligibility
                                                                          Assessments Program




        *    - Significant Deficiency                                                  MNC - Material Noncompliance
        ** - Material Weakness                                                         NC - Noncompliance
        ND - The amount of questioned costs cannot be determined                       N/A - Not Applicable
                                                                                       CAP - Corrective Action Plan
     COMMONWEALTH OF PENNSYLVANIA
     Index to Federal Award Findings and Questioned Costs - June 30, 2021
                                                                                                                                               Impacted
         Finding                                                                                                     Compliance   Questioned     State    Finding   CAP
         Number        ALN         Assistance Listing Program Name                  Finding Title                    Conclusion     Costs       Agency      Page    Page


         2021-013     16.575     Crime Victim Assistance             Information Technology General Controls Need        N/A        None       OA-OIT        80     111
            *                                                        Improvement (A Similar Condition Was Noted
                                                                     in Prior Year Finding 2020-015)

         2021-014     Various    Various ALNs – See Finding          State Agencies Did Not Identify the Federal         NC         ND         Various       82     111
            *                                                        Award      Information      and    Applicable
                                                                     Requirements at the Time of the Subaward and
                                                                     Did Not Evaluate Each Subrecipient’s Risk of
                                                                     Noncompliance as Required by the Uniform
                                                                     Grant Guidance (A Similar Condition Was
                                                                     Noted in Prior Year Finding 2020-020)

          2021-015    Various    Various ALNs – See Finding          A    Material   Weakness    and   Material         NC –         ND        Various       85      113
        *- Medicaid                                                  Noncompliance Exist in the Commonwealth’s        Medicaid
       ** - All Other                                                Subrecipient Audit Resolution Process (A          MNC –
         Programs                                                    Similar Condition Was Noted in Prior Year        All Other
                                                                     Finding 2020-021)                                Programs
55




        *    - Significant Deficiency                                             MNC - Material Noncompliance
        ** - Material Weakness                                                    NC - Noncompliance
        ND - The amount of questioned costs cannot be determined                  N/A - Not Applicable
                                                                                  CAP - Corrective Action Plan
COMMONWEALTH OF PENNSYLVANIA
Matrix of Findings by Federal Agency - June 30, 2021




Federal Agency   USDA   DOI    DOJ    DOL    DOT       TRE   ED   HHS   USDHS

    Prefix        10     15     16     17     20       21    84   93     97

   Finding

  2021-003                                                   X

  2021-004               X

  2021-005        X                                                X

  2021-006                                             X

  2021-007                                                         X

  2021-008                                                         X

  2021-009                                                         X

  2021-010                                                        X

  2021-011                             X                                 X

  2021-012                             X

  2021-013                      X

  2021-014                                    X                    X

  2021-015               X      X                                  X     X




                                        56
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Department of Education

Finding 2021 – 003:

ALN 84.425 – COVID 19 – Education Stabilization Fund

A Significant Deficiency and Noncompliance Exist at the Department of Education Related to Submission of
Elementary and Secondary School Emergency Relief Fund Annual Reporting

Federal Grant Number(s) and Year(s): S425D2 (3/13/2020 – 9/30/2022)

Type of Finding: Significant Deficiency, Noncompliance

Compliance Requirement: Reporting

Condition: As the State Educational Agency (SEA), the Pennsylvania Department of Education (PDE) is required to
submit an annual data report to the United States Department of Education (USDE). This report supports the annual
collection of data pertaining to the uses of funds under the Elementary and Secondary School Emergency Relief Fund
(ESSER). USDE awards ESSER grants to SEAs for the purpose of providing local educational agencies (LEAs), including
charter schools that are LEAs, with emergency relief funds to address the impact of the Novel Coronavirus Disease 2019
(COVID-19) on elementary and secondary schools across the nation. LEAs must provide equitable services to students
and teachers in non-public schools as required under the Coronavirus Aid, Relief, and Economic Security Act (CARES
Act).

During the fiscal year ended June 30, 2021, PDE was required to submit an annual report for the period March 13, 2020
to September 30, 2020 by February 1, 2021. As the direct recipient of ESSER funds, PDE is responsible for ensuring the
timeliness and accuracy of the annual report submission. PDE worked with USDE’s contractor and obtained summary
information from the LEAs to compile and submit the report. The report contained all required data elements. However,
PDE did not implement policies and procedures to ensure the accuracy of the information reported by the LEAs. Therefore,
PDE was unable to provide supporting documentation for amounts reported by LEAs on the annual report or to
demonstrate that they had reviewed and verified the accuracy of this information.

Criteria: The July 2021 OMB Compliance Supplement, Part 4, Section L.3.c, Reporting – Special Reporting – Annual
Reporting, states in part:

Direct recipients of ESSER I and ESSER II grants must submit an annual report [OMB No. 1810-0749] with data for the
following categories:

         • Overall ESSER I and ESSER II Fund Grant for SEA;
         • SEA Reserve (up to 10 percent of total allocation);
         • Mandatory Subgrants to LEAs, Section 18003(c) of the CARES Act and Section 313(c) of the CRRSA Act…
         • Student Participation and Engagement; and
         • Full-Time Equivalent (FTE) Positions.

2 CFR Section 200.303, Internal controls, states:

The non-Federal entity must:

    (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that
        the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the
        terms and conditions of the Federal award. These internal controls should be in compliance with guidance in
        “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United
        States or the “Internal Control Integrated Framework”, issued by the Committee of the Sponsoring Organizations
        of the Treadway Commission (COSO).



                                                          57
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Finding 2021 – 003: (continued)
Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal
Government (Green Book), published in September 2014. The Green Book states in part:

Management should establish and operate monitoring activities to monitor the internal control system and evaluate the
results. Management should remediate identified internal control deficiencies on a timely basis.

Cause: PDE did not implement policies and procedures to ensure the accuracy of information reported by LEAs which
was included on the Annual Report.

Effect: Without review and validation of the detail supporting the summary information reported by LEAs, the Annual
Report may have contained inaccurate information.

Recommendation: We recommend that PDE implement formal policies and procedures to verify the information reported
by LEAs to be included on the Annual Report. Reported amounts should be reviewed for accuracy before reports are
submitted to USDE to ensure that reports filed are complete and accurate.

Agency Response: PDE agrees with the finding as written.

Questioned Costs: The amount of questioned costs cannot be determined.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


                                                          58
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Department of Environmental Protection

Finding 2021 – 004:

ALN 15.252 – Abandoned Mine Land Reclamation
A Material Weakness and Material Noncompliance Exist at the Department of Environmental Protection Related
to Subrecipient Monitoring (A Similar Condition Was Noted in Prior Year Finding 2020-004)

Federal Grant Number(s) and Year(s): S21AF10015 (4/01/2021 – 12/31/2021), S21AF10015 (1/01/2021 – 12/31/2023),
S20AF20092 (10/01/2020 – 09/30/2023), S20AF20006 (1/01/2020 – 12/31/2022), S19AF20006 (1/01/2019 – 12/31/2021),
S19AF20004 (12/01/2018 – 11/30/2021), S18AF20006 2018 (4/01/2018 – 12/31/2020), S18AF20004 (11/01/2017 –
10/31/2020), S16AF20042 (6/01/2016 – 5/31/2021)

Type of Finding: Material Weakness, Material Noncompliance

Compliance Requirement: Subrecipient Monitoring

Condition: The Department of Environmental Protection (DEP) administers the Abandoned Mine Land Reclamation
(AMLR) program funded by the United States Department of the Interior (DOI). During the fiscal year ended June 30,
2021, DEP expended $57,711,525 for the AMLR program, of which $8,783,233 was paid to 23 entities with whom DEP
executed subrecipient agreements to provide abandoned mine land reclamation repairs and services throughout
Pennsylvania. These subrecipient agreements included clauses requiring subrecipient Single Audits. Also, as a result of
the expenditures being recorded as subrecipient expenditures in the SAP accounting system, the expenditures were
reported as subrecipient expenditures to the federal government when they were automatically uploaded to the federal
USASpending system. Our audit testing disclosed that DEP did not conduct program monitoring of these subrecipient
expenditures during the fiscal year ended June 30, 2021.

Criteria: As part of administering the AMLR program, DEP must have policies, procedures, and controls in place to
ensure compliance with federal requirements within contract requirements and regulations.

2 CFR Section 200.332, Requirements for pass through entities, states in part:

All pass-through entities must:

(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; and that subaward
performance goals are achieved.

The standard contract agreement between DEP and the local grantee states, in part:

Audit/Compliance Review Requirements - The contractor must comply with all applicable federal and state grant
requirements including the Single Audit Act Amendments of 1996; 2 CFR Part 200 as amended; and any other applicable
law or regulation, and any amendment to such other applicable law or regulation that may be enacted or promulgated by
the federal government.

Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal
Government (Green Book), published in September 2014. The Green Book states in part:

Management should establish and operate monitoring activities to monitor the internal control system and evaluate the
results. Management should remediate identified internal control deficiencies on a timely basis.




                                                            59
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Finding 2021 – 004: (continued)
Cause: DEP management indicated that the 23 entities were contractors for whom subrecipient monitoring requirements
were not applicable, and the related expenditures were erroneously recorded in the SAP accounting system and on the
Commonwealth’s SEFA as subrecipient expenditures. DEP management stated that their policies and procedures are not
significantly different between the entities recorded as subrecipients and those recorded as contractors. However, as noted
in the finding condition, our audit disclosed that DEP executed subrecipient agreements with the 23 entities, some of whom
had Single Audits conducted, with the AMLR expenditures reported on the Single Audit SEFAs as required for
subrecipients.

In December 2019, DEP’s Bureau of Abandoned Mine Reclamation management decided that DEP would not approve
any additional agreements until the issue is resolved at both the federal and state levels. However, DEP management
stated that the agreements that were already in place would continue as executed. DEP did charge expenditures against
the previously executed agreements but did not execute any new agreements during the current audit period.

Effect: Without the timely completion of AMLR program subrecipient monitoring, DEP cannot ensure compliance with
federal statutes, regulations, and the terms and conditions of the subaward contracts, confirm that local subgrantees are
performing satisfactory work, ensure the efficient use of program resources, and minimize the risk for fraud and abuse.
Completing monitoring activities is essential for DEP to determine whether the local agencies are complying with federal
regulations and spending grant funds appropriately.

If contractors are misrepresented as subrecipients in the agreements and SAP accounting system, expenditures may be
incorrectly reported and unnecessary Single Audit burden has been created at the subrecipient level.

Recommendation: We recommend that DEP management make a determination of whether recipients with existing
agreements are contractors or subrecipients, and if changes are necessary, amend the agreements and correct the accounting
system to record subrecipient and contractor expenditures accurately. DEP should seek formal federal DOI approval to
revise any existing agreements to contractor agreements. DEP should also follow this determination consistently with
future agreements and accounting treatment.

DEP should also develop written policies and procedures for subrecipient monitoring and implement them immediately to
ensure timely subrecipient compliance with federal regulations.

Agency Response: DEP agrees with the facts as presented in the finding.

Questioned Costs: The amount of questioned costs cannot be determined.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


                                                            60
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Department of Human Services

Finding 2021 – 005:

ALN 10.551 and 10.561 – Supplemental Nutrition Assistance Program (SNAP) Cluster
 (including COVID-19)
ALN 93.558 – Temporary Assistance for Needy Families

A Material Weakness and Material Noncompliance Exist at the Department of Human Services Related to
Electronic Benefits Transfer Card Security (A Similar Condition Was Noted in Prior Year Finding 2020-005)

Federal Grant Number(s) and Year(s): 211PA405S2514 (10/01/2020 – 9/30/2021), 201PA405S2514 (10/01/2019 –
9/30/2020), 2101PATANF (10/01/2020 – 9/30/2021), 2001PATANF (10/01/2019 – 9/30/2020)

Type of Finding: Material Weakness, Material Noncompliance

Compliance Requirement: Special Tests and Provisions related to EBT Card Security

Condition: During our audit of the Supplemental Nutrition Assistance Program (SNAP) administered by the Department
of Human Services (DHS), we evaluated the security over Electronic Benefits Transfer (EBT) cards, which includes both
the physical security of EBT cards during the issuance process at County Assistance Offices (CAO), as well as the handling
of EBT cards returned from the United States Postal Service as undeliverable, or those that have been lost or stolen. EBT
cards are the method by which SNAP benefit payments are made available to recipients. Also, EBT cards are the primary
method by which cash and special allowance benefit payments are made available to Temporary Assistance for Needy
Families (TANF) recipients. Total benefit expenditures for SNAP for the fiscal year ended June 30, 2021 totaled $4.9
billion. Total benefit expenditures for TANF for the fiscal year ended June 30, 2021 totaled $111.2 million.

Fourteen of the 87 CAO and district locations that issued EBT cards were selected for site testing in the current audit
period. During our review of the physical security over EBT cards, we noted exceptions at all CAO and district locations
selected for testing. These exceptions included the following:

    1) Certain EBT personnel interviewed were unable to adequately answer all questions regarding EBT Security
       policies and procedures (1 district office and 4 locations);
    2) The ending inventory count of EBT cards at June 30, 2021 which was calculated using the weekly log including
       July 1, 2020, the daily logs for the fiscal year ended June 30, 2021, and the EBT shipment logs for the fiscal year
       ended June 30, 2021 did not reconcile to the inventory count on the weekly log including June 30, 2021 in the
       EBT Card Tracking Database (2 district offices and 9 locations);
    3) The EBT card issuance total on the Over the Counter (OTC) Card Reconciliation Report for the fiscal year ended
       June 30, 2021 provided by the EBT Project Office did not reconcile to the daily logs for the fiscal year ended
       June 30, 2021 in the EBT Card Tracking Database (2 district offices and 8 locations);
    4) Failure to perform the following:

             •    Appoint an Alternate EBT Coordinator (1 district office and 1 location);
             •    Completion of the witness field on an EBT Shipment Verification Log (1 location);
             •    Completion of the witness field on a Ribbon Installation and Destruction Log (1 location);
             •    Create adequate written internal procedures for EBT Security for over the counter card mailings (6
                  locations);
             •    Designate a manager or supervisor to the Alternate EBT Coordinator role (1 location);
             •    Destroy paper EBT logs after four years (2 locations);
             •    Ensure that coverage for card pinning is available until 5:00 PM each business day (1 location);
             •    Locate shipping manifest to support the EBT Shipments Verification Log (1 location);




                                                           61
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Finding 2021 – 005: (continued)

             •    Maintain adequate segregation of duties when completing the Weekly Log in the EBT Card Tracking
                  Database. A user edited the Weekly Log after it was approved (1 location);
             •    Maintain adequate security of EBT Cards (5 locations);
             •    Maintain adequate security of pinning device (4 locations);
             •    Maintain adequate security of ribbons, paper EBT logs, and Electronic Payment Processing and
                  Information Control (EPPIC) EBT Systems Application forms (2 locations);
             •    Proper completion of the date field on the EBT Shipment Verification Log (1 location);
             •    Proper completion of the requestor field on the EPPIC EBT Systems Application forms (2 district offices
                  and 9 locations);
             •    Retain paper EBT logs for four years (1 location);
             •    Retain EPPIC EBT Systems Application forms electronically (2 district offices and 1 location);
             •    Timely completion and submission of the EPPIC EBT Systems Application forms to the Office of
                  Income Maintenance EBT Security (1 location).

Forty of the 261 business days in the current audit period were selected to review the handling and destruction of returned
EBT cards. During our review of the handling and destruction of returned EBT cards, we noted exceptions on two of the
forty business days selected for testing. These exceptions included the following:

    1) Failure to properly complete the EBT Headquarters Card Destruction Log. The "Cards Destroyed By" column
       of the EBT Headquarters Card Destruction Log was signed and dated by the clerk two days prior to the daily log
       date.
    2) Failure to properly complete the EBT Headquarters Card Destruction Log. The "Approved by Project Office"
       column of the EBT Headquarters Card Destruction Log was signed and dated by the supervisor one year earlier
       than the daily log date.

Criteria: The 2021 OMB Compliance Supplement, Part 4 – Agency Program Requirements for the SNAP Cluster, Special
Tests and Provisions – N.3 EBT Card Security, states:

The state is required to maintain adequate security over, and documentation/records for, EBT cards to prevent their theft,
embezzlement, loss, damage, destruction, unauthorized transfer, negotiation, or use (7 CFR Section 274.8(b)(3)).

7 CFR Section 274.5, Record retention and forms security, states:

(c) Accountable Documents.

(1) EBT cards shall be considered accountable documents. The State agency shall provide the following minimum security
and control procedures for these documents:

   i.    Secure storage;
  ii.    Access limited to authorized personnel;
 iii.    Bulk inventory control records;
 iv.     Subsequent control records maintained through the point of issuance or use; and
  v.     Periodic review and validation of inventory controls and records by parties not otherwise involved in maintaining
         control records.

45 CFR Section 75.302 applicable to TANF states:

(b) The financial management system of each non-Federal entity must provide for the following (see also §75.361, 75.362,
75.363, 75.364, and 75.365):




                                                            62
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Finding 2021 – 005: (continued)
(4) Effective control over, and accountability for, all funds, property, and other assets. The non-Federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes. See §75.303.

Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal
Government (Green Book), published in September 2014. The Green Book states in part:

Management should establish and operate monitoring activities to monitor the internal control system and evaluate the
results. Management should remediate identified internal control deficiencies on a timely basis.

Cause: Established policies and procedures were not followed consistently across CAO and district locations, which
resulted in ineffective internal controls over EBT card security.

Effect: Without adequate security controls over EBT cards, there exists the possibility of misappropriation and/or abuse.

Recommendation: We recommend that DHS monitor EBT card security at CAO and district locations on a regular basis
to improve consistency in the execution of documented policies and procedures.

Agency Response: DHS agrees with this finding.

Questioned Costs: The amount of questioned costs cannot be determined.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


                                                           63
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Department of Human Services

Finding 2021 – 006:

ALN 21.023 – COVID 19 – Emergency Rental Assistance Program

A Significant Deficiency and Noncompliance Exist at the Department of Human Services Related to Submission of
Emergency Rental Assistance Monthly and Quarterly Reporting

Federal Grant Number(s) and Year(s): G019649899 (3/13/2020 – 9/30/2021)

Type of Finding: Significant Deficiency, Noncompliance

Compliance Requirement: Reporting

Condition: Emergency Rental Assistance (ERA) 1 and ERA 2 state, local, and territorial recipients were required to
submit monthly and quarterly reports to the United States Department of the Treasury (US Treasury). The monthly reports
are brief two-question updates through which ERA recipients provide US Treasury with very high-level counts of the
numbers of households receiving assistance and the amounts of ERA funds distributed. The quarterly reports are in-depth
reports with data on an array of programmatic and financial information to provide transparency in the use and progress
of ERA funds. Monthly reports were required beginning with the month ending April 30, 2021, and quarterly reports were
required beginning with Quarter 1, covering the period of award date through March 30, 2021, and for Quarter 2, covering
the period of April 1 through June 30, 2021. As the direct recipient of ERA funds, the Department of Human Services
(DHS) is responsible for ensuring the timeliness and accuracy of the report submissions. DHS obtained report information
from subrecipients which was compiled and submitted by the due dates. The reports contained all required data elements,
however, DHS did not implement policies and procedures to ensure the accuracy of the information reported by the
counties. Therefore, DHS was unable to provide supporting documentation for amounts reported by county subrecipients
on the reports or to demonstrate that they had reviewed and verified the accuracy of this information.

Criteria: The Emergency Rental Assistance Program Reporting Guidance published by the US Treasury identifies several
steps in the reporting process:

    •    Recipients gather and maintain required information such as counts of applicants and participants; amounts paid
         directly or indirectly to tenants, landlords, and utility/home energy providers; amounts paid to subrecipients and
         contractors; and administrative expenses.

    •    Recipients will need to communicate with and gather required information from their subrecipients and
         contractors, if applicable.

    •    After manually entering or uploading the report information, Recipients must review the information entered or
         submitted to the online reporting forms for any errors and completeness. Following completion of the report in
         Treasury’s portal, the Recipient’s designated Authorized Representative for Reporting must certify to the
         authenticity and accuracy of the information provided and formally submit the report to Treasury.

2 CFR Section 200.303, Internal controls, states:

The non-Federal entity must:

    (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that
        the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the
        terms and conditions of the Federal award. These internal controls should be in compliance with guidance in
        “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United
        States or the “Internal Control Integrated Framework”, issued by the Committee of the Sponsoring Organizations
        of the Treadway Commission (COSO).



                                                            64
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Finding 2021 – 006: (continued)
Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal
Government (Green Book), published in September 2014. The Green Book states in part:

Management should establish and operate monitoring activities to monitor the internal control system and evaluate the
results. Management should remediate identified internal control deficiencies on a timely basis.

Cause: DHS did not implement policies and procedures to ensure the accuracy of information reported by counties which
was included on the reports.

Effect: Without review and validation of the detail supporting the summary information reported by counties, the reports
may have contained inaccurate information.

Recommendation: We recommend that DHS implement formal policies and procedures to verify the information
reported by counties to be included on the reports. Reported amounts should be reviewed for accuracy before reports are
submitted to US Treasury to ensure that reports filed are complete and accurate.

Agency Response: DHS agrees with this finding. DHS is working to validate information provided by counties for
federal submission. Given the urgent nature of this program, delay in receiving federal guidance, and state legislated
reporting, DHS has not yet validated county submittals for the payments made during the period from March 2021 through
June 30, 2021, as this new program was in response to a global health pandemic.

Questioned Costs: The amount of questioned costs cannot be determined.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


                                                          65
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Department of Human Services

Finding 2021 – 007:

ALN 93.558 – Temporary Assistance for Needy Families

Department of Human Services Did Not Validate Financial Information as Part of Its On-Site Monitoring of
Temporary Assistance for Needy Families Subrecipients (A Similar Condition Was Noted in Prior Year Finding
2020-006)

Federal Grant Number(s) and Year(s): 2101PATANF (10/01/2020 – 9/30/2021), 2001PATANF (10/01/2019 –
9/30/2020)

Type of Finding: Significant Deficiency, Noncompliance

Compliance Requirement: Subrecipient Monitoring

Condition: During the fiscal year ended June 30, 2021, the Department of Human Services (DHS) paid $69.2 million in
Temporary Assistance for Needy Families (TANF) funding to subrecipients within the New Directions, Cash Grants, and
Alternatives to Abortion appropriations (or 17.6 percent) out of total federal TANF expenditures of $391.4 million reported
on the June 30, 2021 Schedule of Expenditures of Federal Awards.

Our testing of DHS’s during-the-award monitoring of subrecipients for the fiscal year ended June 30, 2021 disclosed that
DHS performed on-site monitoring for all 15 subrecipients selected for testing. The on-site monitoring that was performed
consisted of reviews of program operations including design, data entry accuracy and timeliness, case management
analysis, and program payment performance goals. The on-site monitoring also included a review of a sample of TANF
recipient case files to ensure that the recipients’ TANF activities were documented and accurately entered in the
Commonwealth’s Workforce Development System. However, DHS’s monitoring procedures for the 15 subrecipients
were not adequate as they did not include a review or monitoring of subrecipient financial records, which would provide
an assessment of a subrecipient’s compliance with applicable federal regulations. Although DHS’s monitoring procedures
include reviewing subrecipient completed questionnaires for selected subrecipients that had questions related to financial
matters, DHS’s monitoring personnel did not review subrecipient financial records. For example, DHS did not perform
procedures to ensure subrecipient invoices agreed to the books and records of the subrecipient and that the records were
adequate to support the allowability of costs paid by DHS during the award period. In addition, DHS’s monitoring
procedures did not include an evaluation of the operating effectiveness of DHS subrecipients’ procedures to monitor Single
Audits and any related findings.

In addition to the 15 subrecipients noted above, we followed up on one subrecipient identified in the prior year finding as
not being on-site monitored by DHS when the risk assessment warranted on-site monitoring. Our follow-up on DHS’s
monitoring of this subrecipient during the current audit period disclosed that DHS personnel began to perform on-site
monitoring on this subrecipient. However, the on-site monitoring was not completed at the time we completed our on-site
monitoring testing. Since the on-site monitoring was not completed, internal control weaknesses, noncompliance, and
questioned costs may have existed and remained undetected during the current audit period. This subrecipient received
approximately $815,000 of TANF funds during the fiscal year ended June 30, 2021.

Criteria: 45 CFR Section 75.352, Requirements for pass-through entities, states:

(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; and that subaward
performance goals are achieved. Pass-through entity monitoring of the subrecipient must include:

    (1) Reviewing financial and performance reports required by the pass-through entity.




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Federal Award Findings and Questioned Costs - June 30, 2021

Finding 2021 – 007: (continued)
    (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining
    to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site
    reviews, and other means.

    (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient...

2 CFR Section 200.332, Requirements for Pass-through Entities, states in part:

All pass-through entities must:

(e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b)
of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability
and compliance with program requirements and achievement of performance goals:

    (1) Providing subrecipients with training and technical assistance on program-related matters; and

    (2) Performing on-site reviews of the subrecipient's program operations;

    (3) Arranging for agreed-upon-procedures engagements as described in §200.425 [Audit services].

Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal
Government (Green Book), published in September 2014. The Green Book states in part:

Management should establish and operate monitoring activities to monitor the internal control system and evaluate the
results. Management should remediate identified internal control deficiencies on a timely basis.

Cause: DHS has not implemented adequate during-the-award monitoring procedures of subrecipients to include testing
of the financial records and the subrecipients’ monitoring of Single Audits sufficient to ensure compliance with federal
regulations. In addition, as indicated in DHS’s corrective action plan for the prior year finding, DHS planned to implement
new procedures to be used for the on-site monitoring performed during the current audit period. However, as indicated
above, the updated procedures were not implemented for the current audit period.

Regarding the aforementioned subrecipient for which on-site monitoring was not completed, DHS personnel stated that
they are working with the subrecipient to obtain the necessary documentation to complete the on-site monitoring.

Effect: TANF subrecipients could be operating in noncompliance with federal regulations without timely detection and
correction by DHS management.

Recommendation: DHS should strengthen its controls to ensure during-the-award monitoring of TANF subrecipients
includes procedures to ensure that subrecipients are in compliance with applicable federal regulations, including ensuring
that all required Single Audits were obtained by all DHS subrecipients.

Agency Response: DHS agrees with this finding.

Questioned Costs: The amount of questioned costs cannot be determined.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


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Department of Human Services

Finding 2021 – 008:

ALN 93.558 – Temporary Assistance for Needy Families
ALN 93.658 – Foster Care – Title IV-E (including COVID-19)
ALN 93.659 – Adoption Assistance (including COVID-19)

Material Weaknesses and Material Noncompliance Exist in Monitoring of Foster Care, Adoption Assistance, and
Temporary Assistance for Needy Families Subrecipients by the Department of Human Services’ Office of Children,
Youth, and Families (A Similar Condition Was Noted in Prior Year Finding 2020-007)

Federal Grant Number(s) and Year(s): 2101PATANF (10/01/2020 – 9/30/2021), 2001PATANF (10/01/2019 –
9/30/2020), 1901PATANF (10/01/2018 – 9/30/2019), 1801PATANF (10/01/2017 – 9/30/2018), 2101PAFOST
(10/01/2020 – 9/30/2021), 2001PAFOST (10/01/2019 – 9/30/2020), 2101PAADPT (10/01/2020 – 9/30/2021),
2001PAADPT (10/01/2019 – 9/30/2020)

Type of Finding: Material Weakness, Material Noncompliance

Compliance Requirement: Subrecipient Monitoring

Condition: The Department of Human Services’ (DHS) Office of Children, Youth, and Families (OCYF) performs two
types of during-the-award monitoring of its 67 subrecipient County Children and Youth Agencies (CCYAs). One group
within OCYF performs on-site inspections to support its reissuance of licenses for all 67 CCYAs to whom DHS subgrants
funds to perform Foster Care, Adoption Assistance services, and Temporary Assistance for Needy Families (TANF) Child
Welfare. These inspections primarily focus on health, safety, and performance issues, and each on-site inspection is
documented on an Annual Survey and Evaluation Summary. A license, or certificate of compliance, is issued for a period
of one year if the results of the on-site inspection determine the entity is in compliance with statutes, ordinances, and
regulations.

In addition, a separate group within DHS’s OCYF performs Title IV-E Quality Assurance Compliance Reviews which
primarily focus on eligibility and allowability. These two types of on-site monitoring visits are not performed at the same
time. To test DHS’s licensing/inspections and Quality Assurance Compliance Reviews in the current year, we selected 13
of the 67 CCYAs receiving Foster Care, Adoption Assistance, and TANF funds.

Our current year testing of the on-site licensing inspections disclosed the following exceptions:

     •   On-site inspections of two of the 13 CCYAs tested were not completed within 12 months of the completion of
         the prior on-site inspection. One of the current year inspections was completed four months late and one of the
         current year inspections was completed 5 months late.

     •   On-site inspections of three of the 13 CCYAs tested were either not reviewed and approved timely, or not
         reviewed and approved at all by a supervisor and a regional director. The inspections were approved between 1
         and 207 days after the expiration of the prior license.

Also, as part of our testing of monitoring, we noted that DHS did not have adequate procedures in place to determine if
CCYAs were monitoring their subrecipients. Specifically, DHS did not perform procedures to determine if CCYAs were
monitoring Single Audits of subrecipients and evaluating the follow-up of any findings, or that CCYAs were only paying
for allowable services.

Foster Care program payments made by DHS to its 67 CCYA subrecipients during the fiscal year ended June 30, 2021
were $204.5 million, or 89.8 percent of total Foster Care expenditures of $227.8 million reported on the June 30, 2021
Schedule of Expenditures of Federal Awards (SEFA). Adoption Assistance program payments made by DHS to its



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Finding 2021 – 008: (continued)
67 CCYA subrecipients during the fiscal year ended June 30, 2021 were $118.6 million, or 75.9 percent of total Adoption
Assistance expenditures of $156.3 million reported on the June 30, 2021 SEFA. TANF Child Welfare program payments
made by DHS to its 67 CCYA subrecipients during the fiscal year ended June 30, 2021 were $48.6 million, or 12.4 percent
of total TANF expenditures of $391.4 million reported on the June 30, 2021 SEFA.

Criteria: 45 CFR Section 75.352, applicable to TANF, Foster Care, and Adoption Assistance states:

(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; and that subaward
performance goals are achieved. Pass-through entity monitoring of the subrecipient must include:

    (1) Reviewing financial and performance reports required by the pass-through entity.

    (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining
    to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site
    reviews, and other means.

    (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient…

Pennsylvania Code Title 55, Chapter 20, Licensure or Approval of Facilities and Agencies, Section 20.51 states:

A certificate of compliance will be issued to the legal entity by the Department if, after an inspection by an authorized
agent of the Department, it is determined that requirements for a certificate of compliance are met.

In addition, Pennsylvania Code Title 55, Chapter 20, Section 20.52 states:

If, during an inspection, authorized agents of the Department observe items of noncompliance with licensure or approval
regulations, the legal entity shall submit an acceptable written plan to correct each noncompliance item and shall establish
an acceptable period of time to correct these items.

Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal
Government (Green Book), published in September 2014. The Green Book states in part:

Management should establish and operate monitoring activities to monitor the internal control system and evaluate the
results. Management should remediate identified internal control deficiencies on a timely basis.

Cause: DHS personnel indicated that the two on-site inspections that were not completed within 12 months of the prior
inspection and the three inspections that were not timely reviewed and approved by a supervisor or a regional director
were due to the COVID-19 pandemic, which caused a delay in scheduling the on-site inspections, as well as the subsequent
review and approvals.

DHS believes that its current monitoring procedures to determine subrecipient eligibility, monitor programmatic
operations, review subrecipient audits, and review subrecipient agreed-upon-procedure reports are sufficient to effectively
monitor its subrecipients or contractors.




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Finding 2021 – 008: (continued)
Effect: DHS OCYF’s failure to perform timely on-site inspections and the subsequent reviews and approvals of the
inspection reports before the expiration of the prior license allowed the CCYAs to operate without a proper license for an
extended period of time. Also, since DHS did not determine if CCYAs were monitoring their subrecipients, CCYAs could
be operating in noncompliance with federal regulations without timely detection and correction by DHS management.

Recommendation: DHS’s OCYF should strengthen its controls to ensure monitoring and inspections of Foster Care,
Adoption Assistance, and TANF subrecipients are performed and reviewed by management on a timely basis and include
procedures to ensure CCYAs are monitoring their subrecipients or contractors.

Agency Response: DHS agrees with this finding.

Questioned Costs: The amount of questioned costs cannot be determined.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


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Department of Human Services

Finding 2021 – 009:

ALN 93.775, 93.777, and 93.778 – Medicaid Cluster (including COVID-19)

A Significant Deficiency and Noncompliance Exist at the Department of Human Services Related to the Medicaid
National Correct Coding Initiative (A Similar Condition Was Noted in Prior Year Finding 2020-010)

Federal Grant Number(s) and Year(s): 2105PA5MAP (10/01/2020 – 9/30/2021), 2105PA5ADM (10/01/2020 –
9/30/2021), 2005PA5MAP (10/01/2019 – 9/30/2020), 2005PA5ADM (10/01/2019 – 9/30/2020)

Type of Finding: Significant Deficiency, Noncompliance

Compliance Requirement: Special Tests and Provisions related to the Medicaid National Correct Coding Initiative
(NCCI)

Condition: The Pennsylvania Department of Human Services (DHS) is required by the United States Department of
Health and Human Services (HHS), Centers for Medicare and Medicaid Services (CMS), to implement six required
Medicaid National Correct Coding Initiative (NCCI) methodologies. These methodologies include procedure-to-
procedure and medically unlikely edits of Medicaid fee-for-service claims submitted for processing through DHS’s
PROMISe system to ensure that only proper payments of Medicaid procedures are reimbursed. As part of this process,
DHS is required to download quarterly NCCI edit tables from CMS which are subsequently uploaded into PROMISe by
DHS’s PROMISe vendor.

During the fiscal year ended June 30, 2021, DHS did not ensure that its contract with the PROMISe vendor included the
NCCI Confidentiality Agreement required by the HHS/CMS Medicaid NCCI Technical Guidance Manual.

Criteria: Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the
internal control framework outlined in the United States Government Accountability Office’s Standards for Internal
Control in the Federal Government (Green Book), published in September 2014. The Green Book states in part:

Management should identify, analyze, and respond to significant changes that could impact the internal control system.

The HHS/CMS Medicaid NCCI Technical Guidance Manual, Section 7.1.2, Sharing of State Medicaid NCCI Edit Files by
States with Other Entities, states in part:

A state Medicaid agency may share these quarterly state Medicaid NCCI edit files which are posted on the secure RISSNET
[Regional Information Sharing System Network] portal with the contracted fiscal agent that processes its fee-for-service
claims or with any of its contracted Medicaid managed-care entities that is using the Medicaid NCCI methodologies in its
processing of claims or encounter data, if appropriate confidentiality agreements are in place.

The HHS/CMS Medicaid NCCI Technical Guidance Manual, Section 7.1.3, Confidentiality Agreements Requirements for
Contracted Parties, states:

At a minimum, the following elements must be included in the confidentiality agreements for any contracted party using
the Medicaid NCCI files posted on the secure RISSNET portal:

Disclosure shall be limited to only those responsible for the implementation of the quarterly state Medicaid NCCI edit
files.




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Finding 2021 – 009: (continued)
After the start of the new calendar quarter, a contracted party may disclose only non-confidential information contained
in the Medicaid NCCI edit files that is also available to the general public found on the Medicaid NCCI webpage.

The contracted party agrees to use any non-public information from the quarterly state Medicaid NCCI edit files only for
any business purposes directly related to the implementation of the Medicaid NCCI methodologies in the particular state.

New, revised, or deleted Medicaid NCCI edits shall not be published or otherwise shared with individuals, medical
societies, or any other entities unless it is a contracted party prior to the posting of the Medicaid NCCI edits on the
Medicaid NCCI webpage.

Implementation of new, revised, or deleted Medicaid NCCI edits shall not occur prior to the first day of the calendar
quarter.

Only a state Medicaid agency has the discretion to release additional information for selected individual edits or limited
ranges of edits from the files posted on the secure RISSNET portal.

State Medicaid agencies must impose penalties, up to and including loss of contract, for violations of any confidentiality
agreement relating to use of the secure RISSNET portal edit files.

Cause: DHS personnel stated that the confidentiality agreement required by the HHS/CMS Medicaid NCCI Technical
Guidance Manual was not included in the PROMISe contract, since the contract was finalized prior to the HHS issuance
of the NCCI requirements.

Effect: Since DHS did not ensure the required NCCI Confidentiality Agreement was included in its contract with the
PROMISe vendor, DHS was not in compliance with federal regulations.

Recommendation: DHS should ensure the required NCCI Confidentiality Agreement is included in an amendment to its
contract with the PROMISe vendor.

Agency Response: DHS agrees with this finding.

Questioned Costs: None




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


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Department of Human Services

Finding 2021 – 010:

ALN 93.775, 93.777, and 93.778 – Medicaid Cluster (including COVID-19)

A Significant Deficiency and Noncompliance Exist at the Department of Human Services Related to the Managed
Care Financial Audit

Federal Grant Number(s) and Year(s): 2105PA5MAP (10/01/2020 – 9/30/2021), 2105PA5ADM (10/01/2020 –
9/30/2021), 2005PA5MAP (10/01/2019 – 9/30/2020), 2005PA5ADM (10/01/2019 – 9/30/2020)

Type of Finding: Significant Deficiency, Noncompliance

Compliance Requirement: Special Tests and Provisions related to the Managed Care Financial Audit

Condition: The Pennsylvania Department of Human Services (DHS) administers the Medicaid Cluster for which
expenditures reported on the fiscal year ended June 30, 2021 Schedule of Expenditures of Federal Awards totaled
$23,828,691,242. DHS is required by the United States Department of Health and Human Services (HHS), Centers for
Medicare and Medicaid Services (CMS), to obtain two types of audits for Medicaid Cluster managed care: annual audited
financial reports and periodic audits. The periodic audits concern the accuracy, truthfulness, and completeness of the
encounter and financial data submitted by, or on behalf of, each managed care organization (MCO), and the periodic audit
results are required to be posted on DHS’s website.

During the fiscal year ended June 30, 2021, periodic audits were required for MCOs used for behavioral health, long-term
care, and physical health. Periodic audit reports for behavioral health were obtained, and the results were properly posted
to DHS’s website. DHS’s Office of Long-Term Living (OLTL) obtained all three required periodic audit reports for the
long-term care MCOs, but OLTL did not ensure the periodic audit reports’ results were posted on DHS’s website as
required by HHS. DHS’s Office of Medical Assistance Programs (OMAP) did not obtain one required periodic audit
report for the physical health MCOs, so the periodic audit’s results were not available to be posted on DHS’s website as
required by HHS.

Criteria: 42 CFR Section 438.602, State responsibilities, states:

(e) Periodic audits. The State must periodically, but no less frequently than once every 3 years, conduct, or contract for
the conduct of, an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data
submitted by, or on behalf of, each MCO, PIHP [Prepaid Inpatient Health Plan], or PAHP [Prepaid Ambulatory Health
Plan].

(g) Transparency. The State must post on its website, as required in §438.10(c)(3), the following documents and reports:

(4) The results of any audits under paragraph (e) of this section.

Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal
Government (Green Book), published in September 2014. The Green Book states in part:

Management should identify, analyze, and respond to significant changes that could impact the internal control system.




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Finding 2021 – 010: (continued)
Cause: DHS’s OLTL personnel stated that the periodic audit reports’ results were not posted to DHS’s website due to an
oversight. DHS’s OMAP personnel represented the periodic audit was in process but the audit report was not complete,
so there were no results available to post to DHS’s website.

Effect: Since DHS did not ensure all periodic audit reports were completed, and the periodic audit report results were not
all posted to DHS’s website, DHS was not in compliance with federal regulations.

Recommendation: DHS’s OMAP should implement procedures to timely obtain the required periodic audit reports.
OLTL and OMAP should implement procedures to post the periodic audit reports’ results to the DHS website.

Agency Response: DHS agrees with this finding.

Questioned Costs: None




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


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Federal Award Findings and Questioned Costs - June 30, 2021

Department of Labor and Industry

Finding 2021 – 011:

ALN 17.225 – Unemployment Insurance (including COVID-19)
ALN 97.050 – COVID-19 – Presidential Declared Disaster Assistance to Individuals and
 Households – Other Needs

A Significant Deficiency and Noncompliance Exist Related to Eligibility of Unemployment Recipients

Federal Grant Number(s) and Year(s): C10164 (7/1/2020 – 6/30/2021), C29020 (7/1/2020 – 6/30/2021), C29120
(7/1/2020 – 6/30/2021), C29420 (7/1/2020 – 6/30/2021), C28420 (7/1/2020 – 6/30/2021)

Type of Finding: Significant Deficiency, Noncompliance

Compliance Requirement: Eligibility

Condition: During the fiscal year ended June 30, 2021, several presidential acts including the Coronavirus Aid, Relief,
and Economic Securities Act of 2020, the Continued Assistance for Unemployed Workers Act of 2020, and the American
Rescue Plan Act of 2021 were in effect or signed into law authorizing additional funding under both the Unemployment
Insurance program and the Presidential Declared Disaster Assistance to Individuals and Households – Other Needs
program. This federal funding administered by the Pennsylvania Department of Labor and Industry (L&I) was significant
and expanded program eligibility to include individuals affected by changes in employment status resulting from the
COVID-19 pandemic. In accordance with the federal guidance in the Unemployment Insurance Program Letter (UIPL)
16-20, dated April 5, 2020, L&I management implemented a self-attestation strategy through January 2021 to expedite the
disbursement of funds to the individuals with the greatest need. Federal guidance on self-attestation did not change until
the issuance of UIPL 16-20, Change 4, dated January 8, 2021, when L&I management implemented additional changes in
procedures. UIPL 16-20, Change 4, introduced the requirement to obtain documentation of employment/self-employment
or the planned commencement of employment/self-employment.

During the period under self-attestation, several states, including Pennsylvania, experienced significant fraudulent claims.
As a result, the United States Department of Labor (USDOL) and L&I, as well as other federal and state authorities, have
partnered to investigate the extent and methods used to perpetuate the fraud and to identify program improvements. L&I
management implemented ID.me in October 2020 to strengthen verification procedures to authenticate claimants in the
Pandemic Unemployment Assistance (PUA) system. Through January 2021, eligibility determinations made by L&I’s
management followed the existing policies and procedures for this COVID-19 pandemic funding. However, in order to
meet federal and state expectations of timely disbursement, the policies and procedures by design did not include adequate
verification procedures for eligibility throughout the fiscal year under audit. The procedures and policies accommodations
contributed to vulnerabilities within the unemployment programs.

We also performed certain tests of information technology (IT) general controls as part of our audit of the Annual
Comprehensive Financial Report, which included tests of applications that supported activities which were material to the
Commonwealth’s financial statements. Basic Financial Statement Finding 2021 – 002, which was reported for the
Commonwealth for the fiscal year ended June 30, 2021, disclosed internal control deficiencies in applications supporting
the unemployment major programs.

Criteria: 2 CFR Section 200.303, Internal controls, states:




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COMMONWEALTH OF PENNSYLVANIA
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Finding 2021 – 011: (continued)
The non-Federal entity must:

(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the
non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal
Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).

29 CFR 97.20(b), Standards for financial management systems, states in part:

(3) Internal Control. Effective control and accountability must be maintained for all grant and subgrant cash, real and
personal property, and other assets. Grantees and subgrantees must adequately safeguard all such property and must
assure that it is used solely for authorized purposes.

Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal
Government (Green Book), published in September 2014. The Green Book states in part:

Management should consider the potential for fraud when identifying, analyzing, and responding to risks.

Management should identify, analyze, and respond to significant changes that could impact the internal control system.

The July 2021 OMB Compliance Supplement, Part 4, states:

State Workforce Agencies (SWA) responsibilities include: (1) establishing specific, detailed policies and operating
procedures which comply with the requirements of federal laws and regulations; (2) determining the state UI tax structure;
(3) collecting state UI contributions from employers (commonly called “unemployment taxes”); (4) determining claimant
eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s
revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and
procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations
substantially comply with federal law.

Cause: Pennsylvania experienced unprecedented claims volume with increased funding and additional program
requirements with a priority for efficient distribution from both the USDOL and Commonwealth officials. Commonwealth
management made decisions to relax verification procedures to meet demand and program expectations. During the fiscal
year several verification procedures including ID.me and data cross checks were implemented to assist in determining the
extent of fraudulent activity, and to detect and prevent the filing of further fraudulent claims.

Effect: The unemployment programs became more vulnerable to fraudulent claims due to the relaxing of verification
procedures.

Recommendation: We recommend that L&I management implement additional internal controls to efficiently verify
program eligibility while providing timely payment to program beneficiaries.




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Finding 2021 – 011: (continued)
Agency Response: The Department acknowledges the issuance of this finding. Pennsylvania is tasked with following
federal guidelines in the processing of all types of unemployment insurance.

Questioned Costs: Undetermined and under investigation by federal and state authorities.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


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COMMONWEALTH OF PENNSYLVANIA
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Department of Labor and Industry

Finding 2021 – 012:

ALN 17.225 – Unemployment Insurance (including COVID-19)

A Significant Deficiency Exists at the Department of Labor and Industry Related to the Reemployment Services
and Eligibility Assessments Program

Federal Grant Number(s) and Year(s): C10164 (7/1/2020 – 6/30/2021), C29020 (7/1/2020 – 6/30/2021), C29120
(7/1/2020 – 6/30/2021), C29420 (7/1/2020 – 6/30/2021)

Type of Finding: Significant Deficiency

Compliance Requirement: Special Tests and Provisions related to Unemployment Insurance (UI) Reemployment
Programs: Worker Profiling and Reemployment Services (WPRS) and Reemployment Services and Eligibility
Assessments (RESEA)

Condition: During the fiscal year ended June 30, 2021, the Department of Labor and Industry (L&I) was required to
administer reemployment services for the Unemployment Insurance (UI) program. The Commonwealth of Pennsylvania
elected to operate the Reemployment Services and Eligibility Assessments (RESEA) program to satisfy the Worker
Profiling and Reemployment Services (WPRS) federal mandate which was permitted by federal requirements.

The RESEA program enables claimants who are most likely to exhaust their benefits to access services that assist them to
return to work or provide assistance in areas such as job search or placement, job markets, and testing. Claimant
participants work with a case administrator (administrator) throughout the program, and the administrators are supervised
by a case manager. L&I’s program procedures are outlined in the Labor and Industry RESEA Manual which details
claimant selection, eligibility, and the intervention process performed by the administrator to assist participating claimants.

The Commonwealth of Pennsylvania’s RESEA program was suspended for the first half of the 2021 fiscal year due to the
COVID-19 pandemic and became operational again in January 2021. L&I management indicated that case managers can
use reporting tools to monitor that cases are proceeding and being completed as required. Additionally, administrators can
use a comprehensive checklist from the RESEA Manual to ensure that all elements of the program are being satisfied for
each case. In order to test the RESEA requirements for the period of January 2021 until the fiscal year end of June 30,
2021, a sample of 40 out of 4,087 claimant cases that completed the program during that time period was selected for
testing. No noncompliance was identified. However, we were unable to test the operating effectiveness of certain internal
control procedures at the case level, since supporting documentation for reporting tools and checklists was not maintained
for 31 of the 40 cases tested.

Criteria: 2 CFR Section 200.303, Internal controls, states:

The non-Federal entity must:

(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the
non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal
Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).

Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal
Government (Green Book), published in September 2014. The Green Book states in part:




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Finding 2021 – 012: (continued)
Management should design control activities to achieve objectives and respond to risks.

Management should establish and operate monitoring activities to monitor the internal control system and evaluate the
results. Management should remediate identified internal control deficiencies on a timely basis.

Cause: According to L&I management, the reporting tools and checklist were optional and could be used by
administrators and case managers at their discretion. As a result, these control measures were not being applied and/or
documented consistently from case to case.

Effect: The lack of adequate internal controls over compliance in the RESEA program could result in improper
identification of claimants and insufficient services resulting in federal noncompliance. Although noncompliance was not
identified by our audit procedures, fully operational controls would enable case administrators and managers to ensure
compliance with program requirements and to timely prevent and detect instances of noncompliance.

Recommendation: We recommend that L&I management require the use of the checklist and/or reporting tools to
strengthen internal controls and to ensure verification of all elements of the RESEA program are occurring, accurate, and
complete. Also, L&I management should ensure that proper documentation of the use of these tools is maintained.

Agency Response: In the recent Single Audit conducted on the RESEA program for the fiscal year ended June 30, 2021,
it was determined that the program was lacking internal controls. It was recommended through the audit that the staff
checklist for the RESEA program provided in the RESEA Policy and Procedures Desk Guide be a mandatory requirement.
The L&I management team agrees that this checklist become mandatory. The updated RESEA staff checklist will be
completed for each RESEA participant. The supervisor will review each RESEA participant’s file to ensure all portions
of the program have been completed, and both the staff member and the supervisor will sign off, acknowledging their
review.

The RESEA Checklist has been sent to all Pennsylvania CareerLink Program Supervisors and Career Advisors/Trainees
to notify them of this new mandatory requirement and the requirement to retain the checklist in the participant’s file.

In addition, the RESEA Policy and Procedures Desk Guide will be updated to reflect this mandatory new requirement for
staff.

Questioned Costs: None




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


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Office of Administration – Office for Information Technology

Finding 2021 – 013:

ALN 16.575 – Crime Victim Assistance

Information Technology General Controls Need Improvement (A Similar Condition Was Noted in Prior Year
Finding 2020-015)

Federal Grant Number(s) and Year(s): 2020-V2-GX-0063 (10/01/2019 – 9/30/2023), 2019-V2-GX-0026 (10/01/2018
– 9/30/2022), 2018-V2-GX-0068 (10/01/2017 – 9/30/2021), 2017-VA-GX-0069 (10/01/2016 – 9/30/2020)

Type of Finding: Significant Deficiency

Compliance Requirement: Other

Condition: As part of testing internal controls over major programs, we performed certain tests of information technology
(IT) general controls, including procedures to determine the status of prior year Single Audit Finding 2020 – 015. Our
procedures disclosed the following control deficiencies in an application supported by the Public Safety Delivery Center
that impacted the Crime Victim Assistance program:

    1.     As noted in the prior year, we found a lack of segregation of duties between application development and
           promotion of code to production.

    2.     Five administrator accounts on servers managed by the Enterprise Data Center (EDC) were not removed timely
           after the users separated employment. These five accounts had full administrative access rights to the major
           program’s application and database servers.

A detailed schedule of issues has been provided to the Office of Administration, Office for Information Technology (OA-
OIT), for corrective action.

Criteria: Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the
internal control framework outlined in the United States Government Accountability Office’s Standards for Internal
Control in the Federal Government (Green Book), published in September 2014.

•        Green Book Principle 11 – Design Activities for the Information System, states in part:

    o      11.04 Management designs the entity’s information system and the use of information technology… Additionally,
           information technology may enhance internal control over security and confidentiality of information by
           appropriately restricting access.

    o      11.12 Management designs control activities over access to protect an entity from inappropriate access and
           unauthorized use of the system. These control activities support appropriate segregation of duties. By preventing
           unauthorized use of and changes to the system, data and program integrity are protected from malicious intent
           (e.g., someone breaking into the technology to commit fraud, vandalism, or terrorism) or error.

    o      11.14 Management designs control activities to limit user access to information technology through authorization
           control activities such as providing a unique user identification or token to authorized users. These control
           activities may restrict authorized users to the applications or functions commensurate with their assigned
           responsibilities, supporting an appropriate segregation of duties. Management designs other control activities
           to promptly update access rights when employees change job functions or leave the entity.




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Finding 2021 – 013: (continued)
A well-designed system of internal controls dictates that effective general computer controls, which include adequate
segregation of duties, access controls to programs and data, appropriate monitoring, and controls to update access rights,
be established and functioning to ensure that overall agency operations are conducted in accordance with management’s
intent.

Cause: As noted in the prior year finding, developers continued to have administrative access to the change management
software tool. Although the tool was configured to log activity and send an automated email to a third party when a
developer approved code to production, no documentation was maintained as evidence that the logs or the email
notifications were monitored. As for the separated users whose accounts were not removed, the control to remove the
accounts at the time of separation failed, and the bi-annual access reviews performed by EDC administrators did not
identify these inappropriate accounts. When EDC moved to a quarterly review, the separated users’ accounts were
identified and removed prior to the end of the audit.

Effect: The deficiencies noted above in IT general controls could result in unauthorized changes to the software and
noncompliance with federal laws and regulations. Segregation of duties weaknesses and untimely removal of access when
no longer needed contribute to the risk that system activity can occur that is not in accordance with management’s intent.
Finally, without properly functioning controls over segregation of duties and separated users, the auditors are precluded
from reliance on computer controls in the Crime Victim Assistance program. Separately, not deleting accounts with
administrative access after the user separates employment increases the risk that accounts could be misused, intentionally
or unintentionally either by authorized users, or by unauthorized external entities that have compromised the account.

Recommendation: We recommend that OA-OIT continue its efforts to resolve the general computer control deficiencies
noted above. Specific consideration should be given to:

    •    Segregating the development of programs from promotion to the production environment;
    •    When segregation of duties is not possible, performing documented monitoring of the activities of developers
         who have the ability to implement code to production;
    •    Removing server administrator accounts timely upon user separation; and
    •    Conducting effective periodic access reviews of privileged users.

Agency Response: Office of Administration, Office for Information Technology (OA-OIT), agrees with this finding.

Questioned Costs: None




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


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Various Agencies

Finding 2021 – 014:

ALN 20.205 and 20.219 – Highway Planning and Construction Cluster (including COVID-19)
ALN 93.558 – Temporary Assistance for Needy Families
ALN 93.658 – Foster Care – Title IV-E (including COVID-19)
ALN 93.659 – Adoption Assistance (including COVID-19)
State Agencies Did Not Identify the Federal Award Information and Applicable Requirements at the Time of the
Subaward and Did Not Evaluate Each Subrecipient’s Risk of Noncompliance as Required by the Uniform Grant
Guidance (A Similar Condition Was Noted in Prior Year Finding 2020-020)

Federal Grant Number(s) and Year(s): N78000 (7/01/2020 – 6/30/2021), 2101PATANF (10/01/2020 – 9/30/2021),
2001PATANF (10/01/2019 – 9/30/2020), 1901PATANF (10/01/2018 – 9/30/2019), 1801PATANF (10/01/2017 –
9/30/2018), 2101PAFOST (10/01/2020 – 9/30/2021), 2001PAFOST (10/01/2019 – 9/30/2020), 2101PAADPT
(10/01/2020 – 9/30/2021), 2001PAADPT (10/01/2019 – 9/30/2020)

Type of Finding: Significant Deficiency, Noncompliance

Compliance Requirement: Subrecipient Monitoring

Condition: The Uniform Guidance in 2 CFR Section 200 applies to the major programs listed above for the fiscal year
ended June 30, 2021. Our testing disclosed that the state agencies did not identify the federal award information and
applicable requirements in subrecipient award documents. Additionally, the state agencies did not evaluate each
subrecipient’s risk of noncompliance for the purpose of determining the appropriate subrecipient monitoring related to the
subaward. This represents an internal control weakness which causes subrecipients to be improperly informed of federal
award information and not adequately monitored by the state agencies. Also, it could cause the omission or improper
identification of program expenditures on subrecipients’ Schedules of Expenditures of Federal Awards (SEFAs). The
following chart shows which federal award information required by 2 CFR Section 200 was omitted (as indicated by “No”)
from the subrecipient award documents at the time of the subaward and which major programs did not have a state agency
evaluation of each subrecipient’s risk of noncompliance.

                                                                     Subaward        Contact
                                                                     Period of     Information
                                 Amount Passed to       Federal     Performance        for        Evaluation of
                                 Subrecipients (in      Award        Start and      Awarding      Subrecipient
               Program             thousands)            Date        End Dates       Official         Risk
             HPC Cluster
         (including COVID-             $160,636            -              -             No               -
                  19)
            TANF – Child
                                         $48,556          No             No             No            No (1)
               Welfare
             Foster Care –
         Counties (including           $204,494           No             No             No            No (1)
              COVID-19)
         Foster Care – Non-
                                         $13,599          No             No             No              No
            Profit Contract
               Adoption
             Assistance –
                                       $118,596           No             No             No            No (1)
         Counties (including
              COVID-19)




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Finding 2021 – 014: (continued)

                                                  Federal        Name of
                                                  Award           Federal    Assistance    Assistance
                                               Identification    Awarding     Listing       Listing
                           Program
                                                 Number           Agency      Number         Title
                    HPC Cluster (including
                                                     -              -           No             No
                          COVID-19)
                    TANF – Child Welfare            No             No             -             -
                    Foster Care – Counties
                                                    No             No             -             -
                    (including COVID-19)
                      Foster Care – Non-
                                                    No             No           No             No
                        Profit Contract
                    Adoption Assistance –
                      Counties (including           No             No             -             -
                          COVID-19)

(The cells with a hyphen in the table indicate that the federal award information was included in the subrecipient award
documents or was not applicable for the respective major program.)

(1) Although an evaluation of subrecipient risk was conducted, the only risk factor used in the evaluation was the error
rate detected for the county subrecipients. The evaluation is deemed inadequate since there was no written evidence that
the risk assessment considered other risk factors, such as the risk factors identified in 2 CFR Section 200.332.

Criteria: 2 CFR Section 200.332, Requirements for pass-through entities, states in part:

All pass-through entities must:

(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following
information at the time of the subaward and if any of these data elements change, include the changes in subsequent
subaward modification. When some of this information is not available, the pass-through entity must provide the best
information available to describe the Federal award and subaward. Required information includes:

(1) Federal Award Identification.

         (iii) Federal Award Identification Number (FAIN);
         (iv) Federal Award Date (see the definition of Federal Award date in section 200.1) of award to the recipient by
         the Federal agency;
         (v) Subaward Period of Performance Start and End Date;
         (xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the
         pass-through entity;
         (xii) Assistance Listings Number and Title; the pass-through entity must identify the dollar amount made available
         under each Federal award and the Assistance Listings Number at time of disbursement;

(6) Appropriate terms and conditions concerning closeout of the subaward.

   (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 described in paragraphs (d) and
   (e) of this section, which may include consideration of such factors as:

      (1)   The subrecipient’s prior experience with the same or similar subawards;
      (2)   The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance
            with Subpart F [Audit Requirements] of this part, and the extent to which the same or similar subaward has
            been audited as a major program;



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Finding 2021 – 014: (continued)
      (3)    Whether the subrecipient has new personnel or new or substantially changed systems; and
      (4)    The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal
             awards directly from a Federal awarding agency).

Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s Standards for Internal Control in the Federal
Government (Green Book), published in September 2014. The Green Book states in part:

Management should identify, analyze, and respond to risks related to achieving the defined objectives. Management
should identify, analyze, and respond to significant changes that could impact the internal control system.

Cause: In general, the state agencies’ process for subrecipient award monitoring did not identify the omission of required
elements from the grant awards. In addition, the risk assessments performed by the agencies were not properly
documented.

Effect: Excluding the federal grant award information at the time of the subaward may cause subrecipients and their
auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also
the potential for subrecipients to have incomplete SEFAs in their Single Audit reports submitted to the Commonwealth,
and federal funds may not be properly audited at the subrecipient level in accordance with the Single Audit Act and
Uniform Guidance.

Not evaluating each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient
monitoring related to the subaward may result in subrecipients using the subaward for unauthorized purposes or in violation
of the terms and conditions of the subaward, and state agency monitoring would not detect this noncompliance and ensure
it is corrected in a timely manner.

Recommendation: State agencies should develop policies and reporting mechanisms to ensure all required federal award
information is disseminated to all subrecipients at the time of the subaward to ensure subrecipient compliance with the
Uniform Guidance in 2 CFR Section 200 and other applicable federal regulations. In addition, state agencies should
correspond with applicable subrecipients to ensure they are aware of the correct federal award information and review
applicable subaward documents prior to issuance to ensure federal information is complete and accurate. State agencies
should also implement procedures to adequately document their evaluation of each subrecipient’s risk of noncompliance
as cited in 2 CFR Section 200.332 for purposes of determining the appropriate subrecipient monitoring related to the
subaward.

PennDOT Response: PennDOT agrees with the finding.

DHS Response: DHS agrees with the finding.

Questioned Costs: The amount of questioned costs cannot be determined.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


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Various Agencies

Finding 2021 – 015:

ALN 15.252 – Abandoned Mine Land Reclamation
ALN 16.575 – Crime Victim Assistance
ALN 93.558 – Temporary Assistance for Needy Families
ALN 93.563 – Child Support Enforcement
ALN 93.575 and 93.596 – Child Care and Development Fund (CCDF) Cluster (including
 COVID-19)
ALN 93.658 – Foster Care – Title IV-E (including COVID-19)
ALN 93.659 – Adoption Assistance (including COVID-19)
ALN 93.775, 93.777, and 93.778 – Medicaid Cluster (including COVID-19)
ALN 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) (including
 COVID-19)

A Material Weakness and Material Noncompliance Exist in the Commonwealth’s Subrecipient Audit Resolution
Process (A Similar Condition Was Noted in Prior Year Finding 2020-021)

Federal Grant Number(s) and Year(s): S21AF10015 (1/01/2021 – 12/31/2023), S20AF20092 (10/01/2020 –
9/30/2023), S20AF20006 (1/01/2020 – 12/31/2022), S19AF20006 (1/01/2019 – 12/31/2021), S19AF20004 (12/01/2018
– 11/30/2021), S18AF20004 (11/01/2017 – 10/31/2020), S18AF20006 (4/01/2018 – 12/31/2020), S16AF20042
(6/01/2016 – 5/31/2021), 2020-V2-GX-0063 (10/01/2019 – 9/30/2023), 2019-V2-GX-0026 (10/01/2018 – 9/30/2022),
2018-V2-GX-0068 (10/01/2017 – 9/30/2021), 2017-VA-GX-0069 (10/01/2016 – 9/30/2020), 2101PATANF (10/01/2020
– 9/30/2021), 2001PATANF (10/01/2019 – 9/30/2020), 2101PACSES (10/01/2020 – 9/30/2021), 2001PACSES
(10/01/2019 – 9/30/2020), G2101PACCDF (10/01/2020 – 9/30/2021), G2001PACCDF (10/01/2019 – 9/30/2020),
2101PAFOST (10/01/2020 – 9/30/2021), 2001PAFOST (10/01/2019 – 9/30/2020), 2101PAADPT (10/01/2020 –
9/30/2021), 2001PAADPT (10/01/2019 – 9/30/2020), 2105PA5MAP (10/01/2020 – 9/30/2021), 2005PA5MAP
(10/01/2019 – 9/30/2020), 4506DRPA (1/20/2020 – 3/02/2024), 3441DRPA (1/20/2020 – 1/20/2025), 4408DRPA
(11/27/2018 – 11/27/2022)

Type of Finding: Significant Deficiency, Noncompliance for Medicaid Cluster
                 Material Weakness, Material Noncompliance for Other Programs

Compliance Requirement: Subrecipient Monitoring

Condition: Under the Commonwealth of Pennsylvania's (Commonwealth) implementation of the Single Audit Act,
review and resolution of subrecipient Single Audit reports is split into two stages. The Office of the Budget’s Bureau of
Accounting and Financial Management (OB-BAFM) ensures the reports meet technical standards through a centralized
desk review process. The various funding agencies in the Commonwealth are responsible for making a management
decision on each finding within six months of the Federal Audit Clearinghouse’s (FAC) Management Decision Letter
(MDL) start date for audits subject to Uniform Guidance and to ensure appropriate corrective action is taken by the
subrecipient (except for Uniform Guidance audits under U.S. Department of Labor programs which are permitted 12
months for management decisions in accordance with 2 CFR Section 2900.21). Each Commonwealth agency is also
responsible for reviewing financial information in each audit report to determine whether the audit included all pass-
through funding provided by the agency in order to ensure pass-through funds were subject to audit. Most agencies meet
this requirement by performing Schedule of Expenditures of Federal Awards (SEFA) reconciliations. The agency is also
required to adjust Commonwealth records, if necessary.




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Finding 2021 – 015: (continued)
Our fiscal year ended June 30, 2021 audit of the Commonwealth’s process for review and resolution of subrecipient Single
Audits included an evaluation of the Commonwealth’s fiscal year ended June 30, 2020 subrecipient audit universe for
audits due for submission to the FAC during the fiscal year ended June 30, 2021. We also evaluated the Commonwealth’s
review of 33 subrecipient audit reports with findings in major programs/clusters which were identified on the
Commonwealth agencies’ tracking lists during the fiscal year ended June 30, 2021, and required management decisions
by Commonwealth agencies.

Our testing disclosed the following audit exceptions regarding the Commonwealth agencies’ review of subrecipient audit
reports:

•   Department of Environmental Protection (DEP): The time period for making a management decision on findings was
    approximately 8.6 months after the FAC MDL start date for one out of two audit reports with findings.

•   Department of Human Services (DHS): The time period for making a management decision on findings ranged from
    approximately 7.2 months to 20.3 months after the FAC MDL start date for 22 out of 23 subrecipient audit reports
    with findings. There was also a delay in DHS’s procedures to ensure the subrecipient SEFAs were accurate so that
    major programs were properly determined and subject to audit. In addition, our review disclosed that three
    subrecipient audit reports with findings for which DHS was the lead agency were submitted late to the FAC, with
    FAC acceptance dates ranging from approximately 3.6 months to 10.8 months after the Single Audit due date.

•   Pennsylvania Commission on Crime and Delinquency (PCCD): The time period for making a management decision
    on findings was approximately 10.3 months after the FAC MDL start date for one out of two subrecipient audit reports
    with findings.

•   Pennsylvania Emergency Management Agency (PEMA): The time period for making a management decision on
    findings was approximately 12 months after the FAC MDL start date for one subrecipient audit report with findings.
    In addition, our review disclosed the one subrecipient audit report with findings for which PEMA was the lead agency
    was submitted approximately 16 months late to the FAC and was excluded from PEMA’s tracking list.

As a follow-up to the prior year finding, we noted that the Commonwealth subgranted federal funds totaling $285,634,900
to the City of Philadelphia during the fiscal year ended June 30, 2020, for which a Single Audit was not submitted to the
FAC as of our January 2022 testing date. This was over 3.5 months after the September 30, 2021 due date, which had
been extended due to the COVID-19 pandemic in accordance with the Office of Management and Budget’s Memorandum
M-21-20, Appendix 3. Our testing disclosed that DHS’s subgrants to the City of Philadelphia were material for four of
the 14 major programs/clusters with material subgranted funds.

Our follow-up on the prior year finding also disclosed that the Commonwealth subgranted federal funds totaling
$30,158,167 to Bucks County during the fiscal year ended December 31, 2019. The audit was submitted to the FAC on
February 24, 2021, which was nearly two months after the December 31, 2020 due date, which had been extended in
accordance with the Office of Management and Budget’s Memorandum M-20-26, Appendix A.

DHS was the lead agency for the City of Philadelphia and Bucks County audits.

Criteria: 2 CFR §200.332, Requirements for pass-through entities, states in part:

All pass-through entities must:

(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, and that subaward
performance goals are achieved. Pass-through entity monitoring of the subrecipient must include:




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Finding 2021 – 015: (continued)
    (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining
    to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site
    reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address
    Single Audit findings related to the particular subaward.

    (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the
    subrecipient from the pass-through entity as required by §200.521 [Management decision].

(f) Verify that every subrecipient is audited as required by Subpart F [Audit Requirements] of this part when it is expected
that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set
forth in §200.501 [Audit requirements].

(g) Consider whether the results of the subrecipient’s audit, on-site review, or other monitoring indicate conditions that
necessitate adjustments to the pass-through entity’s own records.

(h) Consider taking enforcement action against noncompliant subrecipients as described in §200.339 [Remedies for
noncompliance] of this part and in program regulations.

In order to carry out these responsibilities properly, good internal control dictates that state pass-through agencies ensure
subrecipient Single Audit SEFAs are representative of state payment records each year, and that the related federal
programs have been properly subjected to Single Audit procedures.

2 CFR §200.512, Report submission, states in part:

(a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and
reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after
receipt of the auditor’s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday,
Sunday, or Federal holiday, the reporting package is due the next business day.

2 CFR §200.521, Management decision, states in part:

(a) General. The management decision must clearly state whether or not the finding is sustained, the reasons for the
decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action.

(d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management
decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed
with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit
report.

2 CFR §200.505, Sanctions, states:

In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, Federal agencies
and pass-through entities must take appropriate action as provided in §200.339 [Remedies for noncompliance].

2 CFR §200.339, Remedies for noncompliance, states in part:

If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions
of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described
in §200.208 [Specific conditions]. If the Federal awarding agency or pass-through entity determines that noncompliance
cannot be remedied by imposing additional conditions, the federal awarding agency or pass-through entity may take one
or more of the following actions, as appropriate in the circumstances.

(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe
enforcement action by the Federal awarding agency or pass-through entity.


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Finding 2021 – 015: (continued)
(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity
or action not in compliance.

(c) Wholly or partly suspend or terminate the Federal award.

(d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency
regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding
agency).

(e) Withhold further Federal awards for the project or program.

(f) Take other remedies that may be legally available.

To ensure Commonwealth enforcement of federal regulations for subrecipient noncompliance with audit requirements,
Commonwealth Management Directive 325.8, Remedies for Recipient Noncompliance with Audit Requirements, Section
5 related to policy, states in part:

(a) Agencies must develop and implement remedial action that reflects the unique requirements of each program…

(b) Overall periods for the implementation of remedial action should not exceed six months from the date the first remedial
action is initiated. At the end of the six-month period, the recipient should take the appropriate corrective action or the
final stage of remedial action should be imposed on the recipient. Examples of remedial action include, but are not limited
to:

    (1) Meeting or calling the recipient to explain the importance and benefits of the audit and audit resolution processes,
        emphasizing the value of the audit as an administrative tool and the Commonwealth’s reliance on an acceptable
        audit and prompt resolution as evidence of the recipient’s ability to properly administer the program.
    (2) Encouraging the entity to establish an audit committee or designate an individual as the single point of contact
        to:
        (a) Communicate regarding the audit.
        (b) Arrange for and oversee the audit.
        (c) Direct and monitor audit resolution.
    (3) Providing technical assistance to the recipient in devising and implementing an appropriate plan to remedy the
        noncompliance.
    (4) Withholding a portion of assistance payments until the noncompliance is resolved.
    (5) Withholding or disallowing overhead costs until the noncompliance is resolved.
    (6) Suspending the assistance agreement until the noncompliance is resolved.
    (7) Terminating the assistance agreement with the recipient and, if necessary, seeking alternative entities to
        administer the program.

Management Directive 325.9, Processing Audits of Federal Pass-Through Funds, Section 7 related to procedures, states
in part:

c. Agencies.

    (1) Evaluate single audit report submissions received from BOA [now OB-BAFM] to determine program purpose
        acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the
        applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a
        management decision; and that the subrecipient has submitted an adequate corrective action plan.

    (6) Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.338 [now 200.339]
        and Management Directive 325.8, Remedies for Recipient Noncompliance with Audit Requirements, when
        subrecipients fail to comply with the provisions of Subpart F.


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Federal Award Findings and Questioned Costs - June 30, 2021

Finding 2021 – 015: (continued)
Management Directive 325.12, Standards for Internal Control for Commonwealth Agencies, adopted the internal control
framework outlined in the United States Government Accountability Office’s, Standards for Internal Control in the
Federal Government (Green Book), published in September 2014. The Green Book states in part:

Management should establish and operate monitoring activities to monitor the internal control system and evaluate the
results. Management should remediate identified internal control deficiencies on a timely basis.

Cause: One reason provided by Commonwealth management for untimely audit resolution in the various agencies,
including making management decisions, approving corrective action, and performing procedures to ensure the accuracy
of subrecipient SEFAs, and for the exclusion of an audit from a tracking list, was either a change in staff or a lack of staff
to follow up and process subrecipient audit reports more timely. DEP personnel stated the late management decision
resulted from late notification of FAC audit receipt by OB-BAFM. PCCD personnel indicated the management decision
was not completed due to an oversight.

Regarding late and outstanding audit report submissions, the Commonwealth agencies did not appear to be timely
implementing remedial action steps in accordance with 2 CFR §200.339 and Commonwealth Management Directive 325.8
in order to ensure compliance with federal audit submission requirements.

Effect: Since required management decisions were not made within six months to ensure appropriate corrective action
was taken on audits received from subrecipients, the Commonwealth did not comply with federal regulations, and
subrecipients were not made aware of acceptance or rejection of corrective action plans in a timely manner. Further,
noncompliance may recur in future periods if control deficiencies are not corrected on a timely basis, and there is an
increased risk of unallowable charges being made to federal programs if corrective action and recovery of questioned costs
is not timely.

Regarding the SEFA reviews or alternate procedures which are not being performed timely and the late Single Audit report
submissions, there is an increased risk that subrecipients could be misspending and/or inappropriately tracking and
reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and
corrected by agency personnel on a timely basis as required.

Finally, additional federal pass-through funds may be unaudited in the future without timely and effective remedial action
from Commonwealth agencies to enforce compliance.

Recommendation: We recommend that the above weaknesses that cause untimely subrecipient Single Audit resolution,
including untimely management decisions on findings, untimely review of the SEFA or alternate procedures, and late audit
report submissions be corrected to ensure compliance with federal requirements and Commonwealth Management
Directives, and to better ensure more timely subrecipient compliance with program requirements.

Commonwealth agencies should promptly pursue outstanding audits and implement remedial action steps on a timely basis
in accordance with 2 CFR §200.339 and Commonwealth Management Directive 325.8.

DEP Response: DEP agrees with the finding.

DHS Response: While DHS agrees with this finding, we believe we are in compliance with 2 CFR §200.339 and
Commonwealth Management Directive 325.8 related to outstanding audits. We continue to work with counties and their
independent auditors to obtain any late Single Audit reports, and albeit late, we do receive them which is the ultimate goal.

PCCD Response: PCCD is in agreement with the finding.

PEMA Response: PEMA agrees with this finding. The subrecipient was inadvertently excluded from PEMA’s audit
tracking list due to failure of our new employee to enter the information into the Single Audit database. As soon as we
became aware of the omission, and having previously reviewed the audit report, a management decision letter was issued




                                                             89
COMMONWEALTH OF PENNSYLVANIA
Federal Award Findings and Questioned Costs - June 30, 2021

Finding 2021 – 015: (continued)
to the subrecipient on January 21, 2022. In addition, please note that PEMA had been in constant communication with
this subrecipient to resolve its noncompliance due to failure to submit the Single Audit reporting package within nine
months of its year end date of December 31, 2018, and BAFM and the Bureau of State and Federal Audits have been
provided documentary evidence of these communications.

Questioned Costs: The amount of questioned costs cannot be determined.




The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action
Plans located elsewhere in this Report.


                                                         90
   Management’s
Summary Schedule of
Prior Audit Findings




 Commonwealth of Pennsylvania




              91
                                       COMMONWEALTH OF PENNSYLVANIA
                                          OFFICE OF THE GOVERNOR


      GREGORY THALL
          SECRETARY
GOVERNOR’S OFFICE OF THE BUDGET



Summary Schedule of Prior Audit Findings - June 30, 2021

  Finding      State Agency/Finding Title/Comments

  FINDINGS FOR THE YEAR ENDED JUNE 30, 2020:
  (Please see Corrective Action Plan Schedule for planned corrective actions for any current year repeat findings.)

  FINANCIAL STATEMENT FINDINGS

  STATEWIDE (SW)

  2020-001   Information Technology General Controls Need Improvement (A Similar Condition Was Noted in Prior
             Year Finding 2019-001)

             The system issues in question have been resolved or will be resolved when the system migration is completed.
             Continuing to develop the process of changing the profiles such that they are managed like service accounts
             per policy. Account monitoring documentation is being addressed. Continuing to develop the process of
             changing the profiles such that they are managed like service accounts per policy. A workgroup has been
             formed and seeking a Privileged Identity Management (PIM) solution. Anticipated completion date: June
             2022.

  2020-002   Unemployment Compensation Accounts Payable Accrual Methodology and Controls Need Improvement

             BAFM and L&I met to discuss what is needed for the ACFR, which included the request for the accrued
             benefits which included copies of the files that the auditors used last year. The following due dates were
             established where L&I will send BAFM (by UC program) the benefits paid by benefit week for the period of
             July-October 31: July info to be received August 10, August info to be received September 10, September 1-
             17 info to be received September 24, and Sept 18-October 31 to be received November 5. L&I is on target to
             meet the due dates requested. The anticipated CAP completion date is October 2021.

  FEDERAL PROGRAM FINDINGS

  DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT (DCED)

  2020-003   The Department of Community and Economic Development Did Not Perform Adequate During-the-Award
             Monitoring of Subrecipients (A Similar Condition Was Noted in Prior Year Finding 2019-004)

             DCED has made progress towards eliminating the backlog of monitoring and should have it completed by
             June 30, 2022. Finding was not reissued.




                                                         92
COMMONWEALTH OF PENNSYLVANIA
Summary Schedule of Prior Audit Findings - June 30, 2021
 Finding    State Agency/Finding Title/Comments
 DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP)

 2020-004   A Material Weakness and Material Noncompliance Exist at the Department of Environmental Protection
            Related to Subrecipient Monitoring

            DEP ceased issuing AMLR Project Grants until the finding is resolved. DOI provided training on the Uniform
            Guidance. The training provided a broad overview but lacked specific details related to the AML Program.
            The instructor made numerous mentions that details specific to implementation of the AML Program and,
            AML and AMLER grants, needed to be provided by DOI. Following a discussion with staff in the Governor’s
            Office, DEP was asked to draft a letter to DOI requesting guidelines that delineate the types of AML service
            delivery and AML reclamation project activities that would render an AML grant agreement as subrecipient
            or contractor relationships under Uniform Guidance. Staff in the Governor’s Office informed DEP that, in
            lieu of sending the letter to DOI, they would present the issue to the Intergovernmental Team in DOI. DOI
            staff in the Pittsburgh Field Office indicated they are preparing a briefing paper on the finding for DOI
            leadership. Anticipated CAP completion is before the end of 2022.

 DEPARTMENT OF HUMAN SERVICES (DHS)

 2020-005   A Material Weakness and Material Noncompliance Exist at the Department of Human Services Related to
            Electronic Benefits Transfer Card Security (A Similar Condition Was Noted in Prior Year Finding 2019-007)

            To comply with the OIM EBT Procedures Manual, County Assistance Offices (CAOs) and District Offices
            reviewed and updated their internal procedures for over the counter card mailings as needed. Findings will
            be reported to each area’s Staff Assistant. CAOs and district offices were instructed to review their pinning
            list and card creator list to ensure the names are correct and ensure there is adequate coverage from opening
            to close, including lunch and breaks. Findings will be reported to each area’s Staff Assistant. CAOs and
            district offices were instructed to only use EBT card paper logs in cases of emergency. All card information
            should be recorded in the EBT card tracking database. CAOs and district offices were instructed to review
            EBT manual Executive Director Responsibility; when an EBT staff separates from the CAO, the staff must
            be removed from the EBT list within 24 hours. The staff assistant to the Director of Operations will email
            the area staff assistants the list of exceptions. The area staff assistants will address each exception with the
            CAO to take the necessary actions to ensure safeguards are in place to prevent future exceptions. Finding
            repeated due to timing of corrective actions.

 2020-006   Department of Human Services Did Not Validate Financial Information as Part of Its On-Site Monitoring of
            Temporary Assistance for Needy Families Subrecipients (A Similar Condition Was Noted in Prior Year
            Finding 2019-008)

            OIM-TANF - The checklist updates need to be completed and will be implemented when onsite monitoring
            resumes after the pandemic. Office of Policy Development’s (OPD) new Grant and Policy Specialist was
            hired and risk assessments for FY 20-21 were completed in December 2020. Real Alternatives was identified
            for monitoring. Virtual monitoring took place on June 28, 2021. OPD is still awaiting some of the required
            documentation for review. The anticipated completion date for the CAP is June 2022.




                                                         93
COMMONWEALTH OF PENNSYLVANIA
Summary Schedule of Prior Audit Findings - June 30, 2021
 Finding    State Agency/Finding Title/Comments
 DEPARTMENT OF HUMAN SERVICES (DHS) (Continued)

 2020-007   Material Weaknesses and Material Noncompliance Exist in Monitoring of Foster Care, Adoption Assistance,
            and Temporary Assistance for Needy Families Subrecipients by the Department of Human Services’ Office
            of Children, Youth, and Families (A Similar Condition Was Noted in Prior Year Finding 2019-009)

            OCYF does subrecipient monitoring using regularly scheduled on-site licensing inspections, regular contact
            with subrecipients, and regular Quality Assurance (QA) reviews and visits. OCYF Regional Director Staff
            have verified that OCYF Regional Offices are issuing the Licensing Inspection Summary (LIS) within 15
            days of the close of the inspection, as is considered timely. Counties are required to maintain a written contract
            with each provider to which clients are referred. The provider agency must submit to the county children and
            youth agency (CCYA) quarterly progress reports, discharge summaries, billing statements, and other written
            reports as required by the CCYA and/or DHS regulations or guidance. The CCYA must also monitor provider
            adherence to the Child Protective Services Law (CPSL) background check requirements for services coded
            as “in-home”. Counties have primary oversight of their service providers by the fiscal office, quality assurance
            staff, or their contract monitors. The CCYA must document these efforts and report them to DHS. As part of
            the County single audit reporting package, counties are required to include a supplemental schedule, subjected
            to Agreed-Upon Procedures. The schedule documents CCYA monitoring of providers’ adherence to the
            requirements of the CPSL for in-home providers. The schedule lists all providers, date of most recent
            monitoring, if there were exceptions, submission of a CAP, and acceptance, implementation, and follow-up.
            The auditor is required to test the list for completeness and analyze the CCYA’s documentation of monitoring
            activities for adequacy, obtaining necessary CAPs, timely follow-up, and adequacy and accuracy of
            monitoring documentation. As single audit reports are received in the DHS/Audit Resolution Section, a copy
            is transmitted to OCYF for review by the Bureau of Budget and Fiscal Support and use in the Quality
            Assurance reviews, including the supplemental information and any applicable findings contained. In
            addition, the AG conducts annual engagements of the CCYAs to ascertain and certify actual expenditures on
            behalf of children residing within the County and to determine compliance with regulations. During these
            engagements, the AG reviews the county policies and procedures of in-home purchased services billings and
            CPSL adherence. Any issued findings and/or observations included in these reports are also considered in
            Licensing Inspections and QA reviews. Finding repeated due to timing of corrective actions.

 2020-008   A Significant Deficiency and Noncompliance Exist in the Review and Approval of Temporary Assistance for
            Needy Families Subrecipient Invoices by the Department of Human Services' Office of Children, Youth, and
            Families

            Corrective action was taken.

 2020-009   Noncompliance and Weaknesses Exist in the Department of Human Services’ Program Monitoring of the
            Social Services Block Grant and the Block Grants for Prevention and Treatment of Substance Abuse
            Subrecipients (A Similar Condition Was Noted in Prior Year Finding 2019-010)

            OA-SSBG: The Bureau of Financial Operations (BFO) conducted the risk assessment during the year ended
            June 30, 2021, and continues to conduct during-the-award monitoring for SSBG and SABG using the results
            of that documented risk assessment. For FY20-21, 18 of the 67 counties were identified as high-risk; and six
            counties were monitored for SSBG, of which two were high-risk. These reports are either in process or
            complete. Beginning July 1, 2021, DHS will no longer receive SABG funding to pass-through to
            subrecipients; therefore, risk assessments and monitoring on this funding will stop.

            Office of Policy Development (OPD)-SSBG: Risk assessments for FY 20-21 were completed in December
            2020. Monitoring prioritizes subrecipients receiving a “high risk” designation and/or those who did not
            receive monitoring during the prior fiscal year. Three providers were identified for FY 20-21 monitoring. Due
            to Covid-19, these providers took part in virtual monitoring between May-June 2021. The CAP is considered
            to be complete for OPD. The CAP for OA-SSBG should be completed by June 2023. Finding was not
            reissued.



                                                          94
COMMONWEALTH OF PENNSYLVANIA
Summary Schedule of Prior Audit Findings - June 30, 2021
 Finding    State Agency/Finding Title/Comments
 DEPARTMENT OF HUMAN SERVICES (DHS) (Continued)

 2020-010   A Significant Deficiency and Noncompliance Exist at the Department of Human Services Related to the
            Medicaid National Correct Coding Initiative

            DHS, Bureau of Data and Claims Management (BDCM) will add the NCCI Confidentiality Agreement to the
            forthcoming contract amendment by March 2022.

 DEPARTMENT OF LABOR AND INDUSTRY (L&I)

 2020-011   Significant Deficiency and Noncompliance Related to the Department of Labor and Industry’s Preparation
            and Submission of the Semi-Annual SF-425 Report (A Similar Condition Was Noted in Prior Year Finding
            2019-013)

            Procedures have been revised and implemented to make every effort to ensure the accuracy of the current
            reports prior to submission. Due to unforeseen circumstances, the revision and correction of previously
            submitted SF-425s has been delayed. Anticipated CAP completion date is July 2022. Finding was not
            reissued.

 2020-012   A Significant Deficiency and Noncompliance Exist in the Department of Labor and Industry’s Procedures for
            Performing Eligibility Determinations (A Similar Condition Was Noted in Prior Year Finding 2019-011)

            Level 3 case reviews are currently underway, and upon completion L&I will have the eligibility determination
            scores for the period of July 1, 2020 to June 30, 2021. L&I expects analysis of the compliance for this specific
            item to be complete in August 2021. Anticipated CAP completion date is July 2022. Finding was not reissued.

 2020-013   A Significant Deficiency and Noncompliance Exist in the Department of Labor and Industry’s Procedures
            Related to Period of Performance Requirements (A Similar Condition Was Noted in Prior Year Finding 2019-
            012)

            L&I has consultants meeting with OVR district offices prior to formalizing their analysis. Anticipated CAP
            completion date is December 2021. Finding was not reissued.

 DEPARTMENT OF TRANSPORTATION (PennDOT)

 2020-014   A Significant Deficiency and Noncompliance Exist Related to Monitoring of Locally Sponsored Projects

            Corrective action was taken.

 OFFICE OF ADMINISTRATION, OFFICE FOR INFORMATION TECHNOLOGY (OA-OIT)

 2020-015   Information Technology General Controls Need Improvement (A Similar Condition Was Noted in Prior Year
            Finding 2019-014)

            OA-OIT is removing write access from developers and having database administrators as the only staff with
            write access to databases. Developers can retain read access for troubleshooting and debugging.
            Implementing quarterly reviews of the groups/users to help ensure more timely and accurate user access
            rights. The 'large number of users' issue is being addressed. OA-OIT is seeking possible solutions and seeing
            if there is funding for a Privileged Identity Management (PIM) solution. A workgroup has been formed and
            is seeking a PIM product /vendor. Anticipated completion date: June 2022.




                                                         95
COMMONWEALTH OF PENNSYLVANIA
Summary Schedule of Prior Audit Findings - June 30, 2021
 Finding    State Agency/Finding Title/Comments
 OFFICE OF THE BUDGET, OFFICE OF COMPTROLLER OPERATIONS (OB-OCO)

 2020-016   A Significant Deficiency and Noncompliance Exist Over the Preparation and Submission of the Quarterly
            CMS-64 Report

            Corrective action was taken.

 PENNSYLVANIA COMMISSION ON CRIME AND DELINQUENCY (PCCD)

 2020-017   A Significant Deficiency and Noncompliance Exist in the Pennsylvania Commission on Crime and
            Delinquency’s Procedures Related to Period of Performance Requirements (A Similar Condition Was Noted
            in Prior Year Finding 2019-017)

            Corrective action was taken.

 2020-018   Material Weakness and Material Noncompliance Exist in the Pennsylvania Commission on Crime and
            Delinquency Monitoring of Crime Victim Assistance Program Subrecipients (A Similar Condition Was
            Noted in Prior Year Finding 2019-018)

            Corrective action was taken.

 2020-019   A Significant Deficiency and Noncompliance Exist in the Pennsylvania Commission on Crime and
            Delinquency’s Procedures Related to Performance Reporting Requirements

            Corrective action was taken.

 STATEWIDE (SW)
 2020-020   State Agencies Did Not Identify the Federal Award Information and Applicable Requirements at the Time of
            the Subaward and Did Not Evaluate Each Subrecipient’s Risk of Noncompliance as Required by the Uniform
            Grant Guidance (A Similar Condition Was Noted in Prior Year Finding 2019-019)

            DHS-OCYF: FY 20-21 Tentative Allocation Letters were sent out on April 1, 2021, with ALN and funding
            amounts. Final Allocation Letters will be sent by July 31, 2021, with an attachment including all Federal
            Award information: Amount, Federal Award Identification Number (FAIN); Federal Award Date; Subaward
            Period of Performance Start and End Date; Name of Federal awarding agency, pass-through entity, and
            contact information for awarding official; ALN and Name. OCYF has a risk assessment process in place for
            Title IV-E and TANF awards. During the Quality Assurance reviews, which occur twice a year at a minimum,
            OCYF reviews a sample of Title IV-E eligible foster care cases, Title IV-E ineligible foster care cases, Title
            IV-E eligible adoption assistance cases, and TANF eligible cases. Depending on the number of eligibility and
            claiming errors identified during the review, OCYF schedules more frequent visits as the risk of repeated and
            continued errors in these CCYAs is higher. Inaccurate eligibility determinations lead to inaccurate federal
            claiming, so basing the review schedule on a CCYA’s eligibility review outcome allows OCYF to target those
            CCYAs where inaccurate claiming is a higher risk. However, to further address this finding, the risk
            assessment now includes documentation of other risk factors, such as: submission of a single audit report,
            prior experience, and new personnel.

            PennDOT is reviewing all RAS agreements to ensure all agreements contain a notice provision. Any RAS
            agreement that does not contain a notice provision will have an attachment uploaded with party contacts to
            satisfy the notice requirement.




                                                         96
COMMONWEALTH OF PENNSYLVANIA
Summary Schedule of Prior Audit Findings - June 30, 2021
 Finding    State Agency/Finding Title/Comments
 STATEWIDE (SW) (Continued)

 2020-021   A Material Weakness and Material Noncompliance Exist in the Commonwealth’s Subrecipient Audit
            Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2019-020)

            DCED and PennDOT took corrective action.

            DDAP finalized written procedures on the subrecipient audit review process. The Procurement Section Chief
            vacated the position in June of 2021. The position is instrumental in the review process of the subrecipient
            audits. DDAP continues to train additional staff on the subrecipient audit process. Division staff continues
            to review current audits. However, due to the Section Chief vacancy, DDAP anticipates the CAP completion
            to be December 2021. DDAP is not included in the current finding.

            DEP staff attended a training held by OB-BAFM. This virtual training, covering subrecipient audit
            processing, was attended by all DEP fiscal federal fiscal management specialists. Finding repeated due to
            timing of corrective actions.

            DHS remains in contact with entities to obtain outstanding audit reports and anticipates the backlog of reports
            needing a review will be eliminated by June 30, 2022.

            PCCD plans to formally document all management decisions within six months of FAC acceptance according
            to their written procedures. Finding repeated due to an administrative oversight.

 FINDINGS FOR THE YEAR ENDED JUNE 30, 2019:
 FINANCIAL STATEMENT FINDINGS

 STATEWIDE (SW)

 2019-001   Information Technology General Controls Need Improvement (A Similar Condition Was Noted in Prior Year
            Finding 2018-001)

            Refer to finding 2020-001 for the status of this issue.

 FEDERAL PROGRAM FINDINGS

 DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT (DCED)

 2019-004   The Department of Community and Economic Development Did Not Perform Adequate During-the-Award
            Monitoring of Subrecipients (A Similar Condition Was Noted in Prior Year Finding 2018-003)

            Refer to finding 2020-003 for the status of this issue.

 DEPARTMENT OF HUMAN SERVICES (DHS)

 2019-007   A Material Weakness and Material Noncompliance Exist at the Department of Human Services Related to
            Electronic Benefits Transfer Card Security (A Similar Condition Was Noted in Prior Year Finding 2018-007)

            Refer to finding 2020-005 for the status of this issue.

 2019-008   Department of Human Services Did Not Validate Financial Information as Part of Its On-Site Monitoring of
            Temporary Assistance for Needy Families Subrecipients (A Similar Condition Was Noted in Prior Year
            Finding 2018-008)

            Refer to finding 2020-006 for the status of this issue.

                                                          97
COMMONWEALTH OF PENNSYLVANIA
Summary Schedule of Prior Audit Findings - June 30, 2021
 Finding    State Agency/Finding Title/Comments
 DEPARTMENT OF HUMAN SERVICES (DHS) (Continued)

 2019-009   Material Weaknesses and Material Noncompliance Exist in Monitoring of Foster Care, Adoption Assistance,
            and Temporary Assistance for Needy Families Subrecipients by the Department of Human Services’ Office
            of Children, Youth, and Families (A Similar Condition Was Noted in Prior Year Finding 2018-010)

            Refer to finding 2020-007 for the status of this issue.

 2019-010   Noncompliance and Weaknesses Exist in the Department of Human Services’ Program Monitoring of the
            Social Services Block Grant and the Block Grants for Prevention and Treatment of Substance Abuse
            Subrecipients (A Similar Condition Was Noted in Prior Year Finding 2018-011)

            Refer to finding 2020-009 for the status of this issue.

 DEPARTMENT OF LABOR AND INDUSTRY (L&I)

 2019-011   A Material Weakness and Material Noncompliance Exist in the Department of Labor and Industry’s
            Procedures for Performing Eligibility Determinations and Completing Individualized Plans for Employment
            (A Similar Condition Was Noted in Prior Year Finding 2018-014)

            Refer to finding 2020-012 for the status of this issue.

 2019-012   A Material Weakness and Material Noncompliance Exist in the Department of Labor and Industry’s
            Procedures Related to Period of Performance Requirements (A Similar Condition Was Noted in Prior Year
            Finding 2018-015)

            Refer to finding 2020-013 for the status of this issue.

 2019-013   Significant Deficiency and Noncompliance Related to the Department of Labor and Industry’s Preparation
            and Submission of the Semi-Annual SF-425 Report

            Refer to finding 2020-011 for the status of this issue.

 OFFICE OF ADMINISTRATION, OFFICE FOR INFORMATION TECHNOLOGY (OA-OIT)

 2019-014   Information Technology General Controls Need Improvement (A Similar Condition Was Noted in Prior Year
            Finding 2018-017)

            Refer to finding 2020-015 for the status of this issue.

 PENNSYLVANIA COMMISSION ON CRIME AND DELINQUENCY (PCCD)

 2019-017   A Significant Deficiency and Noncompliance Exist in the Pennsylvania Commission on Crime and
            Delinquency’s Procedures Related to Period of Performance Requirements

            Refer to finding 2020-017 for the status of this issue.

 2019-018   Material Weakness and Material Noncompliance Exist in the Pennsylvania Commission on Crime and
            Delinquency Monitoring of Crime Victim Assistance Program Subrecipients

            Refer to finding 2020-018 for the status of this issue.




                                                          98
COMMONWEALTH OF PENNSYLVANIA
Summary Schedule of Prior Audit Findings - June 30, 2021
 Finding    State Agency/Finding Title/Comments
 STATEWIDE (SW)
 2019-019   State Agencies Did Not Identify the Federal Award Information and Applicable Requirements at the Time of
            the Subaward and Did Not Evaluate Each Subrecipient’s Risk of Noncompliance as Required by the Uniform
            Grant Guidance (A Similar Condition Was Noted in Prior Year Finding 2018-020)

            Refer to finding 2020-020 for the status of this issue.

 2019-020   A Material Weakness and Material Noncompliance Exist in the Commonwealth’s Subrecipient Audit
            Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2018-021)

            Refer to finding 2020-021 for the status of this issue.




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                 100
    Management’s
Corrective Action Plans




  Commonwealth of Pennsylvania




               101
                                                                  COMMONWEALTH OF PENNSYLVANIA
                                                                     OFFICE OF THE GOVERNOR


            GREGORY THALL
                SECRETARY
      GOVERNOR’S OFFICE OF THE BUDGET



      Corrective Action Plans - June 30, 2021
                                                                                                                                                           Anticipated
                                      Contact                                                                                                              Completion
         Finding       Agency      Person & Title                                    Finding Title/Corrective Action                                          Date

        2021-001                                     Information Technology General Controls Need Improvement (A Similar Condition Was Noted in
                                                     Prior Year Finding 2020-001)

                       OA-OIT       Michael          The system(s) in question have been resolved or will be resolved when the system migration is         06/30/2022
                                    Dailey, IT       completed. OA-OIT is continuing to develop the process of changing the profiles per policy. Account
102
                                    Manager 3        monitoring documentation is being addressed.

                                    Kevin Sperber,
                                    IT Generalist
                                    Admin. 1

                                    Ken Kitch, IT
                                    Manager

                                    Gerry
                                    Schopman,
                                    Prog. Anyst. 4

                                    Loc Tran, IT
                                    Manager 1

        2021-002                                     Information Technology Control Weaknesses in the Unemployment Compensation and Pandemic
                                                     Unemployment Assistance Systems

                       OA-OIT       Edward           The system(s) in question have been resolved or will be resolved when the system migration is         06/30/2022
                                    Bowlen, Dir.     completed. We are continuing to develop the process of changing the profiles per policy and
                                    of App. and      communicating policy. Account monitoring documentation is being addressed. A large number of the
      COMMONWEALTH OF PENNSYLVANIA
      Corrective Action Plans - June 30, 2021
                                                                                                                                                        Anticipated
                               Contact                                                                                                                  Completion
        Finding    Agency   Person & Title                                     Finding Title/Corrective Action                                             Date


        2021-002            Service Del.     system administrator accounts to the vendor have been revoked already.
        (cont’d)
                            David
                            Dodson-
                            Andrews, Sr.
                            Proj. Manager,
                            Ben Mod

        2021-003                             A Significant Deficiency and Noncompliance Exist at the Department of Education Related to
                                             Submission of Elementary and Secondary School Emergency Relief Fund Annual Reporting

                    PDE     Susan            The Pennsylvania Department of Education (PDE) recognizes that backup documentation for the                09/01/2022
                            McCrone,         reporting monitoring was not provided. However, PDE does not believe it was out of compliance.
                            Division
                            Manager,         The information submitted to the United States Department of Education (USDE) contained information
103                         Federal          collected and reviewed by several programmatic and administrative levels at PDE. The monitoring and
                            Programs,        record keeping procedures provided reasonable assurance, to the best of PDE’s ability at that time, to
                            PDE              ensure the information collected and submitted with the annual report was accurate.

                                             Current reporting procedures: PDE used its eGrants system to collect all LEA required records under
                                             ESSER I and ESSER II. The eGrants system is designed to allow licensed educational agencies and
                                             certain community-based programs within the commonwealth access to PDE grants. Through this
                                             system, the LEA can submit applications for funding, e-sign contracting documents, upload back-up
                                             documentation, submit program quarterly reports, and file final expenditure reports. The eGrants system
                                             makes it possible for records pertaining to the ESSER awards to be retained separately from other grant
                                             funds, including funds that an SEA or LEA receives under the CARES Act and CRRSA. This follows
                                             the requirements under 2 C.F.R. § 200.334 and 34 C.F.R. § 76.730, including financial records related to
                                             the use of grant funds.

                                             Only an eGrants authorized user that is associated with an Agency or LEA that has an active
                                             Program/Project and the role of Agency Project Writer can upload documents to the project. The SEA
                                             staff then reviews and investigates the documents. Projects advance if the documents are complete and
                                             correct.

                                             The grant process is as follows:
                                             • PDE announces and releases grant application in eGrants;
                                             • LEA designated individual completes application in eGrants;
      COMMONWEALTH OF PENNSYLVANIA
      Corrective Action Plans - June 30, 2021
                                                                                                                                                          Anticipated
                               Contact                                                                                                                    Completion
        Finding    Agency   Person & Title                                     Finding Title/Corrective Action                                               Date


        2021-003                             • Prior to submission, LEA’s board-approved designee signs off electronically on application (typically
        (cont’d)                             Superintendent or Chief Executive Officer);
                                             • The program area reviews the grant application and returns it for corrections (if necessary). Otherwise,
                                             an approvable application goes to the division chief for electronic signature;
                                             • Chief Counsel reviews and approves application for form and legality;
                                             • The Office of Comptroller Operations completes the review of the application and fully executes the
                                             contract; and
                                             • LEA receives its first monthly payment. Payments for grants processed through eGrants are made
                                             monthly through PDE’s Financial Accounting Information (FAI) System. The FAI system interfaces
                                             with PDE’s financial accounting records system, SAP. Monthly payments to LEAs are continuous and
                                             automatic based on quarterly financial reports collected through the FAI System.

                                             Through quarterly financial reporting, LEAs are required to report the amount of cash received,
                                             expended, and on hand. If the amount of cash-on-hand reported is determined to be too high, or the
                                             quarterly report is not submitted, monthly payments will be suspended until the next quarterly report is
104                                          due.

                                             Current monitoring procedures: Monitoring to ensure compliance with existing federal guidelines
                                             typically occurs from January through May annually. LEAs complete an online self-assessment available
                                             within Pennsylvania’s federal monitoring online system, Fedmonitor. All LEAs receive a unique
                                             username and password to access Fedmonitor. LEAs are monitored cyclically or as needed based on
                                             risk.

                                             Beginning in 2021–22, all LEAs were placed on a four-year monitoring cycle and will be monitored
                                             once between 2021–22 and 2024–25. Additionally, all LEAs are annually assessed for risk to prevent
                                             fraud, waste, and abuse. Those deemed to be medium or high risk on the LEA Risk Assessment will be
                                             monitored every year. Points range from 1–20, and most LEAs fall in the low-risk category, with a score
                                             of nine and under.

                                             Annually, the categories and points are evaluated to determine compliance with Uniform Grant
                                             Guidance. LEAs are assigned points for the following factors to determine risk:

                                             • Failure to submit federal grant applications by established deadlines;
                                             • Failure to submit reports/plans by established deadlines which include:
                                                       o Pennsylvania Information Management System data collection;
                                                       o Performance Goal Output Reports; and Schoolwide plan(s);
                                             • Previous year monitor/audit findings;
      COMMONWEALTH OF PENNSYLVANIA
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                                                                                                                                                           Anticipated
                               Contact                                                                                                                     Completion
        Finding    Agency   Person & Title                                       Finding Title/Corrective Action                                              Date


        2021-003                             • Excessive federal program carryover Title I allocation. All LEAs receive at least one point for
        (cont’d)                             allocation; the higher the allocation, the higher the points;
                                             • New entity;
                                             • New federal program coordinators, business managers, and/or superintendent/chief executive officer;
                                             and
                                             • New accounting software at the LEA.

                                             A risk assessment, conducted by an outside, contracted entity stated that PDE’s risk is heightened due to
                                             the four-year monitoring cycle. Therefore, PDE is working to hire an outside contractor to monitor LEA
                                             funds distributed through ESSER I and ESSER II by September 2022.

                                             PDE has also self-identified gaps in procedures and internal controls and taken steps to correct them.

                                             As stated above, policies and procedures are present but are currently being revised, to support the influx
                                             of federal dollars over such a short period of time.
105
                                             Due to capacity issues, PDE does take responsibility for the delay in revising its monitoring and internal
                                             control policy. However, PDE has been working to mitigate risks in several areas based on an
                                             assessment of risk performed by an outside contractor. For the second phase of the risk assessment and
                                             internal controls process, PDE is working to secure an outside contractor to assist with monitoring and
                                             establish corrected internal policies and procedures.

        2021-004                             A Material Weakness and Material Noncompliance Exist at the Department of Environmental
                                             Protection Related to Subrecipient Monitoring (A Similar Condition Was Noted in Prior Year
                                             Finding 2020-004)

                    DEP     Brian Bradley,   This issue was first identified in the last single audit. The corrective actions are ongoing.                 06/30/2022
                            Director,
                            Bureau of        AMLR program representatives attended an online training on March 2, 2021, covering 2 CFR 200 and
                            Abandoned        contractor or subrecipient determinations. The training was being provided by the Department of the
                            Mine             Interior, Office of Surface Mining Reclamation and Enforcement (DOI/OSM).
                            Reclamation
                                             The DEP has ceased issuing AMLR grants under Management Directive 305.20, Grant Administration
                            Tim Golding,     and will not resume issuing them until the AMLR program has subrecipient monitoring procedures in
                            Executive        place.
                            Assistant,
                            Office of        DEP management has determined the recipients with existing agreements are subrecipients. DEP will
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      Corrective Action Plans - June 30, 2021
                                                                                                                                                          Anticipated
                               Contact                                                                                                                    Completion
        Finding    Agency   Person & Title                                     Finding Title/Corrective Action                                               Date


        2021-004            Administration   follow this determination consistently with future agreements and accounting treatment.
        (cont’d)            and
                            Management       DEP is developing written policies and procedures for subrecipient monitoring and will notify grantees
                                             to implement them immediately to ensure timely subrecipient compliance with federal regulations.

        2021-005                             A Material Weakness and Material Noncompliance Exist at the Department of Human Services
                                             Related to Electronic Benefits Transfer Card Security (A Similar Condition Was Noted in Prior
                                             Year Finding 2020-005)

                    DHS     Jeanette         1. The EBT Project Office will make updates to the EBT Procedures Manual (Manual) and OIM EPPIC              03/30/2022
                            Coulston, OIM    EBT Systems Application form (application). The manual will be updated to provide one link to the
                            Income           application. The application will be updated to properly identify signature requirements. Notification of
                            Maintenance      updates will be sent to CAO staff via the End of the Week publication.
                            Program
                            Representative   2. All CAOs and district offices will be reminded of the EBT Coordinators’, alternates’, pinners’, and       04/01/2022
106                                          card makers’ responsibilities and will ensure users in the EBT Card Tracking Database know their
                                             responsibilities and segregation of duties. A reminder will be sent to review the OIM EBT Procedural
                                             Manual.

                                             3. OIM mandates annual training for EBT personnel to be completed at the beginning of each year. The         Completed
                                             training reviews the procedures that safeguard access to the EBT systems. Also included is the
                                             following:
                                              a. Review of roles and responsibilities and who may hold a role
                                              b. Card maker and pinner coverage for all business hours
                                              c. Proper security for EBT cards and associated items
                                              d. Timeframes for submitting changes
                                              e. Retention timeframes
                                             Area managers and Staff assistants monitor completion of the training.

                                             4. The EBT Program office will provide guidelines for the CAOs to follow when reviewing/updating             07/01/2022
                                             their written internal procedures for EBT security for card mailings.

                                             5. The EBT Project Officer will start retraining of parties that are responsible for the completion of the   Completed
                                             EBT Headquarters Card Destruction log.
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                                                                                                                                                          Anticipated
                               Contact                                                                                                                    Completion
        Finding    Agency   Person & Title                                     Finding Title/Corrective Action                                               Date


        2021-006                             A Significant Deficiency and Noncompliance Exist at the Department of Human Services Related
                                             to Submission of Emergency Rental Assistance Monthly and Quarterly Reporting

                    DHS     Joel             DHS Office of Income Maintenance has hired a contractor to assist in developing monitoring procedures        09/30/2022
                            O'Donnell,       to ensure the accuracy of ERAP reporting. Once those procedures are developed, the contractor will also
                            Dir., Bur. of    assist with the validation of the information from the counties.
                            Prog. Support

        2021-007                             Department of Human Services Did Not Validate Financial Information as Part of Its On-Site
                                             Monitoring of Temporary Assistance for Needy Families Subrecipients (A Similar Condition Was
                                             Noted in Prior Year Finding 2020-006)

                    DHS     Joel             New Directions                                                                                               06/30/2022
                            O’Donnell,       The Office of Income Maintenance (OIM) updated agency monitoring personnel checklists in FY 2019-
                            Director,        20 to include testing various financial controls of select grantees based on their Risk Assessment scores.
107                         Bureau of
                            Program          OIM had planned to move forward with a portion of on-site monitoring during the year ended June 30,
                            Support          2020, however, since March 13, 2020, agency personnel have been restricted from travel, making on-site
                                             monitoring not feasible. OIM is currently operating under a public health emergency. Once the state
                                             provides travel guidance at the conclusion of the health emergency and there is a recovery plan in place
                                             as an agency, OIM will be able to perform this monitoring.

                            Jazmin           Alternatives to Abortion                                                                                     06/30/2022
                            Cartwright,      The Office of Policy Development (OPD) initiated numerous conversations with the Alternatives to
                            Grants and       Abortion grantee regarding receiving the requested documentation for monitoring (communication
                            Policy           occurred regularly from April 2021 through January 2022). The grantee disagrees that the disclosure of
                            Specialist       this information is a requirement of the grant agreement and as such has not provided the documentation
                                             needed to complete the monitoring.

                                             On January 27, 2022, DHS sent a letter to the grantee requesting a response to determine the next steps
                                             for this monitoring review. On January 28, 2022, the grantee requested to meet with DHS's Office of
                                             General Counsel to discuss the issue and find a solution.

                                             The Office of General Counsel and the Alternatives to Abortion grantee are in the process of scheduling
                                             a meeting to discuss this situation and come to a resolution. In addition, OPD completed risk
                                             assessments for FY 21-22. Monitoring will prioritize subrecipients receiving a “high risk” designation
                                             and/or who have not been monitored in the past 5 years. Monitoring will occur by June 30, 2022.
      COMMONWEALTH OF PENNSYLVANIA
      Corrective Action Plans - June 30, 2021
                                                                                                                                                         Anticipated
                               Contact                                                                                                                   Completion
        Finding    Agency   Person & Title                                     Finding Title/Corrective Action                                              Date


        2021-008                             Material Weaknesses and Material Noncompliance Exist in Monitoring of Foster Care, Adoption
                                             Assistance, and Temporary Assistance for Needy Families Subrecipients by the Department of
                                             Human Services’ Office of Children, Youth, and Families (A Similar Condition Was Noted in
                                             Prior Year Finding 2020-007)

                    DHS     TinaMarie        OCYF Regional Director staff have verified that OCYF Regional Offices are issuing the Licensing             06/30/2022
                            Petrovitz,       Inspection Summary (LIS) within 15 days of the close of the inspection, as is considered timely. If
                            Director,        applicable, counties have ten calendar days to respond to the plan of correction (POC) and that POC
                            County           needs to be reviewed by the regional office within ten business days for compliance. This LIS will be
                            Support          sent to Harrisburg for processing.

                                             Concerning the monitoring of subrecipients: Counties are required to maintain a written contract with
                                             each provider to which clients are referred. The provider agency must submit to the county children and
                                             youth agency (CCYA) quarterly progress reports, discharge summaries, billing statements, and other
                                             written reports as required by the CCYA and/or in accordance with DHS regulations or guidance. The
108                                          CCYA must monitor provider adherence to the Child Protective Services Law (CPSL) background
                                             check requirements to assure the safety of children receiving prevention, reunification, and aftercare
                                             services (coded as “in-home”). Counties have primary oversight of their service providers by the fiscal
                                             office, quality assurance staff or their contract monitors. The CCYA must document these efforts and
                                             report them to DHS.

                                             As part of the county single audit reporting package, all counties are required to include a supplemental
                                             schedule, which is subjected to an Agreed-Upon Procedures engagement. The schedule documents
                                             CCYA monitoring of providers’ adherence to the requirements of the CPSL for children in in-home
                                             providers. The schedule includes a list of all providers, date of most recent monitoring, if there were
                                             exceptions, submission of a corrective action plan (CAP), and acceptance, implementation, and follow-
                                             up on the CAP. The county’s independent auditor is required to test the list for completeness and analyze
                                             the CCYA’s documentation of monitoring activities for adequacy, obtaining necessary corrective action
                                             plans, and timely follow-up on corrective action plans, and adequacy and accuracy of monitoring
                                             documentation.

                                             As single audit reports are received in DHS, a copy is transmitted to OCYF for review by the Bureau of
                                             Budget and Fiscal Support and use in QA reviews, including the supplemental information and any
                                             applicable findings contained.

                                             In addition, the Pennsylvania Department of the Auditor General (AG) conducts annual engagements of
                                             the CCYAs to ascertain and certify actual expenditures on behalf of children residing within the County
      COMMONWEALTH OF PENNSYLVANIA
      Corrective Action Plans - June 30, 2021
                                                                                                                                                        Anticipated
                               Contact                                                                                                                  Completion
        Finding    Agency   Person & Title                                     Finding Title/Corrective Action                                             Date


        2021-008                              and to determine compliance with regulations. During these engagements, the AG reviews the county
        (cont’d)                              policies and procedures of in-home purchased services billings and CPSL adherence. Any issued
                                              findings and/or observations included in these reports are also considered in Licensing Inspections and
                                              QA reviews.

        2021-009                              A Significant Deficiency and Noncompliance Exist at the Department of Human Services Related
                                              to the Medicaid National Correct Coding Initiative (A Similar Condition Was Noted in Prior Year
                                              Finding 2020-010)

                    DHS     Sandra            OMAP’s Bureau of Data and Claims Management (BDCM) is currently negotiating an amendment to               06/30/2022
                            Marcella, Dir.,   the PROMISe contract which will include the necessary NCCI Confidentiality Agreement.
                            BDCM

        2021-010                              A Significant Deficiency and Noncompliance Exist at the Department of Human Services Related
                                              to the Managed Care Financial Audit
109
                    DHS     Michael           Office of Long-Term Living (OLTL):                                                                        Completed
                            Penney, Dir.,     OLTL posted the annual Community Health Choices MCO audits to the DHS website on January 31,
                            Div. of Rate      2022. In addition, OLTL will post these audits or a summary of them on the DHS website every year.
                            Setting and
                            Auditing

                            Maranatha         Office of Medical Assistance Programs (OMAP):                                                             05/31/2022
                            Perez, Dir.,      OMAP conducted most recent encounter and financial data audit between September and December
                            Bur. of Fiscal    2021. The audit work is complete; however, OMAP is currently reviewing the draft audit report. For
                            Mgmt. (BFM),      this reason, a final audit report was not published to the website in December 2021. OMAP intends to
                                              post the final audit report on DHS’ website in the spring of 2022.
                            Maki Traynor,
                            Dir., Div. of     In order to be in compliance with the encounter and financial data audit requirement in subsequent
                            HealthChoices     periods, OMAP will start the next required encounter data audit in time to publish the report by
                            Rates, BFM        December 31, 2024
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      Corrective Action Plans - June 30, 2021
                                                                                                                                                          Anticipated
                               Contact                                                                                                                    Completion
        Finding    Agency   Person & Title                                      Finding Title/Corrective Action                                              Date


        2021-011                             A Significant Deficiency and Noncompliance Exist Related to Eligibility of Unemployment
                                             Recipients

                    L&I     Rebecca Keen,    Since the implementation of ID.me in the PUA system in October 2020, and in the Ben Mod system in            12/31/2022
                            Acting           July 2021, Pennsylvania continues to monitor and address system vulnerabilities as needed. The chart
                            Director,        below documents Pennsylvania’s improvements to this fraud preventative measure in the Ben Mod
                            Office of UC     system:
                            Benefits
                            Policy           - 7/16/2021 - ID.me goes live for initial claims.
                                             - 7/22/2021 - ID.me goes live for anyone filing weekly certifications on claims with an effective date
                                             after March 1, 2021.
                                             - 7/30/2021 - ID.me goes live for any time a claimant changes his/her Keystone ID (all claim types).
                                             - 10/11/2021 - ID.me goes live for any time a claimant changes his/her payment method (all claim
                                             types).
110                                          A request has been made to Geographic Solutions (GSI), Pennsylvania’s system vendor, to establish a
                                             web service connection to the National Association of State Workforce Agency’s (NAWSA’s) Integrity
                                             Data Hub. The hub is comprised of a unique set of tools that, when actively utilized by all U.S. states
                                             and territories, forms a powerful mechanism for detecting and preventing UI fraud in one robust system.

                                             - Integrity Data Hub - Designed by the Integrity Center’s leading UI experts, the hub provides critical
                                             cross-matching functionality to combat the challenges and urgencies of UI fraud.

                                             - Suspicious Actor Repository - Participating states match current claims against this state-populated
                                             database of fraudulent and suspicious claims data. The repository leverages the investigative power of all
                                             states for the benefit of each state.

                                             Plans are also under way to add multi-factor authentication, a two-step process that will add an extra
                                             layer of protection against fraud and identity theft.

                                             Pennsylvania will be using NASWA's online training resources to train staff on:

                                             - Properly identifying a caller (identity theft).
                                             - Increasing listening skills to assist staff in identifying conflicting information between claimants'
                                             statements.
                                             - Knowing what questions to ask and when to clarify or verify information.
                                             - Educating claimants on their rights, responsibilities, and requirements for eligibility.
      COMMONWEALTH OF PENNSYLVANIA
      Corrective Action Plans - June 30, 2021
                                                                                                                                                           Anticipated
                               Contact                                                                                                                     Completion
        Finding    Agency   Person & Title                                      Finding Title/Corrective Action                                               Date


        2021-011                             - Identifying potential fictitious employer schemes or multi-claimant schemes.
        (cont’d)
                                             Pennsylvania is also working with a U.S. Department of Labor Tiger Team, specifically designed to
                                             analyze state systems and processes and, following recommendations by the Tiger Team, to implement
                                             any recommendations using federal grant funds. One of the focuses of the Tiger Team grant is to
                                             prevent, detect, and recover fraudulent UI overpayments. The Tiger Team is in the process of reviewing
                                             current processes and will be making recommendations to improve the fraud measures.

        2021-012                             A Significant Deficiency Exists at the Department of Labor and Industry Related to the
                                             Reemployment Services and Eligibility Assessments Program

                    L&I     Dorraine         It was recommended through the audit that an existing staff checklist from the RESEA Policy and               Completed
                            Rauch,           Procedures Desk Guide be used as a mandatory control of the program. Based on that recommendation,
                            Workforce        the agency took the checklist, updated it and made it a fillable PDF. There are signature requirements for
                            Dev. Super.      the staff case manager to sign off on, certifying that all steps have been completed. The checklist is then
111                                          provided to the supervisor who is then required to review the participant’s activity and sign off,
                            Crystal          acknowledging that all steps were completed.
                            Houser,
                            Division         On February 11, 2022 an email along with the fillable checklist was sent to all PA CareerLink® staff
                            Chief, Quality   working in the RESEA program notifying them of the new requirement to complete and sign the
                            Assurance        checklist, effective February 14, 2022.

        2021-013                             Information Technology General Controls Need Improvement (A Similar Condition Was Noted in
                                             Prior Year Finding 2020-015)

                   OA-OIT   Derin Myers,     Public Safety Delivery Center will monitor and document the review of email notifications and code            Completed
                            PCCD,            production logs to verify that developers are not pushing unauthorized code to production.
                            Director,
                            OFMA             EDC now performs quarterly review of privileged user accounts to ensure former employees do not
                                             continue to have server access.

        2021-014                             State Agencies Did Not Identify the Federal Award Information and Applicable Requirements at
                                             the Time of the Subaward and Did Not Evaluate Each Subrecipient’s Risk of Noncompliance as
                                             Required by the Uniform Grant Guidance (A Similar Condition Was Noted in Prior Year Finding
                                             2020-020)

                    DHS     TinaMarie        OCYF is sending out a Restrictions and Requirements document with each FY 21-22 Tentative and                 Completed
      COMMONWEALTH OF PENNSYLVANIA
      Corrective Action Plans - June 30, 2021
                                                                                                                                                              Anticipated
                                Contact                                                                                                                       Completion
        Finding    Agency    Person & Title                                       Finding Title/Corrective Action                                                Date


        2021-014             Petrovitz,        Final Allocation letter. The document lists all OCYF’s grants, the federal agency granting the fund and
        (cont’d)             Director of       where to find the rules and regulations guiding the usage of the funds.
                             County
                             Support           FY 21-22 Tentative Allocation Letters are being sent in March 2022. The Final Allocation Letters will
                                               be sent out once the budget passes.

                                               FY 20-21 Tentative Allocation Letters were sent on April 1, 2021, with Assistance Listing Numbers
                                               (ALN) and funding amounts. Final Allocation Letters were sent July 31, 2021, with an attachment
                                               including all Federal Award information: ALN and Name, Amount, Federal Award Identification
                                               Number (FAIN); Federal Award Date; Subaward Period of Performance Start and End Date; Name of
                                               Federal awarding agency, pass-through entity, and contact information for awarding official.

                                               OCYF has a risk assessment process in place for Title IV-E and TANF awards. During the Quality
                                               Assurance reviews, which occur twice a year at a minimum, OCYF reviews a sample of Title IV-E
                                               eligible foster care cases, Title IV-E ineligible foster care cases, Title IV-E eligible adoption assistance
112                                            cases, and TANF eligible cases. Depending on the number of eligibility and claiming errors identified
                                               during the review, OCYF schedules more frequent visits as the risk of repeated and continued errors in
                                               these CCYAs is higher. Inaccurate eligibility determinations lead to inaccurate federal claiming, so
                                               basing the review schedule on a CCYA’s eligibility review outcome allows OCYF to target those
                                               CCYAs where inaccurate claiming is a higher risk. However, to further address this finding, the risk
                                               assessment now includes documentation of other risk factors, such as: submission of a single audit
                                               report, prior experience, and new personnel. The corrective actions are considered complete.

                   PennDOT   Ryan Shiffler,    PennDOT will continue to include the ALN in all RAS agreements. PennDOT is developing further                  06/30/2022
                             Project Dev.      guidance to ensure that Federal & State Assistance Program Names and Numbers are identified correctly
                             Engineer          and populated in agreements. PennDOT will continue to reinforce the need for a notice provision in
                                               RAS agreements. Any RAS agreement that does not contain a notice provision within its body will have
                             Jeffrey Spotts,   an attachment uploaded with party contacts to satisfy the notice requirement and further guidance to
                             Acting Deputy     remind PennDOT personnel of this approach is forthcoming.
                             Chief Counsel

                             Nick Balzer,
                             Asst. Counsel

                             Dougie Chon,
                             Asst. Counsel
      COMMONWEALTH OF PENNSYLVANIA
      Corrective Action Plans - June 30, 2021
                                                                                                                                                          Anticipated
                               Contact                                                                                                                    Completion
        Finding    Agency   Person & Title                                     Finding Title/Corrective Action                                               Date


        2021-015                             A Material Weakness and Material Noncompliance Exist in the Commonwealth’s Subrecipient
                                             Audit Resolution Process (A Similar Condition Was Noted in Prior Year Finding 2020-021)


                    DEP     Jennifer L.      During an audit in December 2020, DEP Fiscal Management became aware of staff not completing the             Completed
                            Brandt,          necessary steps for the management decision process that is included in the instructions for handling
                            Senior Fiscal    single audit reviews. DEP Fiscal Management staff immediately contacted the DEP Program Grant
                            Management       Officers for a review of these findings and the submitted corrective action plans. At that time, there was
                            Specialist,      also a thorough review of all single audits received with findings for the calendar year to ensure these
                            Federal Grants   steps were not missed on any other submissions.
                            and Audits
                                             DEP Fiscal Management staff participated in a mandatory review of department and Commonwealth
                                             policies focusing on these steps January 21, 2021. DEP Fiscal Management updated the internal
                                             procedures to highlight these steps to ensure they are not missed on any future single audit review on
                                             February 1, 2021.
113
                                             DEP Fiscal Management staff participated in a high-level training held by OB-BAFM on March 30,
                                             2021. All staff attended the session, including staff who previously worked on single audits and new
                                             staff that had recently come on board.

                                             OB-BAFM provides agencies with single audit reporting packages that have findings each week that
                                             have been accepted by the Federal Audit Clearinghouse. This allows to start the management decision
                                             process in a timelier manner and meet the six-month deadline for issuing a decision.

                    DHS     David Bryan,     Regarding the timeliness of finding resolution and procedures related to the SEFA reviews, the Audit         06/30/2022
                            Manager,         Resolution Section (ARS) hired an additional staff member in August 2021 and is currently in the
                            Audit Res.       process of hiring another staff member as of February 2022. In addition, ARS is continuing to have staff
                            Section          from other areas in the Division of Audit and Review assist with these reviews to make them timelier.
                                             Finally, the ARS is working with Office of the Budget, Bureau of Accounting and Financial
                            Alexander        Management to develop a risk-based approach for single audit reviews, which will greatly streamline the
                            Matolyak,        process of single audit reviews to gain substantial efficiencies.
                            Director,
                            Division of      Regarding late audit report submissions, DHS will continue to follow the requirements of 2 CFR
                            Audit and        §200.339 and Commonwealth Management Directive 325.8. DHS will continue to work with counties
                            Review           and their independent auditors to obtain any late Single Audit reports.
      COMMONWEALTH OF PENNSYLVANIA
      Corrective Action Plans - June 30, 2021
                                                                                                                                                 Anticipated
                               Contact                                                                                                           Completion
        Finding    Agency   Person & Title                                     Finding Title/Corrective Action                                      Date


        2021-015   PCCD     Chris Epoca,     Internal operating procedures have been revised to include the following corrective actions:        Completed
        (cont’d)            Deputy
                            Director,        PCCD will monitor the “Agency Finding Responsibility Spreadsheet” provided by OB-BAFM on a
                            OFMA             weekly basis.

                                             Once OB-BAFM determines PCCD is the Lead/Responsible agency, PCCD will document the start date
                                             on issuing a management decision. PCCD will issue the Management Decision within six months of
                                             acceptance of the audit report by the Federal Audit Clearinghouse (FAC).

                   PEMA     Anne N. Ofili,   The FAC Weekly Listing and Agency Finding Responsibility Spreadsheet provided by OB-BAFM are        Completed
                            Grants Comp.     now reviewed by a more senior staff to ensure the OB-BAFM routine upload emails are being entered
                            Division Chief   correctly into the single audit database by the designated staff.



114
      Appendix




Commonwealth of Pennsylvania




             115
COMMONWEALTH OF PENNSYLVANIA
APPENDIX - Legend of Abbreviations - June 30, 2021
The following legend presents descriptions of abbreviations:

         ABBREVIATION                          DESCRIPTION

               AA                       Adoption Assistance
               AMLR                     Abandoned Mine Land Reclamation
               ACA                      Affordable Care Act
               ACF                      Administration for Children and Families
               ACFR                     Annual Comprehensive Financial Report
               ACH                      Automated Clearing House
               AG                       Department of the Auditor General
               AGRI                     Department of Agriculture
               AICPA                    American Institute of Certified Public Accountants
               ALN                      Assistance Listing Number
               ARC                      Appalachian Regional Commission
               BAFM                     Bureau of Accounting and Financial Management
               BCSE                     Bureau of Child Support Enforcement
               BFD                      Bureau of Food Distribution
               BFO                      Bureau of Financial Operations
               BFS                      Basic Financial Statements
               BOA                      Bureau of Audits
               BPS                      Bureau of Payable Services
               BQA                      Bureau of Quality Assurance
               BUCD                     Bureau of Unemployment Compensation Disbursements
               BWDA                     Bureau of Workforce Development Administration
               CACFP                    Child and Adult Care Food Program
               CAO                      County Assistance Office
               CAP                      Corrective Action Plan
               CARES                    Coronavirus Aid, Relief, and Economic Security Act
               CCDBG                    Child Care and Development Block Grant
               CCDF                     Child Care and Development Fund
               CCIS                     Child Care Information Service
               CCYA                     County Children and Youth Agency
               CDBG                     Community Development Block Grants
               CFDA                     Catalog of Federal Domestic Assistance
               CFR                      Code of Federal Regulations
               CHIP                     Children’s Health Insurance Program
               CIS                      Client Information System
               CMIA                     Cash Management Improvement Act of 1990
               CMS                      Centers for Medicare and Medicaid Services
               CNC                      Child Nutrition Cluster
               CN-PEARS                 Child Nutrition Program Electronic Application and
                                         Reimbursement System
               COPPAR                   Commonwealth of Pennsylvania Policy and Procurement Action Request
               COSO                     Committee of Sponsoring Organizations of the Treadway Commission
               COVID-19                 Coronavirus Disease 2019
               CSE                      Child Support Enforcement
               CVA                      Crime Victim Assistance
               CWDS                     Commonwealth Workforce Development System
               CWSRF                    Capitalization Grants for Clean Water State Revolving Funds
               DCED                     Department of Community and Economic Development
               DDAP                     Department of Drug and Alcohol Programs
               DEP                      Department of Environmental Protection
               DFN                      Division of Food and Nutrition
               DFP                      Division of Federal Programs
               DGS                      Department of General Services
               DHS                      Department of Human Services

                                                        116
COMMONWEALTH OF PENNSYLVANIA
Legend of Abbreviations (Continued) - June 30, 2021
     ABBREVIATION             DESCRIPTION

          DMVA            Department of Military and Veterans Affairs
          DOD             United States Department of Defense
          DOE             United States Department of Energy
          DOH             Department of Health
          DOI             United States Department of Interior
          DOJ             United States Department of Justice
          DOL             United States Department of Labor
          DOR             Department of Revenue
          DOT             United States Department of Transportation
          EBT             Electronic Benefits Transfer
          eCIS            Electronic Client Information System
          ED              United States Department of Education
          EPA             United States Environmental Protection Agency
          ERA             COVID - 19 – Emergency Rental Assistance Program
          ESEA            Elementary and Secondary Education Act
          ESSER           Elementary and Secondary School Emergency Relief Fund
          FAC             Federal Audit Clearinghouse
          FAIN            Federal Award Identification Number
          FC              Foster Care – Title IV-E
          FEMA            Federal Emergency Management Agency
          FFY             Federal Fiscal Year
          FHWA            Federal Highway Administration
          FNS             Food and Nutrition Service
          FYE             Fiscal Year Ended
          GAAP            Generally Accepted Accounting Principles
          GAO             United States Government Accountability Office
          HHS             United States Department of Health and Human Services
          HIV             Human Immunodeficiency Virus
          HPC             Highway Planning and Construction
          HSGP            Homeland Security Grant Program
          HUD             United States Department of Housing and Urban Development
          IDEA            Individuals with Disabilities Education Act
          IES             Integrated Enterprise System
          IESO            Integrated Enterprise Systems Office
          IT              Information Technology
          ITP             Information Technology Policy
          ITS             Integrated Tax System
          L&I             Department of Labor and Industry
          LCB             Liquor Control Board
          LEA             Local Educational Agency
          LIHEAP          Low-Income Home Energy Assistance Program
          LWIB            Local Workforce Investment Board
          MA              Medical Assistance Program
          MD              Management Directive
          MLF             Motor License Fund
          MOU             Memorandum of Understanding
          NCLB            No Child Left Behind
          NGMO            National Guard Military Operations and Maintenance Projects
          NIST            National Institute of Standards and Technology
          NSLP            National School Lunch Program
          NSP             Neighborhood Stabilization Program
          OA              Office of Administration
          OB              Office of the Budget
          OCDEL           Office of Child Development and Early Learning
          OCO             Office of Comptroller Operations

                                         117
COMMONWEALTH OF PENNSYLVANIA
Legend of Abbreviations (Continued) - June 30, 2021
     ABBREVIATION             DESCRIPTION

          OCYF            Office of Children, Youth, and Families
          ODP             Office of Developmental Programs
          OIG             Office of Inspector General
          OIM             Office of Income Maintenance
          OIT             Office for Information Technology
          OMB             Office of Management and Budget
          OVR             Office of Vocational Rehabilitation
          PCCD            Pennsylvania Commission on Crime and Delinquency
          PDA             Pennsylvania Department of Aging
          PDE             Pennsylvania Department of Education
          PDOT            Pennsylvania Department of Transportation
          PEMA            Pennsylvania Emergency Management Agency
          PennDOT         Pennsylvania Department of Transportation
          PENNVEST        Pennsylvania Infrastructure Investment Authority
          PID             Pennsylvania Insurance Department
          PIMS            Pennsylvania Information Management System
          PLCB            Pennsylvania Liquor Control Board
          PTE             Pass-through entity
          PUA             Pandemic Unemployment Assistance
          RESEA           Reemployment Services and Eligibility Assessments
          RFP             Request for Proposal
          RS-VR           Rehabilitation Services – Vocational Rehabilitation Grants to States
          SABG            Block Grants for Prevention and Treatment of Substance Abuse
          SAS             Statement on Auditing Standards
          SDLC            Systems Development Life Cycle
          SEA             State Educational Agency
          SEFA            Schedule of Expenditures of Federal Awards
          SNAP            Supplemental Nutrition Assistance Program
          SOC             System and Organization Controls
          SSA             United States Social Security Administration
          SSAE            Statements on Standards for Attestation Engagements
          SSBG            Social Services Block Grant
          SW              Statewide Finding
          SWIF            State Workers’ Insurance Fund
          TANF            Temporary Assistance for Needy Families
          TRE             United States Department of the Treasury
          UC              Unemployment Compensation
          UCMS            Unemployment Compensation Modernization System
          UG              Uniform Guidance
          UI              Unemployment Insurance
          USDA            United States Department of Agriculture
          USDE            United States Department of Education
          USDHS           United States Department of Homeland Security
          USDOJ           United States Department of Justice
          USDOL           United States Department of Labor
          WIA             Workforce Investment Act
          WIC             Women, Infants, and Children
          WIOA            Workforce Innovation and Opportunity Act
          WPRS            Worker Profiling and Reemployment Services




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