Lancaster County, PA Final CRF Desk Review Memo 06.29.23

Summary

Treasury Office of Inspector General desk review memorandum OIG-CA-23-024, dated June 29, 2023, on Lancaster County, Pennsylvania's use of Coronavirus Relief Fund proceeds, sent by Assistant Inspector General for Audit Deborah L. Harker to Acting Chief Recovery Officer Jessica Milano and performed under contract by Castro & Company, LLC. Treasury paid Lancaster County $95,224,629.70 from the fund. Castro found that county personnel could not provide documentation for 19 of the 20 transactions selected, leaving $57,734,925.41 in unsupported obligations and $38,793,071.36 in unsupported expenditures, and it questions costs of $38,793,071.36. It also found missed quarterly reports and a Cycle 6 submission prepared and certified by the same person, rates the risk of unallowable use of funds as high, and recommends that Treasury OIG determine if a full-scope audit is feasible.

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

DEPARTM ENT OF THE TREASURY
WASHINGTON, D.C.  20220
OFFICE OF
June 29, 2023
INSPECTOR GENERAL
MEMORANDUM FOR JESSICA MILANO, ACTING CHIEF RECOVERY OFFICER,
DEPARTMENT OF THE TREASURY
FROM:
Deborah L. Harker /s/
Assistant Inspector General for Audit
SUBJECT:
Desk Review of Lancaster County, Pennsylvania’s Use of
Coronavirus Relief Fund Proceeds (OIG-CA-23-024)
Please find the attached desk review memorandum1 on Lancaster County,
Pennsylvania’s (Lancaster County) use of Coronavirus Relief Fund (CRF) proceeds.
The CRF is authorized under Title VI of the Social Security Act, as amended by
Title V, Division A of the Coronavirus Aid, Relief, and Economic Security Act
(CARES Act). Under a contract monitored by our office, Castro & Company, LLC
(Castro), a certified independent public accounting firm, performed the desk
review. Castro performed the desk review in accordance with the Council of the
Inspectors General on Integrity and Efficiency Quality Standards for Federal
Offices of Inspector General standards of independence, due professional care,
and quality assurance.
In its desk review, Castro found that Lancaster County personnel did not complete
the required quarterly Financial Progress Reports (FPR) for Cycles 12 through 5.3 In
addition, Castro noted Lancaster County’s Cycle 64 submission was prepared and
certified by the same person, thus not complying with the segregation of duties
requirement for quarterly submissions. Castro personnel reviewed documentation
for a non-statistical selection of 20 transactions reported in the quarterly reports
and found that Lancaster County personnel could not provide the necessary
documentation to support 19 of the 20 transactions resulting in total unsupported
obligations and expenditures in the amounts of $57,734,925.41 and
$38,793,071.36, respectively (see attached schedule of monetary benefits).
1 The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) assigned the Department of
the Treasury Office of Inspector General with responsibility for compliance monitoring and
oversight of the receipt, disbursement, and use of Coronavirus Relief Fund (CRF) payments. The
purpose of the desk review is to perform monitoring procedures of the prime recipient’s receipt,
disbursement, and use of CRF proceeds as reported in the grants portal on a quarterly basis.
2 Calendar quarter ending June 30, 2020.
3 Calendar quarter ending June 30, 2021.
4 Calendar quarter ending September 30, 2021.

Page 2
Based on the results of its desk review, Castro determined that the expenditures
related to all payment types reviewed did not comply with the CARES Act and
Treasury Guidance. Additionally, Castro determined that the risk of unallowable
use of funds is high. As such, Castro is recommending Treasury OIG pursue
obtaining documentation from Lancaster County personnel and ensure reporting
corrections are made in the grants portal. Further, based on Lancaster County’s
responsiveness to Treasury OIG’s requests and its ability to provide
documentation, Castro recommends Treasury OIG determine if a full-scope audit
is feasible. Castro and Treasury OIG personnel met with Lancaster County
management to discuss the questioned costs and reporting issues.
In connection with our contract with Castro, we reviewed Castro’s desk review
memorandum and related documentation and inquired of its representatives. Our
review, as differentiated from an audit performed in accordance with generally
accepted government auditing standards, was not intended to enable us to
express an opinion on Lancaster County’s use of the CRF proceeds. Castro is
responsible for the attached desk review memorandum and the conclusions
expressed therein. Our review found no instances in which Castro did not comply
in all material respects with the Council of the Inspectors General on Integrity and
Efficiency’s Quality Standards for Federal Offices of Inspectors General.
We appreciate the courtesies and cooperation provided to Castro and our staff
during the desk review. If you have any questions or require further information,
please contact me at (202) 486-1420, or a member of your staff may contact Lisa
DeAngelis, Deputy Assistant Inspector General for Audit, at (202) 487-8371.
cc:
Michelle. A. Dickerman, Deputy Assistant General Counsel, Department of
the Treasury
Victoria Collin, Chief Compliance & Finance Officer, Office of Recovery
Programs, Department of the Treasury
Pat Mulligan, Budget Services Director, Lancaster County, Pennsylvania
Wayne Ference, Partner, Castro & Company, LLC

Page 3
Attachment
Schedule of Monetary Benefits
According to the Code of Federal Regulations,5 a questioned cost is a cost that is
questioned due to a finding:
(a) which resulted from a violation or possible violation of a statute,
regulation, or the terms and conditions of a Federal award, including for
funds used to match Federal funds;
(b) where the costs, at the time of the review, are not supported by
adequate documentation; or
(c) where the costs incurred appear unreasonable and do not reflect the
actions a prudent person would take in the circumstances.
Questioned costs are to be recorded in the Department of the Treasury’s
(Treasury) Joint Audit Management Enterprise System (JAMES).6 The amount will
also be included in the Office of Inspector General (OIG) Semiannual Report to
Congress. It is Treasury management's responsibility to report to Congress on the
status of the agreed to recommendations with monetary benefits in accordance
with 5 USC Section 405(b) of the Inspector General Act of 1978.
Recommendation
Questioned Costs
Recommendation No. 1
$38,793,071.36
The questioned cost represents amounts provided by Treasury under the
Coronavirus Relief Fund. As discussed in the attached desk review, $38,793,071.36
is Lancaster County’s expenditures reported in the grant reporting portal that
lacked supporting documentation.
5 2 CFR § 200.84 – Questioned Cost
6 JAMES is Treasury’s audit recommendation tracking system.

Castro Company
Auditors ✓
Advisors
1635 King Street
Alexandria, VA 22314
Phone: 703.229.4440
Fax: 703.859.7603
www.castroco.com
Desk Review of Lancaster County, Pennsylvania
June 29, 2023
OIG-CA-23-024
MEMORANDUM FOR DEBORAH L. HARKER,
ASSISTANT INSPECTOR GENERAL FOR AUDIT
FROM:
Wayne Ference
Partner, Castro & Company, LLC
SUBJECT:
Desk Review of Lancaster County, Pennsylvania
On August 10, 2021, we initiated a desk review of Lancaster County,
Pennsylvania’s (Lancaster County) use of the Coronavirus Relief Fund (CRF)
authorized under Title VI of the Social Security Act, as amended by Title V Division
A of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).1 The
objective of our desk review was to evaluate Lancaster County’s documentation
supporting its uses of CRF proceeds as reported in the GrantSolutions2 portal and
to assess the risk of unallowable use of funds. The scope of our desk review was
limited to obligation and expenditure data for the period of March 1, 2020 through
September 30, 2021 as reported in Cycles 13 through 64 in the GrantSolutions
portal.
As part of our desk review, we performed the following:
(1) reviewed Lancaster County’s quarterly Financial Progress Reports (FPRs)
submitted in the GrantSolutions portal through September 30, 2021;
(2) reviewed the Department of the Treasury’s (Treasury) Coronavirus Relief
Fund Guidance as published in the Federal Register on January 15, 2021;5
1 P.L. 116-136 (March 27, 2020).
2 GrantSolutions, a grant and program management Federal shared service provider under the
U.S. Department of Health and Human Services, developed a customized and user-friendly
reporting solution to capture the use of CRF payments from recipients.
3 Calendar quarter ending June 30, 2020.
4 Calendar quarter ending September 30, 2021.
5 Coronavirus Relief Fund Guidance as published in the Federal Register (January 15, 2021)
https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register_2021-00827.pdf
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Desk Review of Lancaster County, Pennsylvania
(3) reviewed Treasury Office of Inspector General (OIG) Coronavirus Relief
Fund Frequently Asked Questions Related to Reporting and Recordkeeping;6
(4) reviewed Treasury OIG’s monitoring checklists7 of Lancaster County’s
quarterly FPR submissions for reporting deficiencies;
(5) reviewed other audit reports issued, such as Single Audit reports, and those
issued by the Government Accountability Office and other applicable
Federal agency OIGs for internal control or other deficiencies that may pose
risk or impact Lancaster County’s uses of CRF proceeds;
(6) reviewed Treasury OIG Office of Investigations, Pandemic Response
Accountability Committee (PRAC),8 and Treasury OIG Office of Counsel
input on issues that may pose risk or impact Lancaster County’s uses of
CRF proceeds;
(7) interviewed key personnel responsible for preparing and certifying
Lancaster County’s GrantSolutions quarterly FPR submissions, as well as
officials responsible for obligating and expending CRF proceeds;
(8) made a non-statistical selection of contracts, grants, direct payments, and
aggregate reporting data9 identified through GrantSolutions reporting; and
(9) evaluated documentation and records used to support Lancaster County’s
quarterly FPRs.
Based on the results of our desk review, documentation supporting the uses of
CRF proceeds did not comply with the CARES Act and Treasury’s Guidance,
resulting in total questioned costs of $38,793,071.36. Additionally, we determined
Lancaster County’s risk of unallowable use of funds to be high. As such, Castro is
recommending that Treasury OIG pursue obtaining documentation from
Lancaster County management and ensure reporting corrections are made.
Further, based on Lancaster County’s responsiveness to
6 Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently Asked
Questions Related to Reporting and Recordkeeping OIG-20-028R; March 2, 2021
7 The checklists are used by Treasury OIG to monitor the progress of prime recipient reporting in
the GrantSolutions portal. GrantSolutions quarterly submission reviews are designed to identify
material omissions and significant errors, and where necessary, include procedures for notifying
prime recipients of misreported data for timely correction. Treasury OIG follows the CRF Prime
Recipient Quarterly GrantSolutions Submissions Monitoring and Review Procedures Guide, OIG­
CA-20-029R to monitor the prime recipients quarterly.
8 Section 15010 of P.L. 116-136 established the Pandemic Response Accountability Committee
within the Council of the Inspectors General on Integrity and Efficiency to promote transparency
and conduct and support oversight of covered funds (see Footnote 17 for a definition of covered
funds) and the coronavirus response to (1) prevent and detect fraud, waste, abuse, and
mismanagement; and (2) mitigate major risks that cut across program and agency boundaries.
9 Recipients are required to report CRF transactions greater than or equal to $50,000 in detail in the
GrantSolutions portal. Transactions less than $50,000 can be reported as an aggregate lump-sum
amount by type (contracts, grants, loans, direct payments, and transfers to other government
entities).
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Desk Review of Lancaster County, Pennsylvania
Treasury OIG’s requests and its ability to provide documentation, we recommend
Treasury OIG determine if a full-scope audit is feasible.
Non-Statistical Transaction Selection Methodology
Treasury issued a CRF payment to Lancaster County of $95,224,629.70. As of Cycle
6,10 Lancaster County’s cumulative obligations and expenditures were
$90,231,105.54 and $68,324,633.90, respectively. Lancaster County’s cumulative
obligations and expenditures by payment type as reported in GrantSolutions
through Cycle 610 are summarized below:
Payment Type
Cumulative
Cumulative
Obligations
Expenditures
Contracts >= $50,000
$ 7,965,407.78
$
7,965,397.78
Grants >= $50,000
$ 49,269,040.04
$
49,269,040.04
Loans >= $50,000
$
-
$
-
Transfers >= $50,000
$
-
$
-
Direct Payments >= $50,000
$ 10,163,049.03
$
10,163,049.03
Aggregate Reporting < $50,000
$ 22,833,608.69
$
927,147.05
Aggregate Payments to Individuals
(Any Amount)
$
-
$
-
Totals
$ 90,231,105.54
$
68,324,633.90
Castro made a non-statistical selection of Contracts greater than or equal to
$50,000, Grants greater than or equal to $50,000, Direct Payments greater than or
equal to $50,000, and Aggregate Reporting less than $50,000. Selections were
made using auditor judgment based on information and risks identified in
reviewing audit reports, the GrantSolutions portal reporting anomalies11 identified
by the Treasury OIG CRF monitoring team, and review of Lancaster County’s FPR
submissions. Castro noted Lancaster County did not obligate or expend CRF
proceeds for Loans greater than or equal to $50,000, Transfers greater than or
equal to $50,000,12 or Aggregate Payments to Individuals;13 therefore, we did not
make a selection of transactions from these categories.
The number of transactions (20) we selected to test were based on Lancaster
County’s total CRF award amount and our overall initial risk assessment of
Lancaster County. To allocate the number of transactions (20) by obligation type
10 Calendar quarter ending September 30, 2021.
11 Treasury OIG has a pre-defined list of risk indicators that are triggered based on data submitted
by recipients in the FPR submissions that meet certain criteria. Castro reviewed these results
provided by Treasury OIG for Lancaster County.
12 A transfer to another government entity is a disbursement or payment to a government entity
that is legally distinct from the prime recipient.
13 Obligations and expenditures for payments made to individuals, regardless of amount, are
required to be reported in the aggregate in the GrantSolutions portal to prevent inappropriate
disclosure of personally identifiable information.
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Desk Review of Lancaster County, Pennsylvania
(Contracts greater than or equal to $50,000, Grants greater than or equal to
$50,000, Direct Payments greater than or equal to $50,000, and Aggregate
Reporting less than $50,000), we compared the obligation type dollar amounts as
a percentage of cumulative obligations for Cycle 6.14
Additionally, Treasury OIG provided information on an anomaly identified for
Lancaster County. Specifically, Lancaster County received funding from multiple
other federal programs and would need effective internal controls to ensure funds
were properly charged. Due to the coverage of our transactions selected for
testing, this anomaly reported by Treasury OIG did not result in additional
transactions to test for Castro’s desk review.
Background
The CARES Act appropriated $150 billion to establish the CRF. Under the CRF,
Treasury made payments for specified uses to States; eligible units of local
governments; the District of Columbia; U.S. Territories, including the
Commonwealth of Puerto Rico, the United States Virgin Islands, Guam, American
Samoa, and the Commonwealth of the Northern Mariana Islands; and Tribal
governments. Treasury issued a CRF payment to Lancaster County for
$95,224,629.70. The CARES Act stipulates that a recipient may only use the funds
to cover costs that—
(1) are necessary expenditures incurred due to the public health emergency with
respect to the coronavirus disease 2019 (COVID-19);
(2) were not accounted for in the budget most recently approved as of
March 27, 2020; and
(3) were incurred between March 1, 2020 and December 31, 2021.15
Section 15011 of the CARES Act, requires each covered recipient16 to submit to
Treasury and the PRAC, no later than 10 days after the end of each calendar
14 Calendar quarter ending September 30, 2021.
15 P.L. 116-260 (December 27, 2020). The period of performance end date of the CRF was extended
through December 31, 2021 by the Consolidated Appropriations Act, 2021. The period of
performance end date for tribal entities was further extended to December 31, 2022 by the State,
Local, Tribal, and Territorial Fiscal Recovery, Infrastructure, and Disaster Relief Flexibility Act,
Division LL of the Consolidated Appropriations Act, 2023, P.L. 117-328, December 29, 2022, 136
Stat. 4459.
16 Section 15011 of P.L. 116-136 defines a covered recipient as any entity that receives large
covered funds and includes any State, the District of Columbia, and any territory or possession of
the United States.
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Desk Review of Lancaster County, Pennsylvania
quarter, a report that contains (1) the total amount of large covered funds17,18
received from Treasury; (2) the amount of large covered funds received that were
expended or obligated for each project or activity; (3) a detailed list of all projects
or activities for which large covered funds were expended or obligated; and (4)
detailed information on any level of sub-contracts or sub-grants awarded by the
covered recipient or its sub-contractees or sub-grantees.
The CARES Act assigned Treasury OIG the responsibility for compliance
monitoring and oversight of the receipt, disbursement, and use of CRF proceeds.
Treasury OIG also was assigned authority to recoup funds in the event that it is
determined a recipient failed to comply with requirements of subsection 601(d) of
the Social Security Act, as amended, (42 U.S.C. 801(d)).
Desk Review Results
Our review of the quarterly FPR submissions through September 30, 2021
identified reporting issues and variances, as detailed below.
Financial Progress Reports
Lancaster County personnel completed a quarterly FPR for Cycle 619 however; they
did not complete FPRs for Cycles 120 through 521 as required under the CARES Act.
The CARES Act guidance requires quarterly FPRs to be submitted by the 10th day
of the month following quarter end unless it falls on a holiday. Further, their Cycle
61919 submission was prepared and certified by the same person. Treasury OIG
Guidance22 requires ”two (2) designees (preparers) to input quarterly data and one
(1) official authorized to certify that the data, in part, is true, accurate, and
complete.” The certifying official for Lancaster County reported that the Budget
Services department was responsible for the CRF quarterly reporting. This official
reported that the lack of segregation of duties occurred because staffing in his
office was reduced to one person.
Overall Obligation and Expenditure Variance
As of Cycle 6,19 Lancaster County personnel obligated CRF proceeds of
17 Section 15010 of P.L. 116-136 defines covered funds as any funds, including loans, that are made
available in any form to any non-Federal entity, not including an individual, under Public Laws 116­
123, 127, and 136, as well as any other law which primarily makes appropriations for Coronavirus
response and related activities.
18 Section 15011 of P.L. 116-136 defines large covered funds as covered funds that amount to more
than $150,000.
19 Calendar quarter ending September 30, 2021.
20 Calendar quarter ending June 30, 2020.
21 Calendar quarter ending June 30, 2021.
22 Department of the Treasury Office of Inspector General Coronavirus Relief Fund Reporting and
Record Retention Requirements OIG-CA-20-021; July 2, 2020
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Desk Review of Lancaster County, Pennsylvania
$90,231,105.54. Castro noted that $1,725,769.40 in the Direct Payments greater
than or equal to $50,000 obligation type should have been reported as Aggregate
Reporting less than $50,000.
Aggregate Grants less than $50,000 in GrantSolutions were reported in amounts
of $22,833,608.69 in Obligations and $927,147.05 for both Current Quarter
Expenditures and Cumulative Expenditures. According to Lancaster County
personnel, they should have reported Cumulative Expenditures in the amount of
$22,833,608.69, which includes expenditures for Project 45018 ($927,147.05),
Project 45009 ($21,524,618.53), and Project 45016 ($381.843.11). As a result,
Lancaster County under-reported expenditures for Aggregate Grants less than
$50,000 by $21,906,461.64. Lancaster County officials stated staffing constraints
were attributable to the variance.
Based on the issues noted above, we determined Lancaster County is not
compliant with Treasury OIG Guidance OIG-CA-20-02123 because the official
authorized to certify that the data is true, accurate, and complete did not ensure
that its submission met all the Treasury OIG Guidance requirements.
We determined Lancaster County was not compliant with Treasury OIG Guidance
OIG-CA-20-028R24 FAQs #’s 10, 53, 54, and 59 because these transactions did not
meet the definition of an Aggregate Reporting less than or equal to $50,000
transaction.
Sub-recipient Reporting
Based on our review of the supporting documentation, Lancaster County
personnel did not input sub-recipient information in their FPR for all 19 sub-
recipients. We noted that Lancaster County personnel incorrectly reported the
DUNS/ID Number, Awardee Name and Award Number within GrantSolutions for
all obligation types by using project numbers and project names. A Lancaster
County official stated this issue was due to staffing constraints.
23 https://oig.treasury.gov/sites/oig/files/2021-01/OIG-CA-20-021.pdf
24 https://oig.treasury.gov/sites/oig/files/2021-03/OIG-CA-20-028R.pdf
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Desk Review of Lancaster County, Pennsylvania
Summary of Testing Results
Transactions selected for detailed review were not supported by documentation
and we were unable to determine if expenditures were allowable in accordance
with the CARES Act and Treasury’s guidance. For all payment types tested, we
were unable to determine if all the transactions tested were necessary
expenditures due to the COVID-19 public health emergency, were not accounted
for in the budget most recently approved as of March 27, 2020, and were incurred
during the covered period. The transactions selected for testing were not selected
statistically, and therefore results cannot be extrapolated to the total universe of
transactions.
The following table includes the total cumulative expenditure population amount
and the cumulative expenditure amount tested. Additionally, this table includes a
summary of Castro’s testing results over cumulative expenditure transaction
balances. Within the “Exception Noted: IPA [Independent Public Accountant]
Recommended for Treasury OIG Follow-up” section of this table, we have
included a summary of unsupported and ineligible expenditures identified as
questioned costs during our desk review. These costs do not comply with the
CARES Act and Treasury’s Guidance. Additionally, in the far-right column, we
have identified the cumulative expenditures that Castro tested without exceptions
noted. See the Desk Review Results section below this table for a detailed
discussion of questioned costs and other issues identified throughout the course
of our desk review.
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–
-
-
Desk Review of Lancaster County, Pennsylvania
Summary of Expenditure Testing and Recommended Results As of Cycle 625
Payment Type
Cumulative
Expenditure
Population
Amount
Cumulative
Expenditure
Tested Amount
Exception Noted: IPA
Recommended for Treasury OIG
Follow up
Castro
Reviewed Value
Without
Exception
(per Support)
Unsupported
Ineligible
Contracts >=
$50,000
$
7,965,407.78
$
7,965,407.78
$
142,779.53
$
-
$
7,822,628.25
Grants >= $50,000
$ 49,269,040.04
$ 49,269,040.04
$ 33,976,014.86
$
-
$ 15,293,025.18
Loans >= $50,000
$
-
$
-
$
-
$
-
$
-
Transfers >=
$50,000
$
-
$
-
$
-
$
-
$
-
Direct Payments
>= $50,000
$
8,437,279.63
$
4,727,141.97
$
3,930,341.97
$
-
$
796,800.00
Aggregate
Reporting <
$50,000
$ 24,559,378.09
$
838,185.62
$
743,935.00
$
-
$
94,250.62
Aggregate
Payments to
Individuals (in any
amount)
$
-
$
-
$
-
$
-
$
-
Totals
$ 90,231,105.54
$ 62,799,775.41
$ 38,793,071.36
$
$ 24,006,704.05
The issues discussed below represent unsupported transaction balances noted
during our testing. Subsection 601 (d) of the Social Security Act, as amended, (42
U.S.C. 801 (d)) requires prime recipients to ensure eligible use of funds, and
Treasury OIG Guidance OIG-CA-20-021, CRF Reporting and Record Retention
Requirements, states: “Recipients of Coronavirus Relief Fund payments shall
maintain and make available to the Treasury OIG upon request all documents and
financial records sufficient to establish compliance.” Lancaster County did not
comply because it did not maintain and provide sufficient records to support
transactions reported in the GrantSolutions portal.
Contracts Greater than or Equal to $50,000
Lancaster County’s Contracts greater than or equal to $50,000 did not comply with
the CARES Act and Treasury’s Guidance. Lancaster County personnel could not
provide the necessary documents, including contracts and invoices, to support
$7,221,357.78 in obligations and $142,779.53 in expenditures reported for all five
selected transactions as reported in GrantSolutions. This resulted in total
questioned costs for Contracts greater than or equal to $50,000 of $142,779.53. A
25 Calendar quarter ending September 30, 2021.
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Desk Review of Lancaster County, Pennsylvania
Lancaster County official explained that maintaining documentation was difficult
due to staffing constraints.
Grants Greater than or Equal to $50,000
Lancaster County personnel could not provide the necessary documents,
including grants and expenditure detail to support $45,945,040.04 in obligations
and $33,976,014.86 in expenditures reported for all seven selected transactions as
reported in GrantSolutions. This resulted in total questioned costs for Grants
Greater than or Equal to $50,000 of $33,976,014.86. A Lancaster County official
explained that maintaining documentation was difficult due to staffing constraints.
Direct Payments Greater than or Equal to $50,000
Lancaster County personnel could not provide the necessary documents to
support $3,930,341.97 in obligations and $3,930,341.97 in expenditures reported
for the two selected transactions as reported in GrantSolutions. This resulted in
total questioned costs for Direct Payments Greater than or Equal to $50,000 of
$3,930,341.97. A Lancaster County official explained that maintaining
documentation was difficult due to staffing constraints.
Aggregate Reporting Less than $50,000
Lancaster County personnel could not provide the necessary documents to
support $638,185.62 in obligations and $743,935.00 in expenditures reported for
all six of the selected transactions as reported in GrantSolutions. This resulted in
total questioned costs for Aggregate Reporting less than $50,000 of $743,935.00. A
Lancaster County official explained that maintaining documentation was difficult
due to staffing constraints.
Conclusion
Based on our review, Lancaster County lacked documentation to support the uses
of CRF proceeds as reported in the GrantSolutions portal and we determined that
the expenditures related to all obligation types reviewed did not comply with the
CARES Act and Treasury’s Guidance. Total unsupported obligations and
expenditures amounted to $57,734,925.41 and $38,793,071.36, respectively. Total
costs questioned are $38,793,071.36.
Based on the totality of the work performed and due to the errors identified
above, we determined Lancaster County’s risk of unallowable use of funds to be
high. As such, Castro is recommending that Treasury OIG pursue obtaining
documentation from Lancaster County personnel and ensure reporting
corrections are made. Further, based on Lancaster County’s responsiveness to
Treasury OIG’s requests and its ability to provide documentation, we recommend
Treasury OIG determine if a full-scope audit is feasible.
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Desk Review of Lancaster County, Pennsylvania
*****
All work completed with this letter complies with the Council of the Inspectors
General on Integrity and Efficiency’s Quality Standards for Federal Offices of
Inspectors General, which require that the work adheres to the professional
standards of independence, due professional care, and quality assurance to
ensure the accuracy of the information presented.26 We appreciate the courtesies
and cooperation provided to our staff during the desk review.
Sincerely,
Wayne Ference
Partner, Castro & Company, LLC
26 https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf
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