10-Appendix U.pdf

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Delaware County, Pennsylvania

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This is an Appendix U audit requirements document issued by the Delaware County Department of Human Services in Pennsylvania, establishing mandatory audit guidance for subrecipient organizations receiving financial assistance from the County's human services programs, including Mental Health, Intellectual and Developmental Disabilities, Early Intervention, Drug and Alcohol, Adult and Family Services, and Child Welfare. The document outlines comprehensive audit requirements applicable to organizations receiving federal, state, or county financial assistance, whether directly from the federal government or indirectly as pass-through awards. Subrecipient organizations must obtain audits in accordance with Generally Accepted Auditing Standards (GAAS) and Government Auditing Standards (Yellow Book), with audit reporting packages due to the County within 30 days of audit completion or nine months after the fiscal year end, whichever is earlier. The document establishes engagement letter requirements, auditor independence standards, and detailed specifications for both Single Audits and Program-Specific Audits under the Uniform Guidance.

The audit threshold for Single Audits or Program-Specific Audits is $750,000 or more in total federal awards from all funding sources during the fiscal year; organizations expending less than $750,000 in federal funds are exempt from Single Audit requirements but must maintain auditable records accessible to federal, state, and local agencies for five years. Subrecipient organizations must submit supplementary financial schedules reconciling Delaware County support to audited financial statements, and must notify the County of their audit status within 45 days of fiscal year end using the prescribed notification forms. The County reserves the right to conduct additional audits of a financial or performance nature and may impose sanctions for untimely audit submissions without approved extensions. All audit workpapers must be retained for a minimum of three years from issuance and made available upon request to cognizant agencies, oversight agencies, the County, and federal representatives. Delaware County passes through audit requirements from the Pennsylvania Department of Human Services and the Pennsylvania Department of Drug and Alcohol, with DDAP requiring audits when organizations expend $750,000 or more in federal awards or more than $500,000 in state funds during the state fiscal year.

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APPENDIX U

Standard_Appendices(AppendixU) Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

DELAWARE COUNTY DEPARTMENT OF HUMAN SERVICES

AUDIT REQUIREMENTS

TABLE OF CONTENTS

U-I OVERVIEW

Introduction 1 Obtaining an Engagement Letter 2 Interpretation of Appendix U 2 Auditor Independence 2 Audit Objectives 2 Audit Reporting Package Submission 3 Extension of Submission Date for Audit Reporting Package 3 Allocations of Indirect Costs 4 Retained Revenue 4 Fraud and Illegal Acts 4 Additional Audit Provisions 5 Special Purpose Reports 6

U-II GENERAL AUDIT REQUIREMENTS

Federally Mandated Audit Requirements Subpart F 7 Local Governments or Non-Profit Organizations 7 For-Profit Organizations 7 Federal Expenditures Notification 8 Types of Federal Audits Single Audits Performed Under the Uniform Guidance 8 Program Specific Audits Performed Under the Uniform Guidance 11

U-III THE COUNTY’S FUNDING SOURCES

Pennsylvania Department of Human Services Audit Guidelines 13 Pennsylvania Department of Drug and Alcohol Audit Guidelines 14

APPENDIX U EXHIBIT A 15

APPENDIX U EXHIBIT B 17

APPENDIX U EXHIBIT C 19

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

AUDIT REQUIREMENTS FOR SUBRECIPIENT ORGANIZATIONS

U-I OVERVIEW

Introduction

The purpose of Appendix U is to set forth audit guidance for provider organizations receiving financial assistance from the Delaware County Department of Human Services (County) either directly or as a subrecipient of a pass-through award.

This audit guidance is applicable to the following Delaware County Human Services programs:

▪ Mental Health

▪ Intellectual and Developmental Disabilities

▪ Early Intervention

▪ Drug and Alcohol

▪ Adult and Family Services

▪ Child Welfare

Depending on the type and amount of funding received, an audit of the financial assistance provided in connection with the County contract may be required.

Awards received from the County may include federal, state, or county financial assistance. In addition to Federal audit requirements, the Commonwealth of Pennsylvania Department of Human Services (DHS) and the Pennsylvania Department of Drug and Alcohol (DDAP) have unique audit requirements which need to be considered in the determination of audit compliance.

Any pass-through of federal awards is required to be reported by subrecipients on the same basis as is required for federal financial assistance received directly from a federal awarding agency.

The County is responsible for ensuring that the financial statements of its subrecipients are appropriately audited in accordance with Government Auditing Standards (the Yellow Book), applicable program requirements and contract provisions, and, when appropriate, the Single Audit Act Amendments of 1996, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) of the Office of Management and Budget (OMB), the Pennsylvania Department of Human Services Single Audit Supplement, and the Pennsylvania Department of Drug and Alcohol audit guidelines.

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

Obtaining an Engagement Letter

For all audits performed in accordance with the provisions of Appendix U, the subrecipient organization must have executed a written engagement letter with its independent auditor establishing an understanding about the services to be performed. The engagement letter should specify the responsibilities of both the subrecipient organization and the auditor and the objectives and scope of the engagement.

Interpretation of Appendix U

Any questions pertaining to Appendix U should be referred to:

Department of Human Services Attn: Contracting Unit 4990 State Road, Suite 101 Drexel Hill, PA 19026 Phone No.: 610-713-2115 Fax No.: 610-713-2326

Auditor Independence

Subrecipient organizations shall ensure that the audit organization and the auditors performing the audit work are independent of mind as well as in appearance. It is crucial that the audit organization and the audit team act with integrity and exercise objectivity and professional skepticism.

Audit Objectives

The audit must be conducted in accordance with auditing standards generally accepted in the United States of America (GAAS) and the standards applicable to financial audits contained in Government Auditing Standards (GAGAS or Yellow Book), issued by the Comptroller General of the United States. A Yellow Book audit can be required by law, regulation, agreement, contract, or policy.

The most common Yellow Book audits are those required as part of a Single Audit performed under Subpart F of the Uniform Guidance, which supersedes OMB Circular A-133 audit requirements. A Single Audit is required if the organization expends more than a specified amount of federal awards. Another common way an organization may be subject to the Yellow Book requirements is because of provisions included in grant agreements or contracts regardless of the amount of federal awards expended. The Yellow Book incorporates GAAS.

Thus, performing a financial audit requires auditing the financial statements in accordance with GAAS, as well as following the additional general, field work, and reporting standards contained in Government Auditing Standards. This includes testing and reporting on compliance with laws, regulations, and provisions of contracts or grant agreements for which noncompliance would be

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25 material to the financial statements. An audit of financial statements in accordance with the Yellow Book may include additional reporting and documentation responsibilities.

The subrecipient organization may satisfy the audit requirements of this contract by obtaining a Single Audit in accordance with the provisions of Subpart F of the Uniform Guidance. Either a Program Specific Audit or an organization-wide Single Audit, performed in accordance with applicable federal, state and county requirements, may be acceptable. In some instances, the auditee may elect to have a series of audits covering departments, agencies, or other organizational units that expended or otherwise administered federal awards, providing that each such audit encompasses the necessary financial reporting requirements for each such department, agency, or other organizational unit.

The subrecipient organization’s audited financial report is utilized by the County to meet its responsibilities in overseeing its programs and assuring the integrity of funds expended. Upon completion of the audit, the supporting audit workpapers shall be made available, upon request, in connection with a quality review, to resolve any audit findings or to carry out oversight responsibilities.

Audit Reporting Package Submission

The County requests that one copy of the audit reporting package conforming to this Appendix U be delivered to the County at the following address:

Department of Human Services Attn: Contracting Unit 4990 State Road, Suite 101 Drexel Hill, PA 19026

The audit reporting package submission date is 30 days after completion of the audit, but in any event, not later than 9 months after the end of the audit period.

However, earlier submission to the County is encouraged.

Extension of Submission Date for Audit Reporting Package

If it is determined that the audit reporting package cannot be submitted to the County before the due date, a written request for extension must be made by submission of Exhibit C to the County. The request must be received by the County at least 2 weeks prior to the due date.

The County may impose sanctions whenever the audit package is not timely submitted and an extension request has not been granted.

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

Allocations of Indirect Costs

Indirect costs are those costs incurred for a common or joint purpose benefiting more than one cost objective or not readily assignable to the cost objective specifically benefited without effort disproportionate to the results achieved.

Indirect costs can be allocated on an individual line-item basis or collected in an expense pool and allocated in total, utilizing an appropriate base on which to allocate the indirect expenses. In order to achieve equitable cost allocation, a plan must be established to define which costs are to be charged directly and which costs are to be treated as common or indirect costs.

If indirect costs are allocated, then the auditor has responsibility concerning the reasonableness of the allocation. The main purpose in allocating indirect costs is to ensure that each program bears its fair share of costs compared to other programs. Indirect costs are charged by way of a cost allocation plan. The cost allocation plan should ensure that:

▪ Costs are consistent and logical;

▪ The allocation includes only costs incurred for a common or joint purpose that benefit more than one program and are not readily assignable to one program;

▪ Each program bears its fair share of costs compared to other programs;

▪ Indirect costs are not charged as both direct and indirect costs; and

▪ The same indirect costs are not being charged to different programs.

Retained Revenue

Delaware County Human Services programs may approve retained revenue allowances by subrecipients by specifically including special retained revenue provisions in the contract. In no case will retained revenue allowances exceed 3% of the total gross revenues applicable to any contract funding representing pass-through funding from Pennsylvania Department of Human Services.

Fraud and Illegal Acts

If fraud or illegal acts are discovered, the auditor should notify the primary executive officer of the subrecipient organization. The subrecipient organization should then promptly notify the County. If the subrecipient’s primary executive officer is in any way involved with the acts, the auditor should then notify the County directly. The County will, in turn, take the matter to the funding agency.

There is no level of materiality to be considered when reporting fraud or illegal acts.

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

Additional Audit Provisions

Subrecipient organizations can be required to have audits by contract or other means, even when the audit would not be required by law.

The County, federal, and state agencies, or their authorized representatives, reserve the right to perform additional audits of a financial and/or performance nature, if deemed necessary in carrying out their program administration and monitoring responsibilities. Any such additional work may rely on the work already performed by the Subrecipient’s auditor, and the costs for any additional work performed will be borne by those agencies at no additional expense to the Subrecipient. A federal awarding agency may request that a specific federal program be audited as a major program in lieu of the federal awarding agency conducting or arranging for additional audits.

If it is decided by the County that an audit of this contract will be performed, the Subrecipient will be given advance notice. The Subrecipient shall maintain books, records, and documents that support the services provided, that the fees retained are in accordance with the contract, and that the Subrecipient has complied with the contract terms and conditions. The Subrecipient agrees to make available, upon reasonable notice, at the office of the Subrecipient, during normal business hours, for the term of this contract and the retention period set forth in this Appendix U, all books, records, and documents for inspection, audit, or reproduction by the County or a state or federal agency or their authorized representative.

Audit working papers and audit reports must be retained by the Subrecipient’s auditor for a minimum of three years from the date of issuance of the audit report, unless the Subrecipient or the Subrecipient’s auditor is notified in writing by the cognizant agency for audit, oversight agency for audit, cognizant agency for indirect costs, or the County, to extend the retention period. The term "cognizant agency" means any Federal or State agency that has the primary audit or oversight responsibility for a particular contractor or grantee. Audit working papers must be made available, upon request, to the cognizant or oversight agency for audit or its designee, cognizant agency for indirect costs, a federal agency, General Accounting Office, the County or its designee at the completion of the audit, as part of a quality review, to resolve audit findings, or to carry out oversight responsibilities. Access to audit documentation includes the right to obtain copies of audit documentation, as is reasonable and necessary.

The Subrecipient shall preserve all books, records, and documents related to the program year for at least three years from the contract expiration date, or until all questioned costs or activities have been resolved to the satisfaction of the grantor or pass-through agency, or as required by applicable federal laws and regulations, whichever is longer. If the program contract is completely or partially terminated, Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25 the records relating to the work terminated shall be preserved and made available for a period of three years from the date of any resulting final settlement.

Special Purpose Reports

The County may require the subrecipient organization or its auditor to issue other reports in addition to those reports addressed in Appendix U. Special Purpose Reports will generally be referenced in the contract.

REMAINDER OF PAGE

INTENTIONALLY LEFT BLANK

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

U-II GENERAL AUDIT REQUIREMENTS

A. Federally Mandated Audit Requirements

Subpart F

The subrecipient organization must comply with all federal, state, and county audit requirements including the Single Audit Act, as amended, Subpart F of the Uniform Guidance, Audits of States, Local Governments, and Non-Profit Organizations, state audit supplements and audit requirements, other applicable laws or regulations, and any amendments to such other applicable laws or regulations which may be enacted or promulgated by federal, state, or local government.

Local Governments or Non-Profit Organizations

If the subrecipient organization expends total federal awards of $750,000 or more (from all funding sources) during its fiscal year, either directly from the federal government or indirectly from a recipient of federal funds, the subrecipient organization is required to have a Single Audit or Program Specific Audit performed in accordance with the provisions of Subpart F of the Uniform Guidance.

If the subrecipient organization expends total federal awards of less than $750,000 (from all funding sources) during its fiscal year, it is exempt from these audit requirements. However, it is required to maintain auditable records of federal, state, and local funds that supplement such awards, and to provide access to such records by federal, state, and local agencies or their designees for a period of at least 5 years after the report release date or for any additional period requested. An organization expending less than $750,000 in federal funds may nevertheless be subject to audit requirements specific to the programs from which they receive funds.

For-Profit Organizations

The Uniform Guidance applies primarily to state and local governments, Indian tribes, institutions of higher education and nonprofit organizations that carry out a federal award as a recipient or subrecipient. However, a subrecipient organization is not exempt from reporting requirements on the basis that it is a for-profit entity. Where funding has been passed through to a for-profit subrecipient, the primary recipient or subrecipient must ensure compliance with applicable laws and regulations. This can be accomplished through pre-award audits, monitoring and post-award audits. Specific audit requirements may also be included in the contract with the for-profit recipient. In some cases, program-specific audits may be required.

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

B. Federal Expenditures Notification

Subrecipient organizations receiving funding from the Delaware County Department of Human Services are required to provide the County with notification regarding federal expenditures. The purpose of this notification is to determine which of the County’s subrecipient organizations has met the Uniform Guidance Single Audit threshold. The notification is to be completed and forwarded to the Delaware County Department of Human Services within 45 days after the subrecipient’s fiscal year end. The schedule format appears as Exhibit B on page 17 of this Appendix U. Subrecipient organizations not meeting the Single Audit threshold are required to provide the County with certain information described on page 2 of Exhibit B.

C. Types of Federal Audits

1. Single Audits Performed Under the Uniform Guidance

General: The Single Audit shall be conducted in accordance with GAGAS/Yellow Book. The audit shall cover the entire operations of the auditee or at the option of the auditee, a series of audits that cover departments, agencies, and other organizational units which expended, or otherwise administered, federal awards during the fiscal year. Each such audit shall encompass the financial statements and Schedule of Expenditures of Federal Awards. The audited financial statements and the Schedule of Expenditures of Federal Awards shall be presented for the same fiscal year.

Financial Statements: The auditor shall determine whether the financial statements of the auditee are presented fairly in all material respects in conformity with U.S. generally accepted accounting principles. The auditor shall also determine whether the Schedule of Expenditures of Federal Awards is presented fairly in all material respects in relation to the auditee’s financial statements taken as a whole.

Other Reports: The auditor shall issue a Yellow Book report on internal control over financial reporting and on compliance and other matters and a Single Audit report on compliance with requirements that could have a direct and material effect on each major program and on internal control over compliance.

Audit Follow-up: The auditor shall follow-up on prior audit findings, perform procedures to assess the reasonableness of the Summary Schedule of Prior Audit Findings prepared by the auditee, and report, as a current year audit finding, if it is concluded that the Summary Schedule of Prior Audit Findings materially misrepresents the status of any prior year finding. The auditor shall perform audit follow-up procedures, regardless of whether a prior audit finding relates to a major program, in the current year.

Single Audit Reporting Package Requirements Checklist:

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▪ Financial statements that reflect financial position, results of operations, or changes in net assets and, when appropriate, cash flows for the fiscal year.

▪ Schedule of Expenditures of federal, state & local awards for the period covered by the financial statements.

▪ Summary schedule of prior audit findings

▪ The auditor’s opinion (or disclaimer of opinion) as to whether the financial statements are presented fairly in all material respects in accordance with generally accepted accounting principles and an opinion (or disclaimer of opinion) as to whether the schedule of expenditures of federal awards is fairly stated in all material respects in relation to the financial statements as a whole.

▪ A report on internal control over financial reporting and compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, noncompliance with which could have a material effect on the financial statements. This report must describe the scope of testing of internal control and compliance and the results of the tests, and, where applicable, it will refer to the separate schedule of findings and questioned costs.

▪ A report on compliance for each major program and on internal control over compliance. This report must describe the scope of testing of internal control over compliance, include an opinion or modified opinion as to whether the auditee complied with Federal statutes, regulations, and the terms and conditions of Federal awards which could have a direct and material effect on each major program and refer to the separate schedule of findings and questioned costs.

▪ A schedule of findings and questioned costs which must include the following three components:

(1) A summary of the auditor’s results, which must include:

(i) The type of report the auditor issued on whether the financial statements audited were prepared in accordance with GAAP (i.e., unmodified opinion, qualified opinion, adverse opinion, or disclaimer of opinion);

(ii) Where applicable, a statement about whether significant deficiencies or material weaknesses in internal control were disclosed by the audit of the financial statements;

(iii) A statement as to whether the audit disclosed any noncompliance that is material to the financial statements of the auditee;

(iv) Where applicable, a statement about whether significant deficiencies or material weaknesses in internal control over major programs were disclosed by the audit;

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

(v) The type of report the auditor issued on compliance for major programs (i.e., unmodified opinion, qualified opinion, adverse opinion, or disclaimer of opinion);

(vi) A statement as to whether the audit disclosed any audit findings that the auditor is required to report;

(vii) An identification of each individual major program, or in the case of a cluster of programs, the cluster name as shown on the Schedule of Expenditures of Federal Awards;

(viii) The dollar threshold used to distinguish between Type A and Type B programs; and

(ix) A statement as to whether the auditee qualified as a low-risk auditee under the criteria for a low-risk auditee.

(2) Findings relating to the financial statements which are required to be reported in accordance with GAGAS.

(3) Findings and questioned costs for Federal awards.

(i) Audit findings (e.g., internal control findings, compliance findings, questioned costs, or fraud) that relate to the same issue should be presented as a single audit finding. Where practical, audit findings should be organized by Federal agency or pass-through entity.

(ii) Audit findings that relate to both the financial statements and Federal awards should be reported in both sections of the schedule.

▪ Corrective action plan on all current year findings and a summary schedule of prior audit findings. When audit findings were not corrected or only partially corrected, the summary schedule must describe the reasons for the finding’s recurrence and planned corrective action.

▪ Data Collection Form stating whether the audit was completed in accordance with the standards for the audit of non-federal entities expending federal awards. The Data Collection Form also provides information about the auditee, its federal programs, and the results of the audit.

▪ Management Letter issued by the auditor.

▪ Delaware County Supplemental Schedule and related report (Appendix U -Exhibit A).

2. Program Specific Audits Performed Under the Uniform Guidance

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

A subrecipient that expends $750,000 in federal awards in any year may elect to have a Program Specific Audit, an audit of one federal program, rather than a Single Audit, if the subrecipient expends its federal awards under only one program (CFDA No.), excluding research and development, and that federal program’s laws, regulations, or grant requirements do not require a financial statement audit of the entity.

Some federal assistance programs make available a Program Specific Audit Guide. If such a guide exists, it must be followed. A Program Specific Audit Guide provides specific guidance with respect to internal control, compliance requirements, suggested audit procedures, and audit reporting requirements. A listing of current program-specific audit guides can be found in the compliance supplement, including federal awarding agency contact information and a web site where a copy of the guide can be obtained. The auditor shall follow GAGAS/Yellow Book and the audit guide when performing a Program Specific Audit.

In those instances where a Federal Program Specific Audit Guide is available, the audit reporting package for a Program Specific Audit may be different and should be prepared in accordance with the audit guide. If a guide does not exist, the same basic responsibilities exist for the federal program as they would for an audit of a major program in a Single Audit.

The auditor must perform an audit of the financial statement(s) for the federal program in accordance with GAGAS/Yellow Book, must obtain an understanding of the subrecipient’s internal control, and must perform tests of internal control as would be required for a major program. Also, the auditor must determine whether the auditee has complied with laws, regulations, and the provision of the grant agreements that could have a direct and material effect on the program as would be required for a major program, follow-up on prior year findings, and report any current year findings.

Program Specific Audit Reporting Package Checklist (when an audit guide is not available):

The Auditee Responsibilities

• Financial statements for the federal program that include, at a minimum, a schedule of federal expenditures of federal awards for the program and notes that describe the significant accounting policies used in preparing the schedule.

• Summary schedule of prior audit findings.

• Audit findings follow-up.

• Corrective action plan.

The Auditor Responsibilities

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

• Perform an audit in accordance with GAGAS.

• Obtain an understanding of internal controls and perform tests of internal controls over the federal program.

• Perform procedures to determine that the auditee has complied with federal statutes, regulations, and the terms and conditions of federal awards that could have a direct and material effect on the federal program.

• Follow up on prior audit findings and perform procedures to assess the reasonableness of the summary schedule of prior audit findings.

• Report on audit findings.

• Issue the following reports:

(i) An opinion (or disclaimer of opinion) as to whether the financial statement(s) of the Federal program is/are presented fairly in all material respects in accordance with the stated accounting policies;

(ii) A report on internal control related to the Federal program, which must describe the scope of testing of internal control and the results of the tests;

(iii) A report on compliance which includes an opinion (or disclaimer of opinion) as to whether the auditee complied with laws, regulations, and the terms and conditions of Federal awards which could have a direct and material effect on the Federal program; and

(iv) A schedule of findings and questioned costs for the Federal program that includes a summary of the auditor’s results relative to the Federal program.

In certain instances, a Yellow Book report on compliance and on internal control over financial reporting with appropriate report modifications for a program-specific audit may be required.

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

U-III THE COUNTY’S FUNDING SOURCES

The Delaware County Department of Human Services funds its human services programs primarily by the pass-through of funding received from the Pennsylvania Department of Human Services (DHS) and the Pennsylvania Department of Drug and Alcohol (DDAP). Auditors of subrecipient organizations should become familiar with the DHS Single Audit Supplement, Pennsylvania Code Title 55, the Bureau of Drug and Alcohol Fiscal Manual and the Pennsylvania Department of Health Audit Requirements.

A. Pennsylvania Department of Human Services (DHS) Audit Guidelines

DHS requires the County to be responsible for ensuring that its subrecipients/ subcontractors are audited in accordance with the Yellow Book and, when appropriate, with the Single Audit Act and the Uniform Guidance. The County manages its subrecipient organization audits by contract.

A Single Audit or program-specific audit in accordance with the Uniform Guidance is acceptable from any entity required to have one. However, the County may require an audit in accordance with Generally Accepted Government Auditing Standards even when expenditures do not exceed the Single Audit threshold.

DHS issues an Administrative Bulletin annually for the purpose of updating and releasing its Single Audit Supplement. Independent auditors of programs funded via DHS either directly or as pass-through funds are responsible for reviewing and implementing the procedures contained in the Single Audit Supplement.

Accordingly, the County herewith passes down all applicable sections of the DHS Single Audit Supplement to its subrecipients who receive DHS funds passed through the County. DHS includes the Single Audit Supplement on the DHS website:

http://www.dhs.state.pa.us/publications/index.htm

The Single Audit Supplement contains Common Requirements representing compliance requirements applicable to all programs funded through DHS. It also provides compliance requirements specific to DHS funded programs. It specifies certain suggested audit procedures that are applicable to subrecipients of service. The Single Audit Supplement is not intended to supersede federal or Commonwealth of Pennsylvania policy, nor is it intended to serve as an all-inclusive audit manual or to supplant the auditor’s judgment concerning the audit work required. The DHS Audit Supplement also follows the Uniform Guidance regarding the determination of major programs. Activities are governed by PA Code Regulations: Title 55.

http://www.dhs.state.pa.us/publications/index.htm

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25

The Bureau of Financial Operations plans, organizes, directs, and controls financial support within the Pennsylvania Department of Human Services. These activities include the resolution of audits, providing technical support on county and subrecipient human services programs and conducting performance audits and reviews of DHS-funded programs. BFO’s Audit Resolution Section manages and reviews DHS’s subrecipient audits from counties and non-profit agencies and these audits can become the basis for any audit adjustments to the contracts and grants.

B. Pennsylvania Department of Drug and Alcohol Audit Guidelines

The Pennsylvania Department of Drug and Alcohol was formerly administered under the Department of Health. In 2012, it became a department in its own right.

The audit requirements for DDAP funded contracts are incorporated by reference to its funding requirements. DDAP’s audit requirements were last revised in July 2015. The Department has also published a Fiscal Manual, which covers the period July 2015 through June 2020.

DDAP subscribes to the federally mandated audit requirements for contracts that are federally funded. Accordingly, if total federal awards of $750,000 or more received either directly from the federal government or indirectly from a recipient of federal funds are expended during the organization’s fiscal year, an audit in accordance with the provisions of the Uniform Guidance is required. This requirement is stipulated regardless of the amount of state funds expended.

DDAP mandates performance of a financial audit made in accordance with the provisions of GAGAS for any contract if less than $750,000 of federal funds but more than $500,000 of state funds are expended during the state fiscal year (July 1 - June 30).

Unless stated otherwise in the contract, DDAP does not require an audit if:

▪ The organization expends less than $500,000 of state funds under the contract during the state fiscal year and expends less than $750,000 in federal awards received from all sources during its fiscal year; or

▪ All contract funds are received on a strictly fee-for-service basis.

Even if the recipient organization is not required to have an audit performed, it is required to maintain auditable records of federal, state, and county awards and expenditures and to provide access to its records by federal, state, and county agencies or their designees.

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25/25

APPENDIX U EXHIBIT A

SUPPLEMENTARY FINANCIAL SCHEDULES

AND AGREED-UPON PROCEDURES REPORT

Whenever Delaware County Human Services awards are passed down to subrecipient organizations, the recipient organizations are required to submit supplementary financial schedules to the County. The supplemental financial schedules should be considered an integral part of the subrecipient’s audit package. The supplemental financial schedule required under Appendix U Exhibit A identifies all revenue support received by the subrecipient organization from Delaware County Human Services and reconciles that information to the total of all revenue reported by the subrecipient organization in its audited financial statements for that period. This schedule is to be accompanied by an auditor’s report on additional information accompanying the basic financial statements.

An illustrative presentation of the format of the supplementary financial schedule report on additional information is presented below.

A. Reconciliation of Support Received from Delaware County Department of Human Services (Appendix U Exhibit A)

EXAMPLE – Report on Reconciliation of Support Received

INDEPENDENT AUDITOR’S REPORT

ON ADDITIONAL INFORMATION

To

We have audited the financial statements of as of and for the year ended June 30, , and have issued our report thereon dated , which contained (an unqualified opinion) on those financial statements. Our report was performed for the purpose of forming an opinion on the financial statements as a whole. The Reconciliation of Support Received from Delaware County Department of Human Services (Appendix U Exhibit A) is presented for purposes of additional analysis and is not a required part of the 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 financial statements. The information has been subjected to the auditing procedures applied in the audit of the financial statements and certain additional procedures, including comparing and reconciling such information directly to the underlying accounting and other re cords used to prepare the financial statements or to the financial statements themselves, and other additional procedures in accordance with auditing standards generally accepted in the United States of America. In our opinion, the information is fairly stated in all material respects in relation to the financial statements as a whole.

Auditor’s Signature

Date of report on the basic financial statements.

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25/25

APPENDIX U EXHIBIT A

(NAME OF SUBRECIPIENT ORGANIZATION)

RECONCILIATION OF SUPPORT RECEIVED FROM

YEAR ENDED JUNE 30,

Revenue recognized as support received from Delaware County (indicate by Delaware County Program):

State and Federal Local Other Total

Mental Health Intellectual and Developmental Disabilities Early Intervention Drug and Alcohol Adult and Family Services Children & Youth Services Juvenile Probation

Total

Other revenue recognized

Total revenue recognized

Note: Total revenue should be reconcilable to the audited financial statements of the subrecipient organization.

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25/25

APPENDIX U EXHIBIT B

NOTIFICATION OF SINGLE AUDIT STATUS

This is to certify that _________________ (subrecipient organization) is subject to compliance with the item marked below for the Fiscal Year Ending ____________ (Last Day of Entity Fiscal Year):

The Organization Expended $750,000 or more in federal financial assistance during the fiscal year ended __________. We understand that a copy of our Single Audit Report must be submitted to Delaware County Department of Human Services within the earlier of 30 days after completion of the audit, or nine months after the end of the fiscal year.

The Organization expended $750,000 or more in federal financial assistance on a single federal program, therefore we have elected to have a program-specific audit of the contract in lieu of a single audit. We understand that a copy of our program-specific audit must be submitted to Delaware County Department of Human Services within the earlier of 30 days after completion of the program audit, or nine months after the end of the audit period.

The Organization expended total federal financial assistance of less than

$750,000 during the fiscal year ended __________, therefore it is exempt with respect to filing a Single Audit Report for that year. We understand however, that we may be asked to provide access to the records we are required to maintain concerning such federal assistance. (Submit page 2 within nine months after the end of the fiscal year.)

The Organization is a for-profit organization and is therefore not subject to the requirements of the Uniform Guidance. (Submit page 2 within nine months after the end of the fiscal year.)

We understand that a copy of the applicable report must be submitted by the required deadline to:

Department of Human Services

Attn: Contracting Unit 4990 State Road, Suite 101 Drexel Hill, PA 19026

We further understand that our failure to submit any applicable report(s) by the required deadline may result in the suspension of payments or prevent the award of future grants.

Signature of Authorized Official Date

Title of Authorized Official

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25/25

APPENDIX U EXHIBIT B

AUDIT STATUS NOTIFICATION LETTER

(Required for Subrecipient Organizations claiming exemption from audit submission requirements)

Please complete the following information, sign after the statement below, and fax it to 610-713-2326. The form is due to the Delaware County Department of Human Services within nine months after the end of the subrecipient organization’s fiscal year.

Subrecipient Organization:

Address:

Fiscal Year Ended (month/date/year):

Agency Contact Person (Name, Title, Phone #):

I certify that the Subrecipient Organization identified above expended less than $750,000 in federal awards from all funding sources for the fiscal year ended ___________or is a for-profit organization. I also certify that (CHECK ONE):

The Subrecipient organization’s financial statement audit did not include any disclosures related to current or prior years that could negatively impact Delaware County-funded programs (including, but not limited to, fraud, going concern uncertainties, financial statement misstatements and violations of contract and grant provisions), or

A financial statement audit has not been conducted for the above-mentioned fiscal year.

Signature

Print Name/Title (Financial Director or Designee)

Date

Rev. 3/00; 6/00; 1/04; 3/05; 5/11; 4/13; 3/14; 11/14; 2/15; 6/15; 11/15; 6/18; 6/19; 7/21, 10/24, 7/25/25

APPENDIX U EXHIBIT C

SUBRECIPIENT REQUEST FOR EXTENSION

RELATED TO SUBMISSION OF AUDITED FINANCIAL STATEMENTS

Subrecipient Organization:

Address:

Fiscal Year Ended:

Name of Subrecipient Organization Contact Person:

Phone #: Fax #:

Email:

Subrecipient requests an extension of the due date for report submission until .

Explanation and Justification:

Signature and Title Date

Submit this request by mail, or fax to:

Mail: Department of Human Services

Attn: Contracting Unit 4990 State Road, Suite 101 Drexel Hill, PA 19026

Fax: Attention: Human Services Accountant 610-713-2326

FOR USE BY DELAWARE COUNTY

Request Approved Request Not Approved

By:

Delaware County Department of Human Services Date

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