10 Program, Fiscal Monitoring, and Audit, 2605(b)(10) - Assurance 10

10.1. How do you ensure good fiscal accounting and tracking of funds? Application Monitoring Procedures: All applications approved at the local agency level and forwarded for payment will be submitted for all computerized eligibility checks before payment is made. The Agency monitors and tracks LIHEAP funds in several different ways to ensure fiscal accounting and tracking of LIHEAP funds. The following is an overview of our procedures. Application Monitoring Procedures: All applications approved at the local agency level and forwarded for payment will be submitted for all computerized eligibility checks before payment is made. The computerized checking process includes: a. Check for duplicate Social Security Numbers in existing DHS systems; b. Verify Social Security Numbers, Social Security benefit amounts, and death information through data exchange with the Social Security Administration; c. Verify Supplemental Security Income payments through the State Data Exchange (SDX); d. Check for criminal information on all household members through data exchange with the Commonwealth Judicial Information System; e. Check on family size and income; f. Check for Cash payment above $1,000; g. Check for Crisis payment below $25; h. Check for total Crisis payment above $1000; and i. Determination of payment; • All fields must contain acceptable established elements (characters or numbers); • All required fields must be completed. Agency Monitoring Procedures: 1. The first step of the agency’s monitoring strategy begins at the County Assistance Office (CAO). •CAO staff members, involved in determining LIHEAP eligibility are mandated to participate in weekly Knowledge Reinforcement Sessions. Each LIHEAP Knowledge Reinforcement Session (LKRS) is 6 to 7 slides in length with 5 questions which must be answered correctly in order to complete the session. The sessions reinforce policy and procedural issues that are error prone, based on monitoring findings. •CAO supervisors complete reviews of LIHEAP applications using a review tool designed to guide the reviewer and accumulate meaningful statewide results. CAO supervisors and managers as well as staff in the Bureau of Program Evaluation (BPE) monitor the results of the supervisor reviews to identify trends and implement corrective actions. •Electronic conferences are held initially weekly, then biweekly or monthly, to provide the counties with real-time system, policy and operational updates that impact the LIHEAP workflow. The calls also provide a means for CAOs to get answers to questions or resolutions to issues encountered. •Both the CAOs and the monitoring staff communicate with the Policy team through the LIHEAP Training and Policy mailbox to address questions and issues on a daily basis as they arise. The shared responses ensure a uniform interpretation and consistent application of regulations throughout the agency. 2. For the second step of the agency’s monitoring strategy BPE coordinates the annual LIHEAP monitoring reviews of CAOs and Crisis Contractors based on a two-year schedule for the CAOs. Additional CAOs are reviewed, as needed, based on extenuating circumstances or the recommendation of the Bureau of Operations. LIHEAP reviews are completed by a field-based monitoring team. Monitoring activities include: • CAO and Crisis Contractor administration of LIHEAP activities including eligibility, benefit determination and corrective action through LIHEAP application reviews and on-site visits. • Over 2,600 LIHEAP applications are randomly selected through data mining techniques and random samples and reviewed annually. • Independent audit on-site reviews to reduce potential bias in the monitoring process. • Investigation and appropriate and timely escalation of information that suggests potential misuse, misrepresentation, or abuse. • Issuance of preliminary and updated performance reports to CAOs to provide relevant data on accuracy and the composition of findings at both the county level and state level. • Development of corrective action plans based on the findings from the monitoring team. The plans are implemented by OIM and monitored for compliance by BPE. • Development and implementation of year-round program changes to increase program accuracy and integrity through collaboration with other bureaus. Examples include working with Staff Development in the development of LIHEAP training for the next LIHEAP season to incorporate situations found to be prone to error. Additional monitoring procedures include the following: Bureau of Financial Operations provides OIM with technical assistance and conducts performance audits of specific CAOs and crisis contractors, as needed, to resolve systemic problems. •Controls are built into the PROMISe™ system which vendors use to bill for LIHEAP Crisis claims to ensure the vendors bill for valid Crisis requests and are paid the amount they are authorized to receive. •The vendor unit assists heating vendors by answering questions, helping to file Crisis claims in PROMISe™, and reviewing vendor transactions. •Executive Staff from the Bureaus of Policy, Program Support, and Program Evaluation meet on a bi-weekly basis to discuss LIHEAP and all issues and topics pertinent to the program. •CAO supervisors review a list of direct pay authorizations every Friday to ensure that the budgets are being authorized correctly and accurately. •The Comptroller’s Office reviews the weekly LIHEAP vouchers for any questionable payments and works with OIM to ensure all payments issued to households are correct. •The field monitoring team conducts reviews of LIHEAP vendors to ensure compliance with the DHS LIHEAP Vendor Agreement, focusing on the following areas: -Compliance with DHS Information Requirements -Proper and Accurate completion of the Vendor Agreement -Timeliness of Crisis delivery -Application of LIHEAP benefit in accordance with vendor agreement and DHS Policy -Proper handling of LIHEAP refunds -Record Retention 10.1a Provide your definitions of the following: Obligation Pennsylvania's financial obligations (incurred and anticipated) refers to funds committed for a specific use related to administering the LIHEAP program. Examples of obligations include the issuance of benefits to LIHEAP clients, purchase orders related to LIHEAP, procurement of IT services to support the LIHEAP program, costs related to the administering of the weatherization program, cost related to the monitoring the LIHEAP program, and among other related LIHEAP obligations Expenditures Expenditures refers to the payment of funds for actual expenditures incurred to administer the LIHEAP program. Expenditure timeframe Pennsylvania's expenditures falls within two time frames. There is the state fiscal year (SFY) which runs from July 1, 202X to the following June 202X. Also, there is the federal fiscal year (FFY) which run from October 1, 202X to the following September 202X. PA's LIHEAP program for a given FFY follows the grant service period for the grant that was awarded to PA. Administrative costs Pennsylvania's administrative costs include all personnel, operating, and indirect costs that incurred to administer the LIHEAP program. IT planning costs are excluded from administrative costs and are included as program costs as per the PA's LIHEAP state plan. Audit Process 10.2. Is your LIHEAP program audited annually under the Single Audit Act and OMB Circular A - 133? Yes No 10.2a - if yes, describe your auditor selection process. Single audits are completed through PA's Office of the Auditor General 10.3. Describe any audit findings of the grant recipient (i.e. State/Tribe/Territory) rising to the level of material weakness or reportable condition cited in the single audits, inspector general reviews, or other government agency reviews from the most recently audited fiscal year. No Findings Finding Type Brief Summary Resolved? Action Taken 1 10.4. Audits of Local Administering Agencies What types of annual audit requirements do you have in place for local administering agencies/district offices? Select all that apply. Local agencies/district offices are required to have an annual audit in compliance with Single Audit Act and OMB Circular A-133 Local agencies/district offices are required to have an annual audit (other than A-133) Local agencies/district offices' A-133 or other independent audits are reviewed by Grant recipient as part of compliance process. Grant recipient conducts fiscal and program monitoring of local agencies/district offices Local agencies and district offices are required to have an annual audit in compliance with Single Audit Act and OMB Circular A-133 Compliance Monitoring 10.5. Describe your monitoring process for compliance at each level below. Check all that apply. Grant recipients have a policy in place for appropriate separation of duties and internal controls. Internal program review Departmental oversight Secondary review of invoices and payments Other program review mechanisms are in place. Describe: Application Monitoring Procedures: All applications approved at the local agency level and forwarded for payment will be submitted for all computerized eligibility checks before payment is made. The Agency monitors and tracks LIHEAP funds in several different ways to ensure fiscal accounting and tracking of LIHEAP funds. The following is an overview of our procedures. Application Monitoring Procedures: All applications approved at the local agency level and forwarded for payment will be submitted for all computerized eligibility checks before payment is made. The computerized checking process includes: a. Check for duplicate Social Security Numbers in existing DHS systems; b. Verify Social Security Numbers, Social Security benefit amounts, and death information through data exchange with the Social Security Administration; c. Verify Supplemental Security Income payments through the State Data Exchange (SDX); d. Check for criminal information on all household members through data exchange with the Commonwealth Judicial Information System; e. Check on family size and income; f. Check for Cash payment above $1,000; g. Check for Crisis payment below $25; h. Check for total Crisis payment above $1000; and i. Determination of payment; • All fields must contain acceptable established elements (characters or numbers); • All required fields must be completed. Agency Monitoring Procedures: 1. The first step of the agency’s monitoring strategy begins at the County Assistance Office (CAO). •CAO staff members, involved in determining LIHEAP eligibility are mandated to participate in weekly Knowledge Reinforcement Sessions. Each LIHEAP Knowledge Reinforcement Session (LKRS) is 6 to 7 slides in length with 5 questions which must be answered correctly in order to complete the session. The sessions reinforce policy and procedural issues that are error prone, based on monitoring findings. •CAO supervisors complete reviews of LIHEAP applications using a review tool designed to guide the reviewer and accumulate meaningful statewide results. CAO supervisors and managers as well as staff in the Bureau of Program Evaluation (BPE) monitor the results of the supervisor reviews to identify trends and implement corrective actions. •Electronic conferences are held initially weekly, then biweekly or monthly, to provide the counties with real-time system, policy and operational updates that impact the LIHEAP workflow. The calls also provide a means for CAOs to get answers to questions or resolutions to issues encountered. •Both the CAOs and the monitoring staff communicate with the Policy team through the LIHEAP Training and Policy mailbox to address questions and issues on a daily basis as they arise. The shared responses ensure a uniform interpretation and consistent application of regulations throughout the agency. 2. For the second step of the agency’s monitoring strategy BPE coordinates the annual LIHEAP monitoring reviews of CAOs and Crisis Contractors based on a two-year schedule for the CAOs. Additional CAOs are reviewed, as needed, based on extenuating circumstances or the recommendation of the Bureau of Operations. LIHEAP reviews are completed by a field-based monitoring team. Monitoring activities include: • CAO and Crisis Contractor administration of LIHEAP activities including eligibility, benefit determination and corrective action through LIHEAP application reviews and on-site visits. • Over 2,600 LIHEAP applications are randomly selected through data mining techniques and random samples and reviewed annually. • Independent audit on-site reviews to reduce potential bias in the monitoring process. • Investigation and appropriate and timely escalation of information that suggests potential misuse, misrepresentation, or abuse. • Issuance of preliminary and updated performance reports to CAOs to provide relevant data on accuracy and the composition of findings at both the county level and state level. • Development of corrective action plans based on the findings from the monitoring team. The plans are implemented by OIM and monitored for compliance by BPE. • Development and implementation of year-round program changes to increase program accuracy and integrity through collaboration with other bureaus. Examples include working with Staff Development in the development of LIHEAP training for the next LIHEAP season to incorporate situations found to be prone to error. Additional monitoring procedures include the following: Bureau of Financial Operations provides OIM with technical assistance and conducts performance audits of specific CAOs and crisis contractors, as needed, to resolve systemic problems. •Controls are built into the PROMISe™ system which vendors use to bill for LIHEAP Crisis claims to ensure the vendors bill for valid Crisis requests and are paid the amount they are authorized to receive. •The vendor unit assists heating vendors by answering questions, helping to file Crisis claims in PROMISe™, and reviewing vendor transactions. •Executive Staff from the Bureaus of Policy, Program Support, and Program Evaluation meet on a bi-weekly basis to discuss LIHEAP and all issues and topics pertinent to the program. •CAO supervisors review a list of direct pay authorizations every Friday to ensure that the budgets are being authorized correctly and accurately. •The Comptroller’s Office reviews the weekly LIHEAP vouchers for any questionable payments and works with OIM to ensure all payments issued to households are correct. •The field monitoring team conducts reviews of LIHEAP vendors to ensure compliance with the DHS LIHEAP Vendor Agreement, focusing on the following areas: -Compliance with DHS Information Requirements -Proper and Accurate completion of the Vendor Agreement -Timeliness of Crisis delivery -Application of LIHEAP benefit in accordance with vendor agreement and DHS Policy -Proper handling of LIHEAP refunds -Record Retention Local Administering Agencies/District Offices: On - site evaluation Annual program review Monitoring through central database Desk reviews Client File Testing/Sampling Other program review mechanisms are in place. Describe: •Per the current visit plan, medium, large, and ad-hoc counties are visited in addition to the crisis contractors. •Agencies are visited in accordance with the established schedule, prior year results and OIM concerns. •Rushmore Case Review Database is used for LIHEAP Monitoring by both the monitoring team and the CAOs. •Per the current visit plan, small processing agencies are monitored by desk review. •The provided database is used by both the CAOs and the LIHEAP monitoring team. •Weekly knowledge reinforcement sessions are in place for all staff processing LIHEAP applications. 10.6 Explain, or attach a copy of your local agency monitoring schedule and protocol. For the agency’s monitoring strategy, BPE coordinates the annual LIHEAP monitoring reviews of CAOs and Crisis Contractors based on a two-year schedule for the CAOs. Additional CAOs are reviewed, as needed, based on extenuating circumstances or the recommendation of the Bureau of Operations. LIHEAP reviews are completed by a field-based monitoring team. Monitoring activities include: • CAO and Crisis Contractor administration of LIHEAP activities including eligibility, benefit determination and corrective action through LIHEAP application reviews and on-site visits. • Over 2,500 LIHEAP applications are randomly selected through data mining techniques and random samples and reviewed annually. • Independent audit on-site reviews to reduce potential bias in the monitoring process. • Investigation and appropriate and timely escalation of information that suggests potential misuse, misrepresentation, or abuse. • Issuance of preliminary and updated performance reports to CAOs to provide relevant data on accuracy and the composition of findings at both the county level and state level. • Development of corrective action plans based on the findings from the monitoring team. The plans are implemented by OIM and monitored for compliance by BPE. • Development and implementation of year-round program changes to increase program accuracy and integrity through collaboration with other bureaus. Examples include working with Staff Development in the development of LIHEAP training for the next LIHEAP season to incorporate situations found to be prone to error. 10.7. Describe how you select local agencies for monitoring reviews. Attach a risk assessment if subrecipients are utilized. Site Visits: All agencies, aside from the largest processing locations are reviewed in a two year rotation. The largest processing locations are reviewed yearly. Size is determined by prior year volume. Some additional CAOs are reviewed, as needed, based on extenuating circumstances such as a change in processing style or prior year results Desk Reviews: Small processing locations, defined as those processing less than 5000 applications yearly, are monitored by desk review. 10.8. How often is each local agency monitored? Please attach a monitoring schedule if one has been developed. Biannually 10.9. How many local agencies are currently on corrective action plans? 10 If any of the above questions require further explanation or clarification that could not be made in the fields provided, attach a document with said explanation here.