Institutional Federal Compliance Report 2021

STATE OF NEW YORK

Schedule of Findings and Questioned Costs

March 31, 2019

(3) Whether the subrecipient has new personnel or new or substantially changed systems; and

(4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).

Lastly, 2 CFR 200.303(a) states the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During the fiscal year ended March 31, 2019, the Office of Temporary and Disability Assistance (the Office) passed through $349,154,784 under the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program federal program (CFDA No. 10.561) to local district offices as presented on the Schedule of Expenditures of Federal Awards (SEFA) as reimbursements for claims submitted through the Automated Claiming System (ACS). The Office did not evaluate each subrecipient’s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward as prescribed in 2 CFR 200.331(b) to determine appropriate subrecipient monitoring described in 2 CFR 200.331(e). Instead, for determining the appropriate subrecipient monitoring to be performed over subrecipients, the Office selected subrecipients to monitor based on a rotation basis considering the last time the subrecipient was monitored. In one instance, the Office considered the number of households within each district to select subrecipients to monitor. Cause The condition found was due to the Office’s policies and procedures not designed to ensure that in determining subrecipient monitoring activities described in 2 CFR 200.331(e) the Office consider the subrecipient’s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subawards as prescribed in 2 CFR 200.331(b). The Office’s policies and procedures are based on a rotational basis. Possible Asserted Effect Failure to perform and document a risk assessment over each district to determine appropriate subrecipient monitoring procedures may result in procedures that are inadequate or inappropriate to detect noncompliance with Federal statues, regulations, and the terms and conditions of the subawards. Questioned Costs None Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend the Office review its policies and procedures including internal controls to ensure each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subawards are considered as part of determining subrecipient monitoring activities to be performed as defined in 2 CFR 200.331(e).

34

(Continued)