Institutional Federal Compliance Report 2021

STATE OF NEW YORK

Schedule of Findings and Questioned Costs

March 31, 2019

appropriate amount of benefits that the participant is eligible to receive. These services are paid for directly by the local district offices, and subsequently, a request for reimbursement is sent to the Office for reimbursement.

For the year ended March 31, 2019, the Office implemented subrecipient monitoring reviews that were performed over 10 local districts selected based upon the Office’s annual risk assessment. The Office’s monitoring review focused on the local district’s eligibility determination process. These reviews consisted of a selection of participants from each district and reviewing their case files to ensure it contained documentation to support an eligibility determination. However, the Office’s subrecipient monitoring reviews did not include procedures to review the amount paid on behalf of the participant was allowable. Specifically, the Office did not perform monitoring procedures to ensure that the local district had correctly coded participants within the Office’s Benefits Issuance and Control System (BICS) (which triggers the value of the services to be paid on behalf of the participant was applied to children (participants) to support that the cost reimbursed to the district office was allowable and accurate. Cause The condition found was primarily due to the Office currently being in the process of completing a gap analysis of their current subrecipient monitoring activities performed by the budget, finance, and program units of the Office. Gaps identified by the Office in subrecipient monitoring in compliance with 45 CFR 75.352(d) and 45 CFR 75.352(e) are being reviewed to be remediated. Currently, implemented monitoring under the Office’s corrective action plan did not consider whether the codes utilized by the local districts for reimbursement was allowable and accurate (i.e. paid to an eligible child who was correctly coded in BICS so that he correct rate was applied to payments). Possible Asserted Effect Failure to perform subrecipient monitoring activities in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e) to ensure costs reimbursed to local districts for participants are accurate and supported by documentation could result in the Office incurring costs that are not allowable with federal statutes, regulations, and the terms and conditions of the subaward. Questioned Costs Cannot be determined Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was included in the 2018 Single Audit Report as finding number 2018-006 on pages 30–33. Recommendation We recommend the Office continue to perform the Office’s gap analysis of its subrecipient monitoring procedures to ensure adequate procedures are performed over subrecipients in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). This would include ensuring that monitoring activities are performed that would detect and identify errors in the coding of children that could result in unallowable costs being reimbursed to subrecipients.

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