Institutional Federal Compliance Report 2021

STATE OF NEW YORK

Schedule of Findings and Questioned Costs

March 31, 2019

(xii) Identification of whether the award is R&D; and

(xiii) Indirect cost rate for the Federal award (including if the de minimis rate is charged per section 75.414).

Additionally, 45 CFR 75.303(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 The Office of Children and Family Services (the Office) passes through funds to local district social services offices (subrecipients) of the State of New York, which have a funding relationship under the program established by the State of New York Laws of 1997. Quarterly, the Federal Government provides a notice of grant awards to the Office for the federal program. For the fiscal year ended March 31, 2019, the Office had communicated the prescribed award identification information as outlined in 45 CFR 75.352 for allocations awarded under the federal grant award numbers 1701NYCCDF and 1801NYCCDF (which include TANF transfers to CCDF Discretionary funds). However the Office had not communicated the prescribed award information for federal grant award 1601NYCCDF and G1601NYTANF. Specifically, communication of the following award identification information was not provided to the subrecipients for these awards:

1) Federal Award Identification Number (FAIN)

2) Federal Award Date

3) Subaward Period of performance Start and End Date

4) Federal award project description

5) Identification of whether the award is research and development (R&D).

Cause The condition found is primarily due to the Office updating its policies and procedures related to communication of award identification information to subrecipients for all new allocations made subsequent to April 1, 2018. The Office did not provide any communications for award identification information as identified above for awards allocated prior to March 31, 2018, which accounted for approximately $281 million of the $914 million or 31% of the funds passed through to subrecipients during the fiscal year ended March 31, 2019. Possible Asserted Effect Failure to adequately communicate changes in award identification information could result in the subrecipients not being able to adequately track and report the subawards received resulting in errors being reported on the subrecipient’s annual schedule of expenditures of federal awards and result in noncompliance with required terms and conditions of the federal award.

54

(Continued)