Institutional Federal Compliance Report 2021

STATE OF NEW YORK

Schedule of Findings and Questioned Costs

March 31, 2019

Federal Agency:

United States Department of Health and Human Services

Federal Program:

Social Services Block Grant (93.667)

Federal Award Numbers:

1701NYTANF, 1701NYSOSR 1801NYTANF, and 1801NYSOSR

Federal Award Years:

2017 and 2018

State Agency:

Office of Children and Family Services

Reference:

2019-020

Criteria Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards , section 75.352(d) states all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.

Pass-through entity monitoring of the subrecipient must include:

(1) Reviewing financial and performance reports required by the pass-through entity.

(2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. Additionally, 45 CFR 75.203(c) requires the nonfederal entity to evaluate and monitor the nonfederal entity’s compliance with statutes, regulations and the terms of the Federal awards. The nonfederal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the federal award (45 CFR 75.400(b)). Each state must expend and account for the federal award in accordance with state laws and procedures for expending the state’s own funds. Such monitoring activities should ensure: (2) Monitoring compliance to ensure that the use all of the amount transferred in from Temporary Assistance for Needy Families (TANF) (CFDA 93.558) is only for programs and services to children or their families whose income is less than 200% of the official poverty guideline as revised annually by HHS (42 U.S. Code Section 604, Use of grants (42 USC 604) Section 604(d)(3)(A) and 42 US Code Section 9902 (42 USC 9902), Definitions Section 9902(2)). Further, 45 CFR 75.352(e) states, depending upon the pass-through entity’s assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Expended federal funds for allowable costs in accordance with federal regulations.

(1) Providing subrecipients with training and technical assistance on program-related matters; and

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