Institutional Federal Compliance Report 2021

STATE OF NEW YORK

Schedule of Findings and Questioned Costs

March 31, 2019

(2) Performing on-site reviews of the subrecipient’s program operations;

(3) Arranging for agreed-upon-procedures engagements as described in 45 CFR 75.425.

Lastly, 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 During the fiscal year ended March 31, 2019, the Office of Children and Families (the Office) passed through $270,599,858 under the Social Services Block Grant (SSBG) federal program (CFDA No. 93.667) to local districts (subrecipients) to provide programmatic services under the SSBG program. As part of the funding arrangement, the local districts are responsible for the administration of the federal program, including ensuring that costs incurred under the federal program are in compliance with federal regulations. During the fiscal year ended March 31, 2019, while the Office performed its annual risk assessment process over its subrecipients, the Office had not yet fully implemented its system of internal controls or policies and procedures related to its subrecipient monitoring activities over the local districts to ensure the federal funds spent by the local districts were spent in compliance with federal statutes, regulations, the terms and conditions of the subaward, and that subaward performance goals were achieved. This would include ensuring that costs incurred by the local district were for allowable services and to ensure that the local district’s use of funds transferred into the SSBG program from the TANF program are used only to provide services to individuals who meet the applicable federal poverty standards necessary. Cause The condition found was primarily due to the Office currently being in the process of completing an analysis of its current subrecipient monitoring activities performed by the budget, finance, and program units of the Office. Gaps in subrecipeint monitoring in compliance with 45 CFR 75.352(d) and 45 CFR 75.352(e) identified by the Office are being reviewed to be remediated. As the Office is in the middle of its implementation process for the period under audit, the Office’s policies and procedures over subrecipient monitoring activities were primarily limited to obtaining and reviewing subrecipients’ single audit reports without consideration of the results of the single audit reports. Possible Asserted Effect Failure to perform subrecipient monitoring activities in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e) could result in the Office not being able to timely identify subrecipient’s noncompliance with federal statutes, regulations, and the terms and conditions of the subaward, and it prevents the Office’s ability to timely seek corrective action from the subrecipient. Questioned Costs Cannot be determined Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample.

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