Institutional Federal Compliance Report 2021

STATE OF NEW YORK

Schedule of Findings and Questioned Costs

Year ended March 31, 2018

(4) Ensuring that any shared costs or matching funds provided by third party in-kind contributions meet the following requirements outlined 45 CFR 75.306(b), including having procedures in place to monitor that the subrecipient’s match is:

a) Are verifiable from the non-Federal entity’s records;

b) Are not included as contributions for any other Federal award;

c) Are necessary and reasonable for accomplishment of project or program objectives;

d) Are allowable under subpart E of 45 CFR 75;

e) Are not paid by the Federal Government under another Federal award, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs;

f) Are provided for in the approved budget when required by the HHS awarding agency; and

g) Conform to other provisions of this part, as applicable.

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

(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, per 45 CFR 75.303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal 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, 2018, the Office of Children and Families (the Office) passed through $217,836,487 under the Adoption Assistance federal program (CFDA number 93.659) to local districts (or subrecipients) to provide programmatic services under the Foster Care program. As part of the funding arrangement, the local districts are responsible for determining participant eligibility for services, establishing rates to be paid on behalf of eligible participants, and ensuring that eligible participants are placed with a provider that has met the appropriate licensing requirements. In addition, the local districts pay 100% of the costs incurred for these services and periodically submit requests for reimbursement to the Office for services rendered. The Office reimburses the local districts for only the federal share of the costs incurred, and the remaining costs incurred by the local districts are used by the Office to meet its required state match.

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