Institutional Federal Compliance Report 2021

STATE OF NEW YORK

Schedule of Findings and Questioned Costs

Year ended March 31, 2018

The Office was unable to demonstrate that it had a system of internal controls or policies and procedures in place to ensure it had performed sufficient subrecipient monitoring activities over the local districts at a level of precision necessary to ensure that the federal funds expended by the local districts were spent in compliance with Federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals were achieved. This would include monitoring subrecipients to ensure that they complied with federal requirements related to allowability of costs incurred, that participant eligibility was determined in accordance with federal regulations, that participants were placed with eligible providers, and that the source of matching funds utilized by the local districts was appropriate. In addition, the Office was not able to demonstrate that it has written policies and procedures to describe their subrecipient monitoring policy is over the local district offices and was not able to demonstrate that it has sufficient means to determine whether or not the local district offices have complied with statutes, regulations, and the terms and conditions of its Federal awards for the Adoption Assistance program. The Office’s internal control monitoring process consisted solely of a specific review over the accuracy of subrecipient eligibility determinations for cases that are considered to have been delinked as directed by the Fostering Connections to Success and Increasing Adoptions Act of 2008 (P.L. 110-361) enacted in October of 2008. Although management performed this review process, we noted that the review was required by the federal government in order to test the accuracy of the annually reported savings achieved as a result of the delinking process and was not a review process that the Office had implemented as part of its system of internal controls to monitor the accuracy of eligibility determinations performed by the local district offices. Additionally, the Office identified in March 2018, through its Audit Quality Control (AQC) Unit, an ad hoc independent Adoption Subsidy Eligibility Review for claims processed was conducted for the period June 2017 through December 2017 as its internal control monitoring process. Although the ad hoc audit was performed, no other audits or monitoring actives were identified or performed. In addition to the monitoring activities described above, the Office relies on the local districts annual single audit reports for its fiscal monitoring. For 15 of the 25 subrecipient single audit reports selected for testwork, Adoption Assistance was not determined to be a major program and the Office did not have any other verifiable evidence that it had monitored these subrecipients for compliance through its own internal subrecipient monitoring activities. Cause The condition found was primarily due to the Office not having monitoring controls in place over the Adoption Assistance program to ensure the State’s compliance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Additionally, the Office’s policies and procedures over fiscal subrecipient monitoring activities were limited to obtaining and reviewing subrecipients’ single audit reports without consideration of the results of the single audit reports. Possible Asserted Effect The lack of written policies and procedures and failure to perform sufficient monitoring activities over subawards to subrecipients could result in the use of federal funding not being in compliance with Federal statutes, regulations, and the terms and conditions of the subaward.

Statistical Sampling

36

(Continued)