Institutional Federal Compliance Report 2021

STATE OF NEW YORK

Schedule of Findings and Questioned Costs

Year ended March 31, 2018

Federal Agency:

U.S. Department of Education

Federal Program:

School Improvement Grants (84.377)

Federal Award Numbers:

S377A140033, S377A150033, and S377A160033

Federal Award Years:

2014, 2015, and 2016

State Agency:

State Education Department

Reference:

2018-018

Criteria Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements , section 200.331(b) states all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraph (e) of this section, which may include consideration of such factors as:

(1) The subrecipient’s prior experience with the same or similar subawards;

(2) The results of previous audits, including whether or not the subrecipient receives a Single Audit in accordance with Subpart F – Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program;

(3) Whether the subrecipient has new personnel or new or substantially changed systems; and

(4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).

Additionally, 2 CFR 200.303(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 New York State Education Department (the Department) passed through $57,582,895 of federal funding to School Improvement Grants 1003(g) eligible school buildings (buildings) local education agencies (LEAs). The Department did not have a risk assessment policy and process designed at a precision level to include each LEA’s building’s individual evaluation of risk of noncompliance with Federal regulations for the purpose of determining appropriate subrecipient monitoring procedures, as defined in 2 CFR 200.331(b).

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