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:

2018-019

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(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.

(3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by section 200.521 Management decision.

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).

The Department did not have sufficient documentation to demonstrate that its subrecipient monitoring policies and procedures were in accordance with Federal regulations.

For 18 of 20 “receivership” buildings selected for testwork, the Department’s monitoring activities did not include documented fiscal monitoring activities to ensure the federal awards were used for authorized purposes in compliance with federal statues, regulations, and the terms and conditions of the subaward.

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