Institutional Federal Compliance Report 2021

STATE OF NEW YORK

Schedule of Findings and Questioned Costs

Year ended March 31, 2018

New York State Governmental Accountability, Audit, and Internal Control Act of 1987 highlighted the need for agency management to promote good internal controls and accountability in government. Article 45, Internal Control Responsibilities of State Agencies, Section 951 Executive Internal control responsibilities states the head of each state agency shall a) establish and maintain for the agency guidelines for a system of internal control that are in accordance with this article and internal control standards; b) Establish and maintain for the agency a system of internal control and a program of internal control review. The program of internal control review shall be designed to identify internal control weaknesses, identify actions that are needed to correct these weaknesses, monitor the implementation of necessary corrective actions and periodically assess the adequacy of the agency’s ongoing internal control; c) make available to each officer and employee of the agency a clear and concise statement of the generally applicable management policies and standards with which the officer or employee of such agency shall be expected to comply. Such statement shall emphasize the importance of effective internal control to the agency and the responsibility of each officer and employee for effective internal control; d) designate an internal control officer, who shall report to the head of the agency, to implement and review the internal control responsibilities established pursuant to this section; e) implement education and training efforts to ensure that officers and employees within such agency have achieved adequate awareness and understanding of internal control standards and, as appropriate, evaluation techniques; and f) periodically evaluate the need for an internal audit function. Condition The Office of Alcoholism and Substance Abuse Services (OASAS) did not drawdown federal funds for reimbursement ensuring minimum time elapsed in accordance with 31 CFR 205, as required through 45 CFR 96.12. During our testwork, for 18 of 65 vouchers sampled, we noted OASAS was reimbursed from the Department of Health and Human Services more than 3 days in advance of the State’s disbursement of funds to the subrecipients. For 21 of the 65 vouchers sampled, we noted OASAS did not follow the State’s Guide to Fiscal Operations Section IX.5, Federal Billing & Invoicing policy. Cause The condition found is due to OASAS not following the State’s federal billing policies and procedures. The State’s Guide to Fiscal Operations Section IX.5, Federal Billing & Invoicing , identifies the State’s policy that the Office must follow in order to minimize time elapse between the drawdown of the Federal funds and the disbursement. Specifically, the guide states the following “Since billing is initiated once an expenditure occurs, it is critical that agencies do not enter AP voucher payment dates more than two days in advance of the current date. Any date beyond this two-day limit may result in federal funds being drawn down before the voucher payments are actually incurred”. It was identified that for 21 of the 65 sampled voucher disbursements, OASAS management entered AP voucher payment dates more than two days in advance of the current date. Possible Asserted Effect Failure to follow the State’s Fiscal Operations Guide may result in OASAS not minimizing the time elapse of drawdowns and the disbursement for Federal program purposes and not being in compliance with Federal statutes, regulations, and the terms and conditions of the subaward.

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