Audit 1558

Internal Control Over Compliance Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 CFR Section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards incompliance with federal statutes, regulations, and the terms and conditions of the federal awards. Statement of Condition: Adequate internal controls over compliance are not established. Specifically, there is a lack of segregation of duties. Statement of Cause: Segregation of these duties has not been achieved due to the small size of the Association and current procedures. Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Section 200.303. There is a reasonable possibility that noncompliance would not be prevented or detected and corrected in a timely basis. Questioned Cost: None Repeat Finding: No Recommendation: We recommend a review of policies and procedures to update and determine where changes may provide opportunities for segregation of duties.Views of responsible officials and planned corrective actions: Invoices received by NYSSA pertaining to Federal Grants will be given a supervisory designee for review (current procedure) and logged on a spreadsheet prior to being delivered to the Finance Office for processing. [New procedure implemented] Invoices to be paid will be entered into Quickbooks financial software by the Finance Manager (current procedure). Checks for payment to grant vendors follow the same procedures and processes as listed in 2022-001 above, numbers 1 and 2 [New procedure implemented] Perspective Information: Management did have a process to identify and track costs under the grant through the use of separate general ledger accounts for purposes of claiming reimbursement.

Procurement – Suspension and Debarment Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs. Statement of Condition: During our testing for procurement compliance, it was determined that the New York State Sheriffs’ Association, Inc. did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs. Questioned Cost: None Statement of Cause: Management was not aware of the requirement to review an entity’s status. Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Association could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs. Repeat Finding: No Recommendation: We recommend management review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs. Views of the Responsible Officials and Planned Corrective Actions: Vendors will be reviewed and documented that they are not debarred, suspended, or otherwise excluded from participation in federal award programs by use of the System for Award Management (SAM), the Official U.S. Government system. [New procedure implemented] Perspective Information: There was one vendor in excess of the $25,000 threshold which was reviewed to determine eligibility for participation noting they are not debarred, suspended, or otherwise excluded from participation in federal award programs.

Internal Control Over Compliance Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 CFR Section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards incompliance with federal statutes, regulations, and the terms and conditions of the federal awards. Statement of Condition: Adequate internal controls over compliance are not established. Specifically, there is a lack of segregation of duties. Statement of Cause: Segregation of these duties has not been achieved due to the small size of the Association and current procedures. Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Section 200.303. There is a reasonable possibility that noncompliance would not be prevented or detected and corrected in a timely basis. Questioned Cost: None Repeat Finding: No Recommendation: We recommend a review of policies and procedures to update and determine where changes may provide opportunities for segregation of duties.Views of responsible officials and planned corrective actions: Invoices received by NYSSA pertaining to Federal Grants will be given a supervisory designee for review (current procedure) and logged on a spreadsheet prior to being delivered to the Finance Office for processing. [New procedure implemented] Invoices to be paid will be entered into Quickbooks financial software by the Finance Manager (current procedure). Checks for payment to grant vendors follow the same procedures and processes as listed in 2022-001 above, numbers 1 and 2 [New procedure implemented] Perspective Information: Management did have a process to identify and track costs under the grant through the use of separate general ledger accounts for purposes of claiming reimbursement.

Procurement – Suspension and Debarment Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs. Statement of Condition: During our testing for procurement compliance, it was determined that the New York State Sheriffs’ Association, Inc. did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs. Questioned Cost: None Statement of Cause: Management was not aware of the requirement to review an entity’s status. Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Association could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs. Repeat Finding: No Recommendation: We recommend management review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs. Views of the Responsible Officials and Planned Corrective Actions: Vendors will be reviewed and documented that they are not debarred, suspended, or otherwise excluded from participation in federal award programs by use of the System for Award Management (SAM), the Official U.S. Government system. [New procedure implemented] Perspective Information: There was one vendor in excess of the $25,000 threshold which was reviewed to determine eligibility for participation noting they are not debarred, suspended, or otherwise excluded from participation in federal award programs.