New York City Department of Human Resources Administration (?HRA?) Finding #: 2022-003 Funding Year(s): 1/22/2021 ? 1/21/2023 Emergency Solutions Grants Program (FAL #14.231) Contract Number: E20MC360104 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Special Tests and Provisions - Compliance and Internal Control (Control Deficiency) Criteria: Per 24 CFR Section 576.203(a)(2), within 180 days after the date that HUD signs the grant agreement with the metropolitan city, urban county, or territory, the recipient must obligate all the grant amount, except the amount for its administrative costs. Total grant award obligations are required to be reported to HUD through the Integrated Disbursement and Information System (?IDIS?), using a PR-91 ESG Financial Summary Report. Condition/Context: HUD signed HRA?s Emergency Solutions Grants Program (?ESG?) grant agreement #E20MC360104 on January 21, 2021, and as such the total grant amount was required to be obligated by July 20, 2021. Per the PR-91 ESG Financial Summary Report submitted by HRA through IDIS on October 12, 2021, $202,222 of the total $14,657,037 award had not been obligated by the required due date. Cause/Effect: While HRA has policies and procedures in place regarding the review and approval of the PR-91 ESG Financial Report, this process did not include a comprehensive review to ensure that HRA obligated all grant funding within the required timeframe prior to submission. As such, this resulted in HRA?s non-compliance. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that HRA strengthen their internal controls over the special tests and provisions process to ensure all grant amounts are obligated within the required 180-day timeframe, and that the obligation is properly reviewed prior to the PR-91 ESG Financial Report submission through IDIS.
New York City Department of Housing Preservation and Development (?HPD?) Finding #: 2022-008 Funding Year(s): 12/18/2018 - 09/01/2027 HOME Investment Partnership Program (FAL #14.239) Contract Number: M-18-MC-36-0204; M-19-MC-36-0204 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Special Tests and Provisions Compliance Criteria: During the period of affordability for which the non-Federal entity must maintain subsidized housing for the HOME-assisted rental housing program, the participating jurisdiction must perform on-site inspections at least once every three (3) years to determine compliance with Housing Quality Standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Furthermore, for any failed inspections, the appropriate repairs to bring the building into compliance must be performed timely. Condition/Context: HPD has policies and procedures in place to identify units which require Housing Quality Standards inspections and performs inspections of these units to help ensure that any needed repairs are completed within the stipulated timeframe. For those units in need of repairs, HPD?s policy requires that repairs be completed within 90 days after the initial inspection and supported by a Certificate of Repairs form. In accordance with the individual agreements between HPD and the Sponsors of the respective housing projects, the Sponsors are responsible for maintaining compliance with the Housing Quality Standards, and HPD inspections are conducted to help ensure the respective Sponsors are maintaining compliance. Additionally, there are clauses within the individual agreements between HPD and the Sponsor which allows HPD to exercise remedies such as restricting funding to Sponsors who do not comply with the Housing Quality Standards. Our procedures identified six (6) instances from a sample of forty (40), where the necessary repairs were not made by the Sponsors within the stipulated 90-day period. Cause/Effect: While HPD conducts monitoring procedures to help ensure that Housing Quality Standards are maintained and, when necessary, related repairs are performed by the respective Sponsors within the prescribed 90-day timeframe, we noted that the necessary repairs were not consistently completed within the stipulated timeframe or not completed at all. Incomplete and/or repairs that do not meet the stipulated completion timeframe could result in Sponsored projects not maintaining the appropriate quality of living conditions for tenants and, therefore, not comply with the applicable Housing Quality Standards. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: While contract provisions between HPD and the respective Sponsors permit HPD to exercise remedies, which may include the withdrawal of future funding, HPD did not elect to exercise any such remedies. Accordingly, we recommend that HPD continue to strengthen its monitoring of Sponsors in connection with housing quality inspections and determine, on a case-by-case basis, whether to exercise appropriate remedies in accordance with contract provisions or consider documenting its rationale for not doing so. Finding #: 2022-008 Funding Year(s): 12/18/2018 - 09/01/2027 HOME Investment Partnership Program (FAL #14.239) Contract Number: M-18-MC-36-0204; M-19-MC-36-0204 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Special Tests and Provisions Compliance Criteria: During the period of affordability for which the non-Federal entity must maintain subsidized housing for the HOME-assisted rental housing program, the participating jurisdiction must perform on-site inspections at least once every three (3) years to determine compliance with Housing Quality Standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Furthermore, for any failed inspections, the appropriate repairs to bring the building into compliance must be performed timely. Condition/Context: HPD has policies and procedures in place to identify units which require Housing Quality Standards inspections and performs inspections of these units to help ensure that any needed repairs are completed within the stipulated timeframe. For those units in need of repairs, HPD?s policy requires that repairs be completed within 90 days after the initial inspection and supported by a Certificate of Repairs form. In accordance with the individual agreements between HPD and the Sponsors of the respective housing projects, the Sponsors are responsible for maintaining compliance with the Housing Quality Standards, and HPD inspections are conducted to help ensure the respective Sponsors are maintaining compliance. Additionally, there are clauses within the individual agreements between HPD and the Sponsor which allows HPD to exercise remedies such as restricting funding to Sponsors who do not comply with the Housing Quality Standards. Our procedures identified six (6) instances from a sample of forty (40), where the necessary repairs were not made by the Sponsors within the stipulated 90-day period. Cause/Effect: While HPD conducts monitoring procedures to help ensure that Housing Quality Standards are maintained and, when necessary, related repairs are performed by the respective Sponsors within the prescribed 90-day timeframe, we noted that the necessary repairs were not consistently completed within the stipulated timeframe or not completed at all. Incomplete and/or repairs that do not meet the stipulated completion timeframe could result in Sponsored projects not maintaining the appropriate quality of living conditions for tenants and, therefore, not comply with the applicable Housing Quality Standards. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: While contract provisions between HPD and the respective Sponsors permit HPD to exercise remedies, which may include the withdrawal of future funding, HPD did not elect to exercise any such remedies. Accordingly, we recommend that HPD continue to strengthen its monitoring of Sponsors in connection with housing quality inspections and determine, on a case-by-case basis, whether to exercise appropriate remedies in accordance with contract provisions or consider documenting its rationale for not doing so.
New York City Human Resources Administration (?HRA?) Finding #: 2022-011 Funding Year(s): 10/19/2017-9/1/2025 HOME Investment Partnerships Program (FAL #14.239) Contract Numbers: M-17-MC-36-0204 Federal Agency: U.S. Department of Housing and Urban Development (?HUD?) Type of Finding: Special Tests and Provisions Material Non-Compliance and Internal Control (Material Weakness) Criteria: Per 24 CFR sections 92.504(d) all housing occupied by tenants receiving HOME tenant-based rental assistance must meet the standards in 24 CFR 982.401 or the successor requirements as established by HUD. The participating jurisdiction must perform annual on-site inspections of rental housing occupied by tenants receiving HOME-assisted TBRA to determine compliance with these standards. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: HRA has policies and procedures in place to identify the units which require Housing Quality Standards inspections and performs inspections of these units to help ensure that any needed repairs are completed within the stipulated timeframe. For those units in need of repairs, HRA policy requires that repairs be completed within 30 days after the initial inspection and supported by a Certificate of Repairs form. In accordance with the individual agreements between HRA and the landlords of the units receiving Tenant Based Rental Assistance, the landlords are responsible for maintaining compliance with the Housing Quality Standards, and HRA inspections are conducted to help ensure the respective landlords are maintaining compliance. Additionally, there are clauses within the individual agreements between HRA and the landlord which allows HRA to exercise remedies such as restricting funding to landlords who do not comply with the Housing Quality Standards. We selected a non-statistical sample of forty (40) units inspected during FY2022 and found that twenty-one (21) of the selections had errors as follows: ? For eleven (11) of twenty-one (21), HRA was not able to provide a copy of the certification of repairs issued by the landlord noting when the repair was made to correct the issues identified in the failed inspection. ? For five (5) of twenty-one (21), the necessary repairs were not made by the landlord within the stipulated 30-day period. For all five (5) of these instances, HRA forwarded a Notification of Failure describing the findings and a reminder that the landlord had 30 days to submit a Certification of Repairs form. ? For two (2) of twenty-one (21), HRA was not able to provide a copy of the Notification of Failure submitted to the landlord to notify them of the failed inspection, reminding the landlord that they had 30 days to submit a Certification of Repairs form. ? For five (5) of twenty-one (21), HRA was not able to provide support noting that the initial inspection failure was dismissed and repairs were no longer necessary. ? For one (1) of twenty-one (21), HRA was not able to provide a copy of the inspection reports completed by a certified inspector. Cause/Effect: While HRA conducts monitoring procedures to help ensure that Housing Quality Standards are maintained and, when necessary, related repairs are performed by the respective landlords within the prescribed 30-day timeframe, we noted the following: ? A comprehensive review and internal control process was not consistently performed and documented to ensure the appropriate evidence was maintained to support the units were compliant with the applicable Housing Quality Standards. ? Necessary repairs were not completed at all, or evidence of the repairs was unable to be provided. Incomplete and/or repairs that do not meet the stipulated completion timeframe could result in landlords not maintaining the appropriate quality of living conditions for tenants and, therefore, not comply with the applicable Housing Quality Standards. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that HRA strengthen its monitoring of landlords in connection with housing quality inspections and determine, on a case-by-case basis, whether to exercise appropriate remedies in accordance with contract provisions or consider documenting its rationale for not doing so. Additionally, we recommend that HRA strengthen their internal controls governing the Housing Quality Standards process, including ensuring that appropriate documentation is maintained to ensure compliance with the Housing Quality Standards.
New York City Human Resources Administration (?HRA?) Finding #: 2022-012 Funding Year(s): 10/19/2017-9/1/2025 HOME Investment Partnerships Program (FAL #14.239) Contract Numbers: M-17-MC-36-0204 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Allowable Costs and Eligibility - Material Noncompliance and Internal Control (Material Weakness) Criteria: In accordance with 23 CFR sections 1.9, 172.11(a), 420.113(a), and 630.106(a), costs incurred under federal awards are considered allowable and reimbursable when such costs are deemed necessary and reasonable; incurred subsequent to the date of authorization to proceed and in accordance with the conditions contained in the project agreement and the plans specifications; and, not included as costs used to meet cost sharing or matching requirements, among other things. As stipulated by 24 CFR ?92.209, tenant-based rental assistance (?TBRA?) may only be provided to very low- and low-income families. The participating jurisdiction must determine that the family is very low- or low-income before the assistance is provided. During the period of assistance, the participating jurisdiction must annually determine that the family continues to be low-income. Also, the maximum monthly assistance that a participating jurisdiction may pay to, or on behalf of, a family may not exceed the difference between a rent standard for the unit size established by the participating jurisdiction and 30% of the family's monthly adjusted income. Additionally, the participating jurisdiction must disapprove a lease if the rent is not reasonable, based on rents that are charged for comparable unassisted rental units. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: The New York City Human Resources Administration (?HRA?) utilizes the Current System to assess beneficiaries? eligibility to receive tenant based rental assistance through the HOME Investment Partnerships Program (?HOME?). To assess eligibility, HRA program staff obtain income supporting documentation to determine if the household met the low-income requirement and to calculate the maximum subsidy amount to be paid by HRA. Additionally, a rent reasonableness valuation is performed which compares the current beneficiary?s rent to other rents charged for comparable units to ensure reasonableness. Upon the completion of the eligibility determination by an HRA staff member, a designated program supervisor reviews and approves the eligibility determination, subsidy amount, and tenant share within Current. We selected a non-statistical sample of forty (40) rental assistance payments made on behalf of tenants during fiscal 2022 and found that twenty-two (22) of the selections had errors as follows: ? For thirteen (13) of the twenty-two (22) selections, HRA was not able to provide documentation to support the participant?s annual income. ? For nine (9) of the twenty-two (22) selections , HRA was also not able to provide the HOME TBRA Certification Information Form, which is utilized to calculate and support HRA?s share of the monthly rent to be paid on behalf of the participant. ? For fourteen (14) of the twenty-two (22) selections, HRA was not able to provide documentation to support that a rent reasonableness assessment was performed. ? For four (4) of the twenty-two (22) selections, it was noted that HRA?s share of monthly rent was determined to be $1,729, $1,778, $1,544, and $235, respectively. However, due to manual input errors, the amounts actually paid on behalf of these tenants were $1,780, $1,762, $1,534, and $176, respectively. ? For one (1) of the twenty-two (22) selections, HRA was unable to provide documentation to support that the eligibility determination and the related calculation was properly reviewed and approved by a supervisor. Total TBRA payments charged to the grant were $5,533,841 and total TBRA benefits subjected to testing were $54,915. Cause/Effect: While HRA has a process in place to assess the eligibility of tenants and calculate the monthly TBRA payments on behalf of those tenants to ensure allowability of costs incurred, a comprehensive review was not consistently performed and documented to ensure the appropriate evidence and related approvals were maintained to support those determinations and calculations. As a result, costs were incurred on behalf of certain tenants that may not have met the eligibility requirements, or an incorrect amount may have been paid on their behalf. Questioned Costs: Known questioned costs totaled $18,240. Identification as a Repeat Finding: This finding is similar to finding #2021-011, included on pages 249 and 250 of the Fiscal 2021 Single Audit report. Recommendation: We recommend that HRA strengthen their internal controls governing the eligibility determination process, including creating a comprehensive review checklist to ensure each tenant meets every eligibility requirement and HRA?s portion of the TBRA payments are properly calculated, and that appropriate supervisory review and approval is consistently performed and documented prior to processing payments and charging costs to the grant.
New York City Department of Health and Mental Hygiene ("DOHMH") Finding #: 2022-007 Funding Year(s): 4/1/2021 ? 3/31/2022 Housing Opportunities for Persons with AIDS (HOPWA) (FAL #14.241) Contract Number: NYH21F002 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Reporting ? Material Noncompliance and Internal Control (Material Weakness) Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (?FFATA?) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252 (the ?Transparency Act?) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The award information must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition/Context: During fiscal year 2022, DOHMH awarded a total of four (4) sub-awards that exceeded $30,000 to three (3) separate subrecipients. We noted that none of these sub-awards were reported in the FSRS system. Cause/Effect: While DOHMH has processes in place to ensure the SAM (System for Award Management) registrations for grant awards are registered under the correct entity, during fiscal 2022, due to management oversite, the SAM registration for this program was not properly processed. The HOPWA agreement was registered under The City of New York, rather than DOHMH, which resulted in DOHMH?s inability to submit information to the FSRS system for FFATA reporting, and therefore, they did not submit any of the required reports related to their fiscal 2022 HOPWA awards. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DOHMH strengthen their processes and internal controls over reporting to ensure all FFATA reports are submitted within the required timeframe, including ensuring that the SAM registration process is completed properly under the correct City agency.
New York City Human Resources Administration (?HRA?) Finding #: 2022-013 Funding Year(s): 7/1/2021 ? 6/30/2022 Housing Opportunities for Persons with AIDS (HOPWA) (FAL #14.241) Contract Numbers: NYH21F002; NYH22F002 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Eligibility - Material Noncompliance and Internal Control (Material Weakness) Criteria: As stipulated by 24 CFR Section 574.3, to be eligible to receive HOPWA funded benefits, a participant must be diagnosed with an acquired immunodeficiency syndrome or related diseases and be a low-income individual, as determined by the Secretary of Housing and Urban Development. HRA utilizes the household income of eligible participants to calculate the monthly rental assistance payment to be made on their behalf. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: We noted that certain rental assistance payments were calculated using an incorrect household income amount. From a non-statistical sample of forty (40) rental assistance payments made on behalf of tenants during FY2022 that were selected for testing, we identified five (5) exceptions, as follows: ? For one (1) of the selections, HRA utilized household income that was higher than their actual income, which caused HRA?s monthly rental assistance payment for the selected period to be less than it should have been. ? For four (4) of the selections, HRA utilized household income that was lower than their actual income, which caused HRA?s monthly rental assistance payment for the selected period to be higher than it should have been. The excess payments for these selections totaled $88. Total rental assistance payments charged to the grant were $20,870,225 and total HOPWA rent subsidies subjected to testing were $51,878. Cause/Effect: While HRA has a process in place to assess the eligibility of tenants and calculate the monthly rental assistance payments to be made on their behalf, they did not consistently ensure that the household income utilized to calculate the monthly rental assistance payment was accurate. As a result, an incorrect monthly rental assistance amount was paid on behalf of certain tenants. Questioned Costs: Known questioned costs totaled $88. Identification as a Repeat Finding: This finding is similar to finding #2021-012, included on pages 251 and 252 of the Fiscal 2021 Single Audit report. Recommendation: We recommend that HRA strengthen their internal controls governing the eligibility process, including ensuring the household income utilized to calculate the monthly rental assistance amount is accurate prior to processing payments and charging costs to the grant.
New York City Human Resources Administration (?HRA?) Finding #: 2022-014 Funding Year(s): 4/1/2021 ? 3/31/2023 Housing Opportunities for Persons with Aids (FAL #14.241) Contract Numbers: NYH21F002; NYH22F002 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Special Tests and Provisions - Compliance and Internal Control (Significant Deficiency) Criteria: All housing that is assisted under specific HOPWA activities per CFR sections 574.300(b) (3), (4), (5), and (8) must meet specific applicable Housing Quality Standards (?HQS?) as outlined in 24 CFR section 574.310(b) determined by on-site inspections. On May 22, 2020 HUD waived the physical inspection requirement for acquisition, rehabilitation, conversion, lease, or repair; new construction of single room occupancy dwellings and community residences; project or tenant-based rental assistance; or operating costs through March 31, 2022, so long as grantees or project sponsors can visually inspect the unit using technology, such as video streaming, to ensure the unit meets HQS before any assistance is provided; and the grantee or project sponsor has written policies that require physical reinspection of the units not previously physically inspected by June 30, 2022. This waiver applied to units where initial eligibility to receive rental assistance was determined during the fiscal year. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: Prior to providing rental assistance to landlords, HRA conducts on-site inspections to ensure each unit meets all applicable Housing Quality Standards. During each inspection, a HRA Case Manager would assign a Quality Assurance (?QA? Inspector to complete an inspection checklist, which outlines each standard and documents if the unit passed or failed each requirement. The QA Inspector would sign off on the report and provide it to the landlord, noting if any repairs are required. In addition to the initial annual inspection, if there were any adverse findings identified, the Case Manager would conduct follow-up visits for that unit until the findings were remediated. If an on-site inspection was unable to be conducted prior to March 31, 2022, a virtual inspection was performed by a QA Inspector via video call. Similarly, an inspection checklist would be completed for the virtual inspection and the QA Inspector would sign off on the checklist and provide a copy to the landlord. Any repairs needed would be followed up on by the Case Manager until all corrections were implemented. After March 31, 2022, HRA would then ensure a physical inspection was conducted prior to June 30, 2022. In accordance with the individual agreements between HRA and the landlords of the units receiving the rental assistance, the landlords are responsible for maintaining compliance with the HQS, and the HRA inspections are conducted to help ensure the respective landlords are maintaining compliance. We selected a non-statistical sample of nineteen (19) units that were subject to an initial inspection by HRA during fiscal 2022 and noted that for three (3) selections, HRA was unable to provide a copy of the inspection checklist that was completed by the QA Inspector prior to assistance being provided for the unit. Cause/Effect: While HRA conducts monitoring procedures to help ensure that Housing Quality Standards are maintained and, when necessary, related repairs are performed by the respective landlords within the prescribed 30-day timeframe, we noted that the inspection checklists used to document such procedures were not consistently maintained. If controls aren?t in place to ensure each unit is properly inspected in accordance with the guidelines and HRA?s policies, there is a risk that some units may not meet the appropriate quality of living conditions for tenants and, therefore, not comply with the applicable Housing Quality Standards. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that HRA strengthen their internal controls governing the Housing Quality Standards inspection process, including that appropriate documentation is maintained for each inspection performed, to ensure compliance with the requirements is met for each unit under their supervision.
New York City Department of Investigation (?DOI?) Finding #: 2022-009 Funding Year(s): 7/1/2021 ? 6/30/2022 Equitable Sharing Program (FAL #16.922) Contract Numbers: N/A Federal Agency: U.S. Department of Justice Type of Finding: Equipment and Real Property Management - Compliance and Internal Control (Significant Deficiency) Criteria: In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Additionally, as stipulated by 2 CFR section 200.313(d)(2), a physical inventory of property and equipment acquired under a federal award must be taken, and the results reconciled with the property records, at least once every two years. Also, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: From a non-statistical sample of forty (40) pieces of equipment subjected to testing, we identified the following errors: ? Seven (7) pieces of equipment were disposed of in fiscal 2019 but the disposition data was not properly updated and the equipment was not removed from the active inventory listing. ? For seven (7) pieces of equipment, DOI was unable to provide evidence that a physical inventory and reconciliation back to property records was performed and documented within the required two-year timeframe. ? For all forty (40) pieces of equipment, DOI was unable to provide supporting documentation that a review and approval of the inventory had taken place at the time the inventory was conducted. Cause/Effect: While DOI had certain procedures in place to monitor their equipment purchased with Federal funding, such procedures were not adequate to ensure that each aspect of the equipment and real property management compliance requirements were performed and documented within the requirement timeframe, which resulted in the findings noted above. Without the appropriate internal controls and monitoring procedures in place, federally funded equipment could be inaccurately recorded on inventory records and not discovered and corrected timely, inventory could be misplaced, misappropriated, or otherwise disposed of outside of the requirements of the federal guidelines Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend that DOI strengthen controls over the inventory process to ensure dispositions of equipment are updated in the equipment records, inventories performed are reconciled back to equipment records, biennial inventory counts are consistently performed over all equipment within the required timeframe, and that the review and approval of each inventory performed is appropriately documented.
New York City Police Department (?NYPD?) Finding #: 2022-010 Funding Year(s): 7/1/2021 ? 6/30/2022 Equitable Sharing Program (FAL #16.922) Contract Numbers: N/A Federal Agency: U.S. Department of Justice Type of Finding: Equipment and Real Property Management - Compliance and Internal Control (Significant Deficiency) Criteria: As stipulated by 2 CFR section 200.313(d)(2), a physical inventory of property and equipment acquired under a federal award must be taken, and the results reconciled with the property records, at least once every two (2) years. Also, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: From a non-statistical sample of four (4) pieces of equipment subjected to testing, we identified that NYPD was unable to provide supporting documentation that a review and approval of the inventory had taken place at the time the inventory was conducted for all items selected for testing. Cause/Effect: While NYPD had certain procedures in place to monitor their equipment purchased with Federal funding, such procedures were not adequate to ensure that each aspect of the equipment and real property management compliance requirements were documented, which resulted in the finding noted above. Without the appropriate internal controls and monitoring procedures in place, federally funded equipment could be inaccurately recorded on inventory records and not discovered and corrected timely, inventory could be misplaced, misappropriated, or otherwise disposed of outside of the requirements of the federal guidelines Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend that NYPD strengthen controls over the inventory process to ensure that the review and approval of each inventory performed is appropriately documented.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department of Health and Mental Hygiene ("DOHMH") Finding #: 2022-006 Funding Year(s): 7/1/2021 ? 6/30/2022 Public Health Emergency Preparedness (FAL #93.069) Contract Numbers: NU90TP922035 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Level of Effort ? Compliance and Internal Control (Control Deficiency) Criteria: The 2 CFR section 200.514(d)(3) states that for those federal programs not covered in the compliance supplement the auditor must use the types of compliance requirements contained and described in Part 3 of the compliance supplement as guidance for identifying the types of compliance requirements to test, and determine the requirements governing the federal program by reviewing the provisions of the federal award or pass-through agency sub-award, and the laws and regulations referred in such awards. As stipulated by Public Health Solutions ("PHS"), the pass-through agency, in its sub-award agreement, Awardees must maintain non-federal expenditures for health-care preparedness and public health security at a level that is not less than the average level of such non-federal expenditures maintained by the awardee for the preceding two-year (2) period. Condition/Context: We noted that total Public Health Emergency Preparedness (?PHEP?) non-federal expenditures for the current year were below the average level of non-federal expenditures for the preceding two-year (2) period. Non-federal expenditures to the program for FY2022 totaled $2,091,743; whereas the average non-federal expenditures for FY2020 & FY2021 totaled $2,482,528. Cause/Effect: While DOHMH has a process in place to track and calculate non-federal expenditures for health-care preparedness and public health security, they did not consistently ensure progressive non-federal expenditures were adequately meeting the appropriate level of effort requirements. As a result, total programmatic non-federal expenditures for the year totaled less than the level of effort requirement. Questioned Costs: None identified Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend that DOHMH strengthen their internal controls regarding compliance surrounding the level of effort requirements, including the appropriate tracking of progressive non-federal expenditures to ensure programmatic level of effort requirements are met. Finding #: 2022-006 Funding Year(s): 7/1/2021 ? 6/30/2022 Public Health Emergency Preparedness (FAL #93.069) Contract Numbers: NU90TP922035 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Level of Effort ? Compliance and Internal Control (Control Deficiency) Criteria: The 2 CFR section 200.514(d)(3) states that for those federal programs not covered in the compliance supplement the auditor must use the types of compliance requirements contained and described in Part 3 of the compliance supplement as guidance for identifying the types of compliance requirements to test, and determine the requirements governing the federal program by reviewing the provisions of the federal award or pass-through agency sub-award, and the laws and regulations referred in such awards. As stipulated by Public Health Solutions ("PHS"), the pass-through agency, in its sub-award agreement, Awardees must maintain non-federal expenditures for health-care preparedness and public health security at a level that is not less than the average level of such non-federal expenditures maintained by the awardee for the preceding two-year (2) period. Condition/Context: We noted that total Public Health Emergency Preparedness (?PHEP?) non-federal expenditures for the current year were below the average level of non-federal expenditures for the preceding two-year (2) period. Non-federal expenditures to the program for FY2022 totaled $2,091,743; whereas the average non-federal expenditures for FY2020 & FY2021 totaled $2,482,528. Cause/Effect: While DOHMH has a process in place to track and calculate non-federal expenditures for health-care preparedness and public health security, they did not consistently ensure progressive non-federal expenditures were adequately meeting the appropriate level of effort requirements. As a result, total programmatic non-federal expenditures for the year totaled less than the level of effort requirement. Questioned Costs: None identified Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend that DOHMH strengthen their internal controls regarding compliance surrounding the level of effort requirements, including the appropriate tracking of progressive non-federal expenditures to ensure programmatic level of effort requirements are met.
New York City Human Resources Administration (?HRA?) and Administration for Children?s Services (?ACS?) Finding #: 2022-015 Funding Year(s): 10/1/2020-9/30/2022 Child Care and Development Block Grant (FAL #93.575) Contract Numbers: 21-OCFS-LCM-19, 22-OCFS-LCM-08 Pass-Through Agency: NYS Office of Children and Family Services Federal Agency: U.S. Department of Health and Human Services Type of Finding: Allowable Costs and Eligibility - Material Noncompliance and Internal Control (Material Weakness) Criteria: In accordance with 23 CFR sections 1.9, 172.11(a), 420.113(a), and 630.106(a), costs incurred under federal awards are considered allowable and reimbursable when such costs are deemed necessary and reasonable; incurred subsequent to the date of authorization to proceed and in accordance with the conditions contained in the project agreement and the plans specifications; and, not included as costs used to meet cost sharing or matching requirements, among other things. As stipulated by the 45 CFR Part 98 Subpart C, to be eligible for services under the Child Care and Development Block Grant (?CCDBG?), a child shall (1) be under the age of thirteen (13) years of age or be under the age of nineteen (19) and physically or mentally incapable of caring for himself or herself; (2) Reside with a family whose income does not exceed 85 percent of the State's median income (SMI) and whose family assets do not exceed $1,000,000; and (3) reside with a parent or parents who are working or attending a job training or educational program; or receive, or need to receive, protective services. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: We selected a non-statistical sample of sixty-five (65) individuals who received services under CCDBG during FY2022 and found that four (4) of the individuals tested had errors as follows: ? Two (2) of the individuals tested from HRA and one (1) of the individuals tested from ACS not meet some or all of the eligibility criteria as stipulated in 45 CFR Part 98 Subpart C ? For one (1) of the individuals, ACS was not able to provide documentation to support that the individual met all the eligibility criteria as stipulated in 45 CFR Part 98 Subpart C Total CCDBG Benefits charged to the grant were $276,786,114 and total CCDBG benefits subjected to testing were $48,752. Cause/Effect: While HRA and ACS have a process in place to assess the eligibility of children, a comprehensive review was not consistently performed and documented to ensure the appropriate evidence and related approvals were maintained to support those determinations. As a result, costs were incurred on behalf of certain children that did not meet all of the eligibility requirements. Questioned Costs: Known questioned costs of $2,419. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that HRA and ACS strengthen their internal controls governing the eligibility requirements, including implementing a review checklist to ensure the child meets every eligibility requirement per 45 CFR Part 98 Subpart C during the eligibility determination process.
New York City Department of Health and Mental Hygiene ("DOHMH") Finding #: 2022-004 Funding Year(s): 8/1/2020 ? 7/31/2025 HIV Prevention Activities ? Health Department Based (FAL #93.940) Contract Number: 20NU62PS924626 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Reporting - Compliance and Internal Control (Control Deficiency) Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (?FFATA?) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The award information must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition/Context: During fiscal year 2022, HIV Prevention Activities awarded a total of two (2) sub-awards that exceeded $30,000 to one (1) subrecipient. Refer to the table below for results of our testing. Cause/Effect: While DOHMH has established policies and procedures to ensure that the required reports are accurately completed and submitted on a timely basis, we noted oversight on the timely reporting for the subawards. This resulted in DOHMH missing the filing window and failing to submit its subawards in the FSRS system within the stipulated reporting period, no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DOHMH strengthen their internal controls over the reporting process to ensure all FFATA reports are submitted within the required timeframe.
New York City Department of Health and Mental Hygiene (?DOHMH?) Finding #: 2022-005 Funding Year(s): 8/1/2020 - 12/31/2022 HIV Prevention Activities ? Health Department Based (FAL #93.940) Contract Numbers: 5 NU62PS924575-04-00; 5 NU62PS924575-05-00; 1NU62PS924626-01-00; 6NU62PS924626-02-01 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Subrecipient Monitoring - Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(d) stipulate that pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Condition/Context: During fiscal 2022, DOHMH passed through federal funding to one subrecipient. We selected this subrecipient for testing and noted that DOHMH did not perform any of the required monitoring procedures in accordance with 2 CFR 200.332(d). Cause/Effect: While DOHMH has established procedures to comply with certain aspects of the subrecipient monitoring compliance requirements, such procedures did not include performing on-site reviews or similar alternate procedures that would allow DOHMH to properly oversee and evaluate the subrecipients? compliance with the requirements of the subaward. Without proper monitoring procedures, DOHMH may not have the appropriate amount of information to ensure the subrecipient is being used in accordance with Federal guidelines and the terms of the subaward. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DOHMH create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including performing appropriate monitoring procedures to ensure each subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves the performance goals of the subaward.
Finding #: 2022-002 Funding Year(s): 7/1/2021-6/30/2022 Port Security Grant Program (FAL #97.056) Contract Number: EMW-2015-PU-APP-00314, EMW-2017-PU-00122 Federal Agency: U.S. Department of Homeland Security Type of Finding: Equipment and Real Property Management - Compliance and Internal Control (Control Deficiency) Criteria: As stipulated by 2 CFR sections 200.313(d)(2), a physical inventory of property and equipment acquired under a federal award must be taken, and the results reconciled with the property records, at least once every two years. Condition/Context: The New York City Police Department (?NYPD?) utilizes the City?s Grants Tracking System (?GTS?), a citywide web-based inventory program, designed to standardize the tracking of federally funded equipment. Further, NYPD Command-designated grants coordinators are responsible for monitoring the equipment and updating the inventory on a periodic basis in accordance with federal guidelines. The NYPD Grants Unit periodically generates an inventory listing from GTS that includes the biennial inventory count due date for each item and distributes it to the assigned NYPD Command designated grant coordinators to ensure the inventory count is conducted timely and in accordance with federal requirements. After the completion of biennial inventory count, the NYPD Command-designated grants coordinators update the inventory count information to GTS. From a haphazard sample of twenty (20) pieces of equipment subjected to testing, we identified three (3) items where the NYPD Command-designated grants coordinators were unable to support that a physical inventory count was conducted within the required two-year period as of June 30, 2022. Cause/Effect: During 2021, the Grants Tracking System was upgraded and the most recent inventory entry and the original acquisition information were migrated to the new system. However, inventory entries performed between acquisition and the most recent inventory entry were not migrated. As per the Office of Management and Budget (OMB), the citywide GTS is the record for all grant-related inventory information. The NYPD does not maintain a separate inventory tracking mechanism. As a result, NYPD could not provide documentation that they complied with 2 CFR sections 200.313(d)(2) as of year-end for three (3) pieces of equipment selected. Inventory counts that are not completed within the required timeframe could result in federally funded equipment being inaccurately recorded on the inventory records and not discovered and corrected timely. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-003 included on pages 232 through 233 of the Fiscal 2021 Single Audit report. Recommendation: We recommend that NYPD strengthen controls over the inventory process to ensure biennial inventory counts for all equipment are consistently performed and documented within the required timeframe, and that such documentation is properly maintained.
New York City Department of Human Resources Administration (?HRA?) Finding #: 2022-003 Funding Year(s): 1/22/2021 ? 1/21/2023 Emergency Solutions Grants Program (FAL #14.231) Contract Number: E20MC360104 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Special Tests and Provisions - Compliance and Internal Control (Control Deficiency) Criteria: Per 24 CFR Section 576.203(a)(2), within 180 days after the date that HUD signs the grant agreement with the metropolitan city, urban county, or territory, the recipient must obligate all the grant amount, except the amount for its administrative costs. Total grant award obligations are required to be reported to HUD through the Integrated Disbursement and Information System (?IDIS?), using a PR-91 ESG Financial Summary Report. Condition/Context: HUD signed HRA?s Emergency Solutions Grants Program (?ESG?) grant agreement #E20MC360104 on January 21, 2021, and as such the total grant amount was required to be obligated by July 20, 2021. Per the PR-91 ESG Financial Summary Report submitted by HRA through IDIS on October 12, 2021, $202,222 of the total $14,657,037 award had not been obligated by the required due date. Cause/Effect: While HRA has policies and procedures in place regarding the review and approval of the PR-91 ESG Financial Report, this process did not include a comprehensive review to ensure that HRA obligated all grant funding within the required timeframe prior to submission. As such, this resulted in HRA?s non-compliance. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that HRA strengthen their internal controls over the special tests and provisions process to ensure all grant amounts are obligated within the required 180-day timeframe, and that the obligation is properly reviewed prior to the PR-91 ESG Financial Report submission through IDIS.
New York City Department of Housing Preservation and Development (?HPD?) Finding #: 2022-008 Funding Year(s): 12/18/2018 - 09/01/2027 HOME Investment Partnership Program (FAL #14.239) Contract Number: M-18-MC-36-0204; M-19-MC-36-0204 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Special Tests and Provisions Compliance Criteria: During the period of affordability for which the non-Federal entity must maintain subsidized housing for the HOME-assisted rental housing program, the participating jurisdiction must perform on-site inspections at least once every three (3) years to determine compliance with Housing Quality Standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Furthermore, for any failed inspections, the appropriate repairs to bring the building into compliance must be performed timely. Condition/Context: HPD has policies and procedures in place to identify units which require Housing Quality Standards inspections and performs inspections of these units to help ensure that any needed repairs are completed within the stipulated timeframe. For those units in need of repairs, HPD?s policy requires that repairs be completed within 90 days after the initial inspection and supported by a Certificate of Repairs form. In accordance with the individual agreements between HPD and the Sponsors of the respective housing projects, the Sponsors are responsible for maintaining compliance with the Housing Quality Standards, and HPD inspections are conducted to help ensure the respective Sponsors are maintaining compliance. Additionally, there are clauses within the individual agreements between HPD and the Sponsor which allows HPD to exercise remedies such as restricting funding to Sponsors who do not comply with the Housing Quality Standards. Our procedures identified six (6) instances from a sample of forty (40), where the necessary repairs were not made by the Sponsors within the stipulated 90-day period. Cause/Effect: While HPD conducts monitoring procedures to help ensure that Housing Quality Standards are maintained and, when necessary, related repairs are performed by the respective Sponsors within the prescribed 90-day timeframe, we noted that the necessary repairs were not consistently completed within the stipulated timeframe or not completed at all. Incomplete and/or repairs that do not meet the stipulated completion timeframe could result in Sponsored projects not maintaining the appropriate quality of living conditions for tenants and, therefore, not comply with the applicable Housing Quality Standards. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: While contract provisions between HPD and the respective Sponsors permit HPD to exercise remedies, which may include the withdrawal of future funding, HPD did not elect to exercise any such remedies. Accordingly, we recommend that HPD continue to strengthen its monitoring of Sponsors in connection with housing quality inspections and determine, on a case-by-case basis, whether to exercise appropriate remedies in accordance with contract provisions or consider documenting its rationale for not doing so. Finding #: 2022-008 Funding Year(s): 12/18/2018 - 09/01/2027 HOME Investment Partnership Program (FAL #14.239) Contract Number: M-18-MC-36-0204; M-19-MC-36-0204 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Special Tests and Provisions Compliance Criteria: During the period of affordability for which the non-Federal entity must maintain subsidized housing for the HOME-assisted rental housing program, the participating jurisdiction must perform on-site inspections at least once every three (3) years to determine compliance with Housing Quality Standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Furthermore, for any failed inspections, the appropriate repairs to bring the building into compliance must be performed timely. Condition/Context: HPD has policies and procedures in place to identify units which require Housing Quality Standards inspections and performs inspections of these units to help ensure that any needed repairs are completed within the stipulated timeframe. For those units in need of repairs, HPD?s policy requires that repairs be completed within 90 days after the initial inspection and supported by a Certificate of Repairs form. In accordance with the individual agreements between HPD and the Sponsors of the respective housing projects, the Sponsors are responsible for maintaining compliance with the Housing Quality Standards, and HPD inspections are conducted to help ensure the respective Sponsors are maintaining compliance. Additionally, there are clauses within the individual agreements between HPD and the Sponsor which allows HPD to exercise remedies such as restricting funding to Sponsors who do not comply with the Housing Quality Standards. Our procedures identified six (6) instances from a sample of forty (40), where the necessary repairs were not made by the Sponsors within the stipulated 90-day period. Cause/Effect: While HPD conducts monitoring procedures to help ensure that Housing Quality Standards are maintained and, when necessary, related repairs are performed by the respective Sponsors within the prescribed 90-day timeframe, we noted that the necessary repairs were not consistently completed within the stipulated timeframe or not completed at all. Incomplete and/or repairs that do not meet the stipulated completion timeframe could result in Sponsored projects not maintaining the appropriate quality of living conditions for tenants and, therefore, not comply with the applicable Housing Quality Standards. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: While contract provisions between HPD and the respective Sponsors permit HPD to exercise remedies, which may include the withdrawal of future funding, HPD did not elect to exercise any such remedies. Accordingly, we recommend that HPD continue to strengthen its monitoring of Sponsors in connection with housing quality inspections and determine, on a case-by-case basis, whether to exercise appropriate remedies in accordance with contract provisions or consider documenting its rationale for not doing so.
New York City Human Resources Administration (?HRA?) Finding #: 2022-011 Funding Year(s): 10/19/2017-9/1/2025 HOME Investment Partnerships Program (FAL #14.239) Contract Numbers: M-17-MC-36-0204 Federal Agency: U.S. Department of Housing and Urban Development (?HUD?) Type of Finding: Special Tests and Provisions Material Non-Compliance and Internal Control (Material Weakness) Criteria: Per 24 CFR sections 92.504(d) all housing occupied by tenants receiving HOME tenant-based rental assistance must meet the standards in 24 CFR 982.401 or the successor requirements as established by HUD. The participating jurisdiction must perform annual on-site inspections of rental housing occupied by tenants receiving HOME-assisted TBRA to determine compliance with these standards. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: HRA has policies and procedures in place to identify the units which require Housing Quality Standards inspections and performs inspections of these units to help ensure that any needed repairs are completed within the stipulated timeframe. For those units in need of repairs, HRA policy requires that repairs be completed within 30 days after the initial inspection and supported by a Certificate of Repairs form. In accordance with the individual agreements between HRA and the landlords of the units receiving Tenant Based Rental Assistance, the landlords are responsible for maintaining compliance with the Housing Quality Standards, and HRA inspections are conducted to help ensure the respective landlords are maintaining compliance. Additionally, there are clauses within the individual agreements between HRA and the landlord which allows HRA to exercise remedies such as restricting funding to landlords who do not comply with the Housing Quality Standards. We selected a non-statistical sample of forty (40) units inspected during FY2022 and found that twenty-one (21) of the selections had errors as follows: ? For eleven (11) of twenty-one (21), HRA was not able to provide a copy of the certification of repairs issued by the landlord noting when the repair was made to correct the issues identified in the failed inspection. ? For five (5) of twenty-one (21), the necessary repairs were not made by the landlord within the stipulated 30-day period. For all five (5) of these instances, HRA forwarded a Notification of Failure describing the findings and a reminder that the landlord had 30 days to submit a Certification of Repairs form. ? For two (2) of twenty-one (21), HRA was not able to provide a copy of the Notification of Failure submitted to the landlord to notify them of the failed inspection, reminding the landlord that they had 30 days to submit a Certification of Repairs form. ? For five (5) of twenty-one (21), HRA was not able to provide support noting that the initial inspection failure was dismissed and repairs were no longer necessary. ? For one (1) of twenty-one (21), HRA was not able to provide a copy of the inspection reports completed by a certified inspector. Cause/Effect: While HRA conducts monitoring procedures to help ensure that Housing Quality Standards are maintained and, when necessary, related repairs are performed by the respective landlords within the prescribed 30-day timeframe, we noted the following: ? A comprehensive review and internal control process was not consistently performed and documented to ensure the appropriate evidence was maintained to support the units were compliant with the applicable Housing Quality Standards. ? Necessary repairs were not completed at all, or evidence of the repairs was unable to be provided. Incomplete and/or repairs that do not meet the stipulated completion timeframe could result in landlords not maintaining the appropriate quality of living conditions for tenants and, therefore, not comply with the applicable Housing Quality Standards. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that HRA strengthen its monitoring of landlords in connection with housing quality inspections and determine, on a case-by-case basis, whether to exercise appropriate remedies in accordance with contract provisions or consider documenting its rationale for not doing so. Additionally, we recommend that HRA strengthen their internal controls governing the Housing Quality Standards process, including ensuring that appropriate documentation is maintained to ensure compliance with the Housing Quality Standards.
New York City Human Resources Administration (?HRA?) Finding #: 2022-012 Funding Year(s): 10/19/2017-9/1/2025 HOME Investment Partnerships Program (FAL #14.239) Contract Numbers: M-17-MC-36-0204 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Allowable Costs and Eligibility - Material Noncompliance and Internal Control (Material Weakness) Criteria: In accordance with 23 CFR sections 1.9, 172.11(a), 420.113(a), and 630.106(a), costs incurred under federal awards are considered allowable and reimbursable when such costs are deemed necessary and reasonable; incurred subsequent to the date of authorization to proceed and in accordance with the conditions contained in the project agreement and the plans specifications; and, not included as costs used to meet cost sharing or matching requirements, among other things. As stipulated by 24 CFR ?92.209, tenant-based rental assistance (?TBRA?) may only be provided to very low- and low-income families. The participating jurisdiction must determine that the family is very low- or low-income before the assistance is provided. During the period of assistance, the participating jurisdiction must annually determine that the family continues to be low-income. Also, the maximum monthly assistance that a participating jurisdiction may pay to, or on behalf of, a family may not exceed the difference between a rent standard for the unit size established by the participating jurisdiction and 30% of the family's monthly adjusted income. Additionally, the participating jurisdiction must disapprove a lease if the rent is not reasonable, based on rents that are charged for comparable unassisted rental units. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: The New York City Human Resources Administration (?HRA?) utilizes the Current System to assess beneficiaries? eligibility to receive tenant based rental assistance through the HOME Investment Partnerships Program (?HOME?). To assess eligibility, HRA program staff obtain income supporting documentation to determine if the household met the low-income requirement and to calculate the maximum subsidy amount to be paid by HRA. Additionally, a rent reasonableness valuation is performed which compares the current beneficiary?s rent to other rents charged for comparable units to ensure reasonableness. Upon the completion of the eligibility determination by an HRA staff member, a designated program supervisor reviews and approves the eligibility determination, subsidy amount, and tenant share within Current. We selected a non-statistical sample of forty (40) rental assistance payments made on behalf of tenants during fiscal 2022 and found that twenty-two (22) of the selections had errors as follows: ? For thirteen (13) of the twenty-two (22) selections, HRA was not able to provide documentation to support the participant?s annual income. ? For nine (9) of the twenty-two (22) selections , HRA was also not able to provide the HOME TBRA Certification Information Form, which is utilized to calculate and support HRA?s share of the monthly rent to be paid on behalf of the participant. ? For fourteen (14) of the twenty-two (22) selections, HRA was not able to provide documentation to support that a rent reasonableness assessment was performed. ? For four (4) of the twenty-two (22) selections, it was noted that HRA?s share of monthly rent was determined to be $1,729, $1,778, $1,544, and $235, respectively. However, due to manual input errors, the amounts actually paid on behalf of these tenants were $1,780, $1,762, $1,534, and $176, respectively. ? For one (1) of the twenty-two (22) selections, HRA was unable to provide documentation to support that the eligibility determination and the related calculation was properly reviewed and approved by a supervisor. Total TBRA payments charged to the grant were $5,533,841 and total TBRA benefits subjected to testing were $54,915. Cause/Effect: While HRA has a process in place to assess the eligibility of tenants and calculate the monthly TBRA payments on behalf of those tenants to ensure allowability of costs incurred, a comprehensive review was not consistently performed and documented to ensure the appropriate evidence and related approvals were maintained to support those determinations and calculations. As a result, costs were incurred on behalf of certain tenants that may not have met the eligibility requirements, or an incorrect amount may have been paid on their behalf. Questioned Costs: Known questioned costs totaled $18,240. Identification as a Repeat Finding: This finding is similar to finding #2021-011, included on pages 249 and 250 of the Fiscal 2021 Single Audit report. Recommendation: We recommend that HRA strengthen their internal controls governing the eligibility determination process, including creating a comprehensive review checklist to ensure each tenant meets every eligibility requirement and HRA?s portion of the TBRA payments are properly calculated, and that appropriate supervisory review and approval is consistently performed and documented prior to processing payments and charging costs to the grant.
New York City Department of Health and Mental Hygiene ("DOHMH") Finding #: 2022-007 Funding Year(s): 4/1/2021 ? 3/31/2022 Housing Opportunities for Persons with AIDS (HOPWA) (FAL #14.241) Contract Number: NYH21F002 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Reporting ? Material Noncompliance and Internal Control (Material Weakness) Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (?FFATA?) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252 (the ?Transparency Act?) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The award information must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition/Context: During fiscal year 2022, DOHMH awarded a total of four (4) sub-awards that exceeded $30,000 to three (3) separate subrecipients. We noted that none of these sub-awards were reported in the FSRS system. Cause/Effect: While DOHMH has processes in place to ensure the SAM (System for Award Management) registrations for grant awards are registered under the correct entity, during fiscal 2022, due to management oversite, the SAM registration for this program was not properly processed. The HOPWA agreement was registered under The City of New York, rather than DOHMH, which resulted in DOHMH?s inability to submit information to the FSRS system for FFATA reporting, and therefore, they did not submit any of the required reports related to their fiscal 2022 HOPWA awards. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DOHMH strengthen their processes and internal controls over reporting to ensure all FFATA reports are submitted within the required timeframe, including ensuring that the SAM registration process is completed properly under the correct City agency.
New York City Human Resources Administration (?HRA?) Finding #: 2022-013 Funding Year(s): 7/1/2021 ? 6/30/2022 Housing Opportunities for Persons with AIDS (HOPWA) (FAL #14.241) Contract Numbers: NYH21F002; NYH22F002 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Eligibility - Material Noncompliance and Internal Control (Material Weakness) Criteria: As stipulated by 24 CFR Section 574.3, to be eligible to receive HOPWA funded benefits, a participant must be diagnosed with an acquired immunodeficiency syndrome or related diseases and be a low-income individual, as determined by the Secretary of Housing and Urban Development. HRA utilizes the household income of eligible participants to calculate the monthly rental assistance payment to be made on their behalf. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: We noted that certain rental assistance payments were calculated using an incorrect household income amount. From a non-statistical sample of forty (40) rental assistance payments made on behalf of tenants during FY2022 that were selected for testing, we identified five (5) exceptions, as follows: ? For one (1) of the selections, HRA utilized household income that was higher than their actual income, which caused HRA?s monthly rental assistance payment for the selected period to be less than it should have been. ? For four (4) of the selections, HRA utilized household income that was lower than their actual income, which caused HRA?s monthly rental assistance payment for the selected period to be higher than it should have been. The excess payments for these selections totaled $88. Total rental assistance payments charged to the grant were $20,870,225 and total HOPWA rent subsidies subjected to testing were $51,878. Cause/Effect: While HRA has a process in place to assess the eligibility of tenants and calculate the monthly rental assistance payments to be made on their behalf, they did not consistently ensure that the household income utilized to calculate the monthly rental assistance payment was accurate. As a result, an incorrect monthly rental assistance amount was paid on behalf of certain tenants. Questioned Costs: Known questioned costs totaled $88. Identification as a Repeat Finding: This finding is similar to finding #2021-012, included on pages 251 and 252 of the Fiscal 2021 Single Audit report. Recommendation: We recommend that HRA strengthen their internal controls governing the eligibility process, including ensuring the household income utilized to calculate the monthly rental assistance amount is accurate prior to processing payments and charging costs to the grant.
New York City Human Resources Administration (?HRA?) Finding #: 2022-014 Funding Year(s): 4/1/2021 ? 3/31/2023 Housing Opportunities for Persons with Aids (FAL #14.241) Contract Numbers: NYH21F002; NYH22F002 Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Special Tests and Provisions - Compliance and Internal Control (Significant Deficiency) Criteria: All housing that is assisted under specific HOPWA activities per CFR sections 574.300(b) (3), (4), (5), and (8) must meet specific applicable Housing Quality Standards (?HQS?) as outlined in 24 CFR section 574.310(b) determined by on-site inspections. On May 22, 2020 HUD waived the physical inspection requirement for acquisition, rehabilitation, conversion, lease, or repair; new construction of single room occupancy dwellings and community residences; project or tenant-based rental assistance; or operating costs through March 31, 2022, so long as grantees or project sponsors can visually inspect the unit using technology, such as video streaming, to ensure the unit meets HQS before any assistance is provided; and the grantee or project sponsor has written policies that require physical reinspection of the units not previously physically inspected by June 30, 2022. This waiver applied to units where initial eligibility to receive rental assistance was determined during the fiscal year. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: Prior to providing rental assistance to landlords, HRA conducts on-site inspections to ensure each unit meets all applicable Housing Quality Standards. During each inspection, a HRA Case Manager would assign a Quality Assurance (?QA? Inspector to complete an inspection checklist, which outlines each standard and documents if the unit passed or failed each requirement. The QA Inspector would sign off on the report and provide it to the landlord, noting if any repairs are required. In addition to the initial annual inspection, if there were any adverse findings identified, the Case Manager would conduct follow-up visits for that unit until the findings were remediated. If an on-site inspection was unable to be conducted prior to March 31, 2022, a virtual inspection was performed by a QA Inspector via video call. Similarly, an inspection checklist would be completed for the virtual inspection and the QA Inspector would sign off on the checklist and provide a copy to the landlord. Any repairs needed would be followed up on by the Case Manager until all corrections were implemented. After March 31, 2022, HRA would then ensure a physical inspection was conducted prior to June 30, 2022. In accordance with the individual agreements between HRA and the landlords of the units receiving the rental assistance, the landlords are responsible for maintaining compliance with the HQS, and the HRA inspections are conducted to help ensure the respective landlords are maintaining compliance. We selected a non-statistical sample of nineteen (19) units that were subject to an initial inspection by HRA during fiscal 2022 and noted that for three (3) selections, HRA was unable to provide a copy of the inspection checklist that was completed by the QA Inspector prior to assistance being provided for the unit. Cause/Effect: While HRA conducts monitoring procedures to help ensure that Housing Quality Standards are maintained and, when necessary, related repairs are performed by the respective landlords within the prescribed 30-day timeframe, we noted that the inspection checklists used to document such procedures were not consistently maintained. If controls aren?t in place to ensure each unit is properly inspected in accordance with the guidelines and HRA?s policies, there is a risk that some units may not meet the appropriate quality of living conditions for tenants and, therefore, not comply with the applicable Housing Quality Standards. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that HRA strengthen their internal controls governing the Housing Quality Standards inspection process, including that appropriate documentation is maintained for each inspection performed, to ensure compliance with the requirements is met for each unit under their supervision.
New York City Department of Investigation (?DOI?) Finding #: 2022-009 Funding Year(s): 7/1/2021 ? 6/30/2022 Equitable Sharing Program (FAL #16.922) Contract Numbers: N/A Federal Agency: U.S. Department of Justice Type of Finding: Equipment and Real Property Management - Compliance and Internal Control (Significant Deficiency) Criteria: In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Additionally, as stipulated by 2 CFR section 200.313(d)(2), a physical inventory of property and equipment acquired under a federal award must be taken, and the results reconciled with the property records, at least once every two years. Also, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: From a non-statistical sample of forty (40) pieces of equipment subjected to testing, we identified the following errors: ? Seven (7) pieces of equipment were disposed of in fiscal 2019 but the disposition data was not properly updated and the equipment was not removed from the active inventory listing. ? For seven (7) pieces of equipment, DOI was unable to provide evidence that a physical inventory and reconciliation back to property records was performed and documented within the required two-year timeframe. ? For all forty (40) pieces of equipment, DOI was unable to provide supporting documentation that a review and approval of the inventory had taken place at the time the inventory was conducted. Cause/Effect: While DOI had certain procedures in place to monitor their equipment purchased with Federal funding, such procedures were not adequate to ensure that each aspect of the equipment and real property management compliance requirements were performed and documented within the requirement timeframe, which resulted in the findings noted above. Without the appropriate internal controls and monitoring procedures in place, federally funded equipment could be inaccurately recorded on inventory records and not discovered and corrected timely, inventory could be misplaced, misappropriated, or otherwise disposed of outside of the requirements of the federal guidelines Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend that DOI strengthen controls over the inventory process to ensure dispositions of equipment are updated in the equipment records, inventories performed are reconciled back to equipment records, biennial inventory counts are consistently performed over all equipment within the required timeframe, and that the review and approval of each inventory performed is appropriately documented.
New York City Police Department (?NYPD?) Finding #: 2022-010 Funding Year(s): 7/1/2021 ? 6/30/2022 Equitable Sharing Program (FAL #16.922) Contract Numbers: N/A Federal Agency: U.S. Department of Justice Type of Finding: Equipment and Real Property Management - Compliance and Internal Control (Significant Deficiency) Criteria: As stipulated by 2 CFR section 200.313(d)(2), a physical inventory of property and equipment acquired under a federal award must be taken, and the results reconciled with the property records, at least once every two (2) years. Also, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: From a non-statistical sample of four (4) pieces of equipment subjected to testing, we identified that NYPD was unable to provide supporting documentation that a review and approval of the inventory had taken place at the time the inventory was conducted for all items selected for testing. Cause/Effect: While NYPD had certain procedures in place to monitor their equipment purchased with Federal funding, such procedures were not adequate to ensure that each aspect of the equipment and real property management compliance requirements were documented, which resulted in the finding noted above. Without the appropriate internal controls and monitoring procedures in place, federally funded equipment could be inaccurately recorded on inventory records and not discovered and corrected timely, inventory could be misplaced, misappropriated, or otherwise disposed of outside of the requirements of the federal guidelines Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend that NYPD strengthen controls over the inventory process to ensure that the review and approval of each inventory performed is appropriately documented.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department of Education (?DOE?) Finding #: 2022-001 Funding Year(s): 9/1/2020 ? 8/31/2022 Title I Grants to Local Educational Agencies (FAL #84.010) Contract Numbers: 1R4551J01, 1R4551M01, 1R4510M01, 1R4511L01, 1R4519F01 Career & Technical Education - Basic Grants to States (FAL #84.048) Contract Numbers: 1R0551A01, 1R0579A01 Twenty-First Century Community Learning Centers (FAL #84.287) Contract Numbers: 1R3902A01, 1R3907A01, 1R3912A01, 1R3918A01, 1R3920A01, 1R3930A01, 1R3903A01, 1R3925A01 English Language Acquisition Grants (FAL #84.365) Contract Number: 1R4142A01, 1R4151A01, 1R4164A01 Supporting Effective Instruction State Grant (FAL #84.367) Contract Numbers: 1R2664A01 Student Support and Academic Enrichment (FAL #84.424) Contract Numbers: 1R1951A01, 1R1951B01 Pass-Through Agency: New York State Department of Education Federal Agency: U.S. Department of Education Type of Finding: Reporting Compliance Criteria: As stipulated by the New York State Education Department (?NYSED?) Fiscal Guidelines for Federal and State Grants, program recipients are required to submit to NYSED a signed copy of the Final Expenditure Report for a Federal Project (?FS-10F?) within 90 days following the end of the grant award period. Condition/Context: Of the sixty-six (66) FS-10F reports submitted by the DOE during fiscal year 2022, we selected a sample of twenty-six (26) FS-10F reports and found that twenty-one (21) of the reports tested were submitted after the required due date, as follows: ? Title I Grants to Local Educational Agencies (FAL #84.010): of the nine (9) FS-10F reports tested, five (5) reports were submitted between 70 and 126 days late. ? Career & Technical Education - Basic Grants to States (FAL #84.048): of the two (2) FS-10F reports tested, such reports were submitted between 21 and 43 days late. ? Twenty-First Century Community Learning Centers (FAL #84.287): of the eight (8) FS-10F reports tested, such reports were submitted between 3 and 36 days late. ? English Language Acquisition Grants (FAL #84.365): of the three (3) FS-10F reports tested, such reports were submitted between 70 and 123 days late. ? Supporting Effective Instruction State Grants (FAL #84.367): of the two (2) FS-10F reports tested, one (1) report was submitted 123 days late. ? Student Support and Academic Enrichment (FAL #84.424): of the two (2) FS-10F reports tested, such reports were submitted between 112 and 123 days late. Cause/Effect: We were informed that due to open encumbrances which had not been fully liquidated by the FS-10F due date, the DOE was unable to complete and submit the FS-10F financial reports within the stipulated 90-day period, thus resulting in late-filed reports. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-001, included on pages 228 and 229 of the Fiscal 2021 Single Audit report. Recommendation: We recommend the DOE consider establishing procedures and operational practices whereby disposition of open encumbrances is accelerated such that all FS-10F expenditure reports are prepared and submitted within the required 90-day timeframe.
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department of Health and Mental Hygiene ("DOHMH") Finding #: 2022-006 Funding Year(s): 7/1/2021 ? 6/30/2022 Public Health Emergency Preparedness (FAL #93.069) Contract Numbers: NU90TP922035 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Level of Effort ? Compliance and Internal Control (Control Deficiency) Criteria: The 2 CFR section 200.514(d)(3) states that for those federal programs not covered in the compliance supplement the auditor must use the types of compliance requirements contained and described in Part 3 of the compliance supplement as guidance for identifying the types of compliance requirements to test, and determine the requirements governing the federal program by reviewing the provisions of the federal award or pass-through agency sub-award, and the laws and regulations referred in such awards. As stipulated by Public Health Solutions ("PHS"), the pass-through agency, in its sub-award agreement, Awardees must maintain non-federal expenditures for health-care preparedness and public health security at a level that is not less than the average level of such non-federal expenditures maintained by the awardee for the preceding two-year (2) period. Condition/Context: We noted that total Public Health Emergency Preparedness (?PHEP?) non-federal expenditures for the current year were below the average level of non-federal expenditures for the preceding two-year (2) period. Non-federal expenditures to the program for FY2022 totaled $2,091,743; whereas the average non-federal expenditures for FY2020 & FY2021 totaled $2,482,528. Cause/Effect: While DOHMH has a process in place to track and calculate non-federal expenditures for health-care preparedness and public health security, they did not consistently ensure progressive non-federal expenditures were adequately meeting the appropriate level of effort requirements. As a result, total programmatic non-federal expenditures for the year totaled less than the level of effort requirement. Questioned Costs: None identified Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend that DOHMH strengthen their internal controls regarding compliance surrounding the level of effort requirements, including the appropriate tracking of progressive non-federal expenditures to ensure programmatic level of effort requirements are met. Finding #: 2022-006 Funding Year(s): 7/1/2021 ? 6/30/2022 Public Health Emergency Preparedness (FAL #93.069) Contract Numbers: NU90TP922035 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Level of Effort ? Compliance and Internal Control (Control Deficiency) Criteria: The 2 CFR section 200.514(d)(3) states that for those federal programs not covered in the compliance supplement the auditor must use the types of compliance requirements contained and described in Part 3 of the compliance supplement as guidance for identifying the types of compliance requirements to test, and determine the requirements governing the federal program by reviewing the provisions of the federal award or pass-through agency sub-award, and the laws and regulations referred in such awards. As stipulated by Public Health Solutions ("PHS"), the pass-through agency, in its sub-award agreement, Awardees must maintain non-federal expenditures for health-care preparedness and public health security at a level that is not less than the average level of such non-federal expenditures maintained by the awardee for the preceding two-year (2) period. Condition/Context: We noted that total Public Health Emergency Preparedness (?PHEP?) non-federal expenditures for the current year were below the average level of non-federal expenditures for the preceding two-year (2) period. Non-federal expenditures to the program for FY2022 totaled $2,091,743; whereas the average non-federal expenditures for FY2020 & FY2021 totaled $2,482,528. Cause/Effect: While DOHMH has a process in place to track and calculate non-federal expenditures for health-care preparedness and public health security, they did not consistently ensure progressive non-federal expenditures were adequately meeting the appropriate level of effort requirements. As a result, total programmatic non-federal expenditures for the year totaled less than the level of effort requirement. Questioned Costs: None identified Identification as a Repeat Finding: This is not a repeat finding Recommendation: We recommend that DOHMH strengthen their internal controls regarding compliance surrounding the level of effort requirements, including the appropriate tracking of progressive non-federal expenditures to ensure programmatic level of effort requirements are met.
New York City Human Resources Administration (?HRA?) and Administration for Children?s Services (?ACS?) Finding #: 2022-015 Funding Year(s): 10/1/2020-9/30/2022 Child Care and Development Block Grant (FAL #93.575) Contract Numbers: 21-OCFS-LCM-19, 22-OCFS-LCM-08 Pass-Through Agency: NYS Office of Children and Family Services Federal Agency: U.S. Department of Health and Human Services Type of Finding: Allowable Costs and Eligibility - Material Noncompliance and Internal Control (Material Weakness) Criteria: In accordance with 23 CFR sections 1.9, 172.11(a), 420.113(a), and 630.106(a), costs incurred under federal awards are considered allowable and reimbursable when such costs are deemed necessary and reasonable; incurred subsequent to the date of authorization to proceed and in accordance with the conditions contained in the project agreement and the plans specifications; and, not included as costs used to meet cost sharing or matching requirements, among other things. As stipulated by the 45 CFR Part 98 Subpart C, to be eligible for services under the Child Care and Development Block Grant (?CCDBG?), a child shall (1) be under the age of thirteen (13) years of age or be under the age of nineteen (19) and physically or mentally incapable of caring for himself or herself; (2) Reside with a family whose income does not exceed 85 percent of the State's median income (SMI) and whose family assets do not exceed $1,000,000; and (3) reside with a parent or parents who are working or attending a job training or educational program; or receive, or need to receive, protective services. Additionally, as stipulated by 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in ?Standards for Internal Control in the Federal Government? (the ?Green Book?) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (?COSO?) for the federal funding streams it administers. Condition/Context: We selected a non-statistical sample of sixty-five (65) individuals who received services under CCDBG during FY2022 and found that four (4) of the individuals tested had errors as follows: ? Two (2) of the individuals tested from HRA and one (1) of the individuals tested from ACS not meet some or all of the eligibility criteria as stipulated in 45 CFR Part 98 Subpart C ? For one (1) of the individuals, ACS was not able to provide documentation to support that the individual met all the eligibility criteria as stipulated in 45 CFR Part 98 Subpart C Total CCDBG Benefits charged to the grant were $276,786,114 and total CCDBG benefits subjected to testing were $48,752. Cause/Effect: While HRA and ACS have a process in place to assess the eligibility of children, a comprehensive review was not consistently performed and documented to ensure the appropriate evidence and related approvals were maintained to support those determinations. As a result, costs were incurred on behalf of certain children that did not meet all of the eligibility requirements. Questioned Costs: Known questioned costs of $2,419. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that HRA and ACS strengthen their internal controls governing the eligibility requirements, including implementing a review checklist to ensure the child meets every eligibility requirement per 45 CFR Part 98 Subpart C during the eligibility determination process.
New York City Department of Health and Mental Hygiene ("DOHMH") Finding #: 2022-004 Funding Year(s): 8/1/2020 ? 7/31/2025 HIV Prevention Activities ? Health Department Based (FAL #93.940) Contract Number: 20NU62PS924626 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Reporting - Compliance and Internal Control (Control Deficiency) Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (?FFATA?) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The award information must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition/Context: During fiscal year 2022, HIV Prevention Activities awarded a total of two (2) sub-awards that exceeded $30,000 to one (1) subrecipient. Refer to the table below for results of our testing. Cause/Effect: While DOHMH has established policies and procedures to ensure that the required reports are accurately completed and submitted on a timely basis, we noted oversight on the timely reporting for the subawards. This resulted in DOHMH missing the filing window and failing to submit its subawards in the FSRS system within the stipulated reporting period, no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DOHMH strengthen their internal controls over the reporting process to ensure all FFATA reports are submitted within the required timeframe.
New York City Department of Health and Mental Hygiene (?DOHMH?) Finding #: 2022-005 Funding Year(s): 8/1/2020 - 12/31/2022 HIV Prevention Activities ? Health Department Based (FAL #93.940) Contract Numbers: 5 NU62PS924575-04-00; 5 NU62PS924575-05-00; 1NU62PS924626-01-00; 6NU62PS924626-02-01 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Subrecipient Monitoring - Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(d) stipulate that pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Condition/Context: During fiscal 2022, DOHMH passed through federal funding to one subrecipient. We selected this subrecipient for testing and noted that DOHMH did not perform any of the required monitoring procedures in accordance with 2 CFR 200.332(d). Cause/Effect: While DOHMH has established procedures to comply with certain aspects of the subrecipient monitoring compliance requirements, such procedures did not include performing on-site reviews or similar alternate procedures that would allow DOHMH to properly oversee and evaluate the subrecipients? compliance with the requirements of the subaward. Without proper monitoring procedures, DOHMH may not have the appropriate amount of information to ensure the subrecipient is being used in accordance with Federal guidelines and the terms of the subaward. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DOHMH create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including performing appropriate monitoring procedures to ensure each subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves the performance goals of the subaward.
Finding #: 2022-002 Funding Year(s): 7/1/2021-6/30/2022 Port Security Grant Program (FAL #97.056) Contract Number: EMW-2015-PU-APP-00314, EMW-2017-PU-00122 Federal Agency: U.S. Department of Homeland Security Type of Finding: Equipment and Real Property Management - Compliance and Internal Control (Control Deficiency) Criteria: As stipulated by 2 CFR sections 200.313(d)(2), a physical inventory of property and equipment acquired under a federal award must be taken, and the results reconciled with the property records, at least once every two years. Condition/Context: The New York City Police Department (?NYPD?) utilizes the City?s Grants Tracking System (?GTS?), a citywide web-based inventory program, designed to standardize the tracking of federally funded equipment. Further, NYPD Command-designated grants coordinators are responsible for monitoring the equipment and updating the inventory on a periodic basis in accordance with federal guidelines. The NYPD Grants Unit periodically generates an inventory listing from GTS that includes the biennial inventory count due date for each item and distributes it to the assigned NYPD Command designated grant coordinators to ensure the inventory count is conducted timely and in accordance with federal requirements. After the completion of biennial inventory count, the NYPD Command-designated grants coordinators update the inventory count information to GTS. From a haphazard sample of twenty (20) pieces of equipment subjected to testing, we identified three (3) items where the NYPD Command-designated grants coordinators were unable to support that a physical inventory count was conducted within the required two-year period as of June 30, 2022. Cause/Effect: During 2021, the Grants Tracking System was upgraded and the most recent inventory entry and the original acquisition information were migrated to the new system. However, inventory entries performed between acquisition and the most recent inventory entry were not migrated. As per the Office of Management and Budget (OMB), the citywide GTS is the record for all grant-related inventory information. The NYPD does not maintain a separate inventory tracking mechanism. As a result, NYPD could not provide documentation that they complied with 2 CFR sections 200.313(d)(2) as of year-end for three (3) pieces of equipment selected. Inventory counts that are not completed within the required timeframe could result in federally funded equipment being inaccurately recorded on the inventory records and not discovered and corrected timely. Questioned Costs: None identified. Identification as a Repeat Finding: This finding is similar to finding #2021-003 included on pages 232 through 233 of the Fiscal 2021 Single Audit report. Recommendation: We recommend that NYPD strengthen controls over the inventory process to ensure biennial inventory counts for all equipment are consistently performed and documented within the required timeframe, and that such documentation is properly maintained.