Audit 413901

Reference Number: 2025-002 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture Federal Program: SNAP Cluster Assistance Listing Number: 10.561 Pass-Through Entity: New York State Office of Temporary and Disability Assistance Pass-Through Entity Identifying Number and Period: 18000 (1/1/2025-12/31/2025), Various Compliance Requirement: Special Tests and Provisions – ADP System for SNAP Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: State agencies are required to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP (7 CFR sections 272.10 and 277.18). This includes: (1) processing and storing all case file information necessary for eligibility determination and benefit calculation, identifying specific elements that affect eligibility, and notifying the certification unit of cases requiring notices of case disposition, adverse action and mass change, and expiration; (2) providing an automatic cutoff of participation for households that have not been recertified at the end of their certification period by reapplying and being determined eligible for a new period (7 CFR sections 272.10(b)(1)(iii) and 273.10(f) and (g)); and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. The State passes the responsibility of document retention to Suffolk County, New York (the County) for eligibility and benefit recalculation, therefore the County is subject to this requirement. Control: Per 2 CFR section 200.303(a), the recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” 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). Condition: The County did not maintain adequate documentation of program participant eligibility; therefore it was unable to demonstrate compliance with the special provisions required for the SNAP ADP System. Context: Forty participants were selected for testing and the following exceptions were noted: • For 1 of 40 participants selected for testing, the County was unable to provide documentation that a program supervisor had approved the application for benefits. • For 2 of 40 participants selected for testing, no approved Case Service Record could be provided to show review of the participants’ eligibility. • For 1 of 40 participants selected, a budget for benefits was not retained, therefore the benefit amount could not be recalculated. Questioned costs: Undetermined. The dollar amount of questioned costs could not be determined because the County did not provide sufficient documentation to determine whether the participants were eligible for program benefits nor could the specific benefit amounts associated with those participants be identified. Cause: The County’s procedures were not sufficient to ensure it maintained documentation that program participants’ eligibility was properly determined, reviewed and approved nor that benefits were properly calculated. Effect: Without sufficient documentation of eligibility, the County cannot demonstrate that services were provided only to eligible participants and that benefit amounts were calculated correctly. Recommendation: The County should strengthen procedures and internal controls to ensure eligibility is properly determined, that benefits are properly calculated, and that supporting documentation is retained and readily available for audit. Views of Responsible Officials: Management agrees with the finding and will perform corrective actions noted on the corresponding Corrective Action Plan.

Reference Number: 2025-003 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services Federal Program: Low-Income Home Energy Assistance Program Assistance Listing Number: 93.568 Pass-Through Entity: New York State Office of Temporary and Disability Assistance Pass-Through Entity Identifying Number and Period: OSC HEAP Awards 1/1/2025-12/31/2025 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Recipients may assist (a) households in which one or more individuals are receiving Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) benefits, or certain needs-tested veterans’ benefits; or (b) households with incomes which do not exceed the greater of 150 percent of the state’s established poverty level, or 60 percent of the state median income. Recipients may establish lower income eligibility criteria, but no household may be excluded solely based on income if the household income is less than 110 percent of the state’s poverty level (42 USC 8624(b)(2)). Recipients must give priority to those households with the highest home energy costs or needs in relation to income and household size (42 USC 8624(b)(5)). The County must ensure that only eligible participants receive services under the program. Control: Per 2 CFR section 200.303(a), the recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” 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). Condition: The County did not maintain adequate documentation of program participant eligibility. Context: For eight of forty participants selected for testing, the County was unable to provide evidence of a Case Service Record which indicates the participant’s categorical eligibility. Questioned costs: Undetermined. The dollar amount of questioned costs could not be determined because the County did not provide sufficient documentation to determine whether the participants were eligible for program benefits nor could the specific benefit amounts associated with those participants be identified. Cause: The County’s procedures were not sufficient to ensure it maintained documentation that program participants’ eligibility was properly determined, reviewed and approved. Effect: Without sufficient documentation of eligibility, the County cannot demonstrate that services were provided only to eligible participants. Recommendation: The County should strengthen procedures and internal controls to ensure eligibility is properly determined and documented and that supporting documentation is retained and readily available for audit. Views of Responsible Officials: Management agrees with the finding and will perform corrective actions noted on the corresponding Corrective Action Plan.

Reference Number: 2025-004 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services Federal Program: Adoption Assistance Assistance Listing Number: 93.659 Pass-Through Entity: New York State Office of Children and Family Services Pass-Through Entity Identifying Number and Period: 18000 (1/1/2025-12/31/2025) Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: In addition to establishment of categorical eligibility, the prospective adoptive parent(s) and any other adult living in the home who has resided in the provider home in the preceding five years must satisfactorily have met a child abuse and neglect registry check. (42 USC 671(a)(20)(B); Pub. L. No. 109-248, Sections 152(c)(2) and (3)). Control: Per 2 CFR section 200.303(a), the recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” 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). Condition: The County did not maintain adequate documentation of program participant eligibility. Context: For four of sixty participants selected for testing, the file maintained by the County did not include evidence that the prospective adoptive parents and adults in the home met the child abuse and neglect registry check. Questioned costs: Undetermined. The dollar amount of questioned costs could not be determined because the County did not provide sufficient documentation to determine whether the participants were eligible for program benefits nor if benefit amounts associated with those participants were unallowable. Cause: The County’s procedures were not sufficient to ensure it retained documentation of the original child abuse and neglect registry checks. Effect: Without sufficient documentation that adoptive parents and adults in the home met the child abuse and neglect registry check, the County cannot demonstrate that services were provided only to eligible participants. Recommendation: The County should strengthen its procedures and internal controls to ensure that required child abuse and neglect registry checks are completed and that documentation supporting participant eligibility is retained in participant files and is readily available for audit. Views of Responsible Officials: Management agrees with the finding and will perform corrective actions noted on the corresponding Corrective Action Plan.

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services Federal Program: Social Services Block Grant Assistance Listing Number: 93.667 Pass-Through Entity: New York State Office of Temporary and Disability Assistance Pass-Through Entity Identifying Number and Period: 18000 (Multiple) (1/1/2025-12/31/2025) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR 200.332(c), a pass-through entity must evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. Per 2 CFR section 200.332(e) and (g), pass-through entities must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward, and must monitor the overall performance of the subrecipient to ensure that the goals and objectives of the subaward are achieved. Subrecipient monitoring must include reviewing financial and performance reports, following up and ensuring that the subrecipient takes timely and appropriate action on deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity, issuing management decisions for applicable audit findings, and verifying that the subrecipient is audited as required by Subpart F when applicable. Control: Per 2 CFR section 200.303(a), the recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” 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). Condition: The County did not maintain documentation that it performed an evaluation of subrecipients’ fraud risk and risk of noncompliance prior to issuance of subawards. Context: For five of five subrecipients selected for testing, the County was unable to provide documentation demonstrating that a program supervisor performed fraud risk and noncompliance risk assessments before the related subawards were issued. Although the County performed general monitoring activities for these subrecipients, the monitoring procedures were not based on documented evaluations of each subrecipient’s individual risk. Questioned costs: Undetermined. Known questioned costs could not be quantified because the County did not maintain documentation of the required subrecipient risk assessments; therefore, the amount of Federal expenditures, if any, affected by the exception could not be determined. Cause: The County’s procedures did not ensure that subrecipient fraud risk and risk of noncompliance were evaluated and documented before subaward issuance. Effect: Without documented risk assessments, the County may not have established appropriate monitoring procedures to address each subrecipient’s fraud risk and risk of noncompliance with program requirements. Recommendation: The County should strengthen procedures and internal controls to ensure subrecipient fraud risk and risk of noncompliance assessments are performed and documented before subaward issuance and that supporting documentation is retained and available for audit. Views of responsible officials: Management agrees with the finding and will perform corrective actions noted on the corresponding Corrective Action Plan.

Reference Number: 2025-006 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture Federal Program: SNAP Cluster Assistance Listing Number: 10.561 Pass-Through Entity: New York State Office of Temporary and Disability Assistance Pass-Through Entity Identifying Number and Period: 18000 (1/1/2025-12/31/2025), Various Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity, as provided in 2 CFR section 180.300. Control: Per 2 CFR section 200.303(a), the recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” 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). Condition: The County was unable to provide documentation that it had verified contractors were not suspended or debarred before entering into a covered transaction with the entities. Context: The suspension and debarment status for two of two contractors selected for testing was not documented. Auditors verified that the contractors were not suspended or debarred at the time of audit. Questioned costs: None noted. There are no questioned costs related to this finding since the vendors were not federally suspended or debarred. Cause: The County did not have effective controls to ensure suspension and debarment checks were performed and documented before contracts were issued. Effect: Without documentation that suspension and debarment checks were completed before contracts were issued, the County cannot demonstrate compliance with federal requirements and it could enter into a transaction with an ineligible entity. Recommendation: We recommend the County implement procedures and controls to ensure suspension and debarment checks are completed before entering into covered transactions and that documentation is retained and is available for audit. Views of responsible officials: Management agrees with the finding and will perform corrective actions noted on the corresponding Corrective Action Plan.