Finding 1215849 (2025-001)

SEFA Reporting Significant Deficiency - Ryan White HIV/AIDS Program Parts A and B Management’s Views and Opinion Sunset Park Health Council, Inc. acknowledges the finding and agrees that the Ending the HIV Epidemic: A Plan for America — Ryan White HIV/AIDS Program Parts A and B grant should have been identified and reported as a federal award on the Schedule of Expenditures of Federal Awards (“SEFA”) beginning with the applicable award period. Management notes that the omission resulted from the Assistance Listing Number (“ALN”) not being identified at the time of the initial grant setup, which impacted the subsequent classification of the award for SEFA reporting purposes. Once identified during the FY2025 audit process, management corrected the matter by including the cumulative federal expenditures under the award on the FY2025 SEFA. Management also notes that there were no questioned costs and that the omission did not impact the prior-year major program determinations. Sunset Park is committed to strengthening its grant setup, award identification, and SEFA review controls to ensure that all federal awards, including federal pass-through awards, are accurately identified, classified, and reported in accordance with Uniform Guidance. The corrective actions described below are intended to improve the completeness and accuracy of federal award reporting and to prevent similar omissions in future reporting periods. Corrective Action Plan: To mitigate this risk, the following controls and procedures will be implemented: 1. Quarterly Grant Review All active and new grants will be reviewed on a quarterly basis by the Director of Grants and Grant Accountants to ensure completeness and accuracy of key award data, including CFDA/ALN identification. Any discrepancies will be identified and corrected timely. 2. AAW (Award Authorization Workflow) Control All Award Authorization Work (AAW) forms submitted to NYU Research Data Management (RDM) will require review and initial approval by the Director of Grants prior to submission, confirming that all required fields, including CFDA/ALN, are complete. 3. RDM Submission Verification Each submission to RDM will require confirmation and acknowledgment that all award data has been properly entered and recorded for both new and existing grants. 4. Chartstring Verification Control As part of the chartstring distribution process, Grant Accountants will confirm that all relevant grant attributes, including CFDA/ALN numbers, have been accurately established and communicated to program teams. 5. SEFA and Interim Review Procedures During interim reviews and annual SEFA preparation, each Grant Accountant will verify that all assigned grants are properly classified as federal or non-federal and that all applicable CFDA/ALN numbers are included and accurately reported. Responsible Parties: • Director of Grants • Grant Accountants • NYU Research Data Management (RDM) Implementation Timeline: Full implementation of corrective actions by August 31, 2026 Training: Grants Fiscal staff will undergo CFDA/ALN identification and SEFA reporting training by August 31, 2026. Training will be recorded and incorporated into onboarding for new staff. Conclusion: These corrective actions strengthen internal controls over grant setup and reporting, ensuring accurate identification of federal funding sources and completeness of SEFA reporting in compliance with Uniform Guidance. Responsible Individual Leonardo Arias Email: Leonardo.Arias@nyulangone.org