Finding 1239024 (2025-002)

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.