Finding 1239027 (2025-004)

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.