Finding Text
2022-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victim Services: Crime Victim Assistance Assistance Listing No. 16.575 United States Department of Housing and Urban Development: Continuum of Care Program Assistance Listing No. 14.267 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The Organization did not yet complete written policies and procedures relative to Federal Awards to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the Organization?s ability to complete policies and procedures to comply with the requirements of the Uniform Guidance. Effect: Not having implemented the updated policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of Organization personnel regarding procedures, it was noted that Organization policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, item # 2021-001, related to the Crime Victim Assistance grant. That same finding is related to the Crime Victim Assistance and the Continuum of Care Program awards, identified above. Recommendation: The Organization should complete the written policies and procedures to comply with the Uniform Guidance requirements. Views of Responsible Officials of Auditee: The Organization agrees with the finding and in 2023, the Organization completed written policies and procedures that comply with the Uniform Guidance requirements.