FUND FOR PUBLIC HEALTH IN NEW YORK, INC.Non-Profit

Finding 2025-001: Finding Type: Noncompliance and significant deficiency in internal control Federal Department: U.S. Department of Health and Human Services Identification of the Federal Program: Assistance Listing Number 93.297 – Teenage Pregnancy Prevention Program, United States Department of Health and Human Services (HHS) Award Number: 5 TP1AH000315-02-00 Compliance Requirements: Matching, Level of Effort, and Earmarking and Reporting Criteria Per 2 CFR 200.303 (Internal Controls), non-federal entities must establish and maintain effective internal control over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and terms and conditions of the award. Effective internal controls should ensure these requirements are consistently met. Per 2 CFR 200.306 (Cost Sharing), cost-sharing contributions, including third-party in-kind contributions, must be properly documented and allowable. Per 2 CFR 200.328 (Financial Reporting), financial reports must be accurate and complete. The SF-425 Federal Financial Report (FFR) instructions require recipients to report recipient share of expenditures (including cost matching or cost sharing). The Notice of Funding Opportunity #AH-TP1-23-001 for Advancing Equity in Adolescent Health through Evidence-Based Teen Pregnancy Prevention Programs and Services issued by HHS states at section D.3.b.1.s: “For awards that do not require matching or cost sharing by statute or regulation, where ‘cost sharing’ refers to costs of a project in addition to Federal funds requested that you voluntarily propose in your budget, if your application is successful, we will include this non-federal cost sharing in the approved budget and you will be held accountable for the non-federal cost-sharing funds as shown in the Notice of Award (NOA). Failure to meet a cost sharing or matching obligation that is part of the approved project budget on the NOA may result in the disallowance of federal funds. If you are funded, you will be required to report cost sharing or matching funds on your quarterly Federal Financial Reports.” Condition The Fund did not formally track or record the in-kind contribution required for federal award #5 TP1AH000314-02-00 for budget period July 1, 2024 through June 30, 2025. The Fund did not report the recipient share of expenditures on the quarterly SF-425 Federal Financial Reports (FFR) during fiscal year 2025. Through review of supporting documentation compiled subsequent to fiscal year 2025, the auditor verified that the Fund received third-party in-kind contributions via donated services performed during the budget period of July 1, 2024 through June 30, 2025 of $1,119,156, which is $22,521 less than the required cost share per the NOA. However, the Fund submitted a grant amendment to HHS on February 28, 2025 via the Grant Solutions system to reduce the Project Director's effort from 100% to 25% (because she was reassigned to another federal program), which would have reduced the required cost share amount to $1,039,482. Had the Fund's grant amendment request been approved, the Fund would have met and exceeded the required in-kind cost share. The Fund has made numerous attempts to contact HHS to obtain resolution regarding the outstanding grant amendment approval request, to no avail. As of May 29, 2026, the grant amendment has yet to be approved by HHS, and it appears as "in progress" in the Grant Solutions system. Therefore, the auditor was unable to determine whether the in-kind cost share was fully met. Cause When applying for the New York City Teens Connection Expansion project funds for budget period July 1, 2024 through June 30, 2025, the Fund included a voluntary non-federal cost share amount of $1,141,677 in their proposed budget. Upon receiving the federal award, HHS included the $1,141,677 cost share on the NOA as a requirement of the federal award. The Fund was aware of the required cost share, but did not formally track or report the donated services provided toward the cost share requirement during fiscal year 2025 because they thought that voluntary cost share amounts are not required to be formally tracked or reported on the FFR. Effect The Fund’s internal controls did not ensure that #93.297 in-kind contributions were formally documented and reported in accordance with Uniform Guidance requirements during fiscal year 2025. Recipient share of expenditures on the quarterly FFRs was underreported and the federal awarding agency may not have been able to verify the Fund’s compliance with matching requirements. Questioned Costs None. Recommendation We recommend that the Fund implement internal control procedures whereby someone reviews NOAs for any specified cost sharing or matching amounts, including those which are voluntary, and ensure that compliance with such requirements are formally tracked and reported over the life of the award. View of Responsible Officials Management agrees with the recommendation. The Organization’s corrective action plan is on page 45.

Finding 2021?002: Reporting Finding Type: Noncompliance, Significant Deficiency Federal Department: U.S. Department of Health and Human Services FAIN: NH75OT000036 COVID-19 ? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crisis, Federal Assistance Listing Number 93.391 Criteria: Federal Funding Accountability and Transparency Act Aspects of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), as amended by Section 6202 of Pub. L. No. 110-252, that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement. Direct recipients are required to report each first-tier subaward or subaward amendment that results in an obligation of $30,000 or more in federal funds. Prime contractors are required to report each first-tier subcontract award of $30,000 or more in federal funds. Grant and cooperative agreement recipients and contractors are required to register in FSRS and report subaward data through FSRS. To do so, they will first be required to register in the System for Award Management (SAM) (if they have not done so previously for another purpose (e.g., submission of applications through Grants.gov) and actively maintain that registration. Prime contractors have previously been required to register in SAM. Information input to FSRS is available at USASpending.gov as the publicly available website for viewing this information (https://www.usaspending.gov/search). Condition: The Fund has an obligation to report subaward data as required under the Federal Funding Accountability and Transparency Act (FFATA). This includes subawardee information, subawardee DUNS or SAM number or Unique Entity ID, and relevant executive compensation, if applicable. Based on our selection of eight subawards for testing, the following was noted. See Schedule of Findings and Questioned Costs for chart/table. Cause: Due to the large volume of COVID-19 work during fiscal year 2022 and understaffing for the Grants and Contracts team, the Fund did not consistently have personnel in place to ensure they submitted subaward information in FFATA reports accurately and timely. Effect: The Fund did not submit subaward information in certain FFATA reports accurately or timely. Questioned Costs: None Recommendation: We recommend that the Fund implement internal control procedures whereby someone other than the preparer reviews the FFATA reports to ensure accurate and timely reporting of all required subawards on FFATA reports prior to submission. View of Responsible Officials: Management agrees with the recommendation. The Organization?s corrective action plan is on page 43 of the audited financial statements report.