United Way of New York CityNon-Profit

Type of Finding: Subrecipient Monitoring – Noncompliance and Internal Control (Significant Deficiency) Supplemental Nutrition Assistance Program Cluster: State Administration Matching Grants for the Supplemental Nutrition Assistance Program (Assistance Listing #10.561) Federal Agency: U.S. Department of Agriculture Pass-Through Entity: New York State Office of Temporary and Disability Assistance Contract Number: TDA01-C00986GG-3410000 Funding Years: 10/1/2023 - 9/30/2025 Criteria: Per 2 CFR 200.332(g), a pass-through entity must verify that subrecipients expected to be audited by 2 CFR Part 200, Subpart F, met this requirement. Condition/Context: For a non-statistical sample of three subrecipients, during the fiscal year ended June 30, 2025, UWNYC did not verify that subrecipients expected to be audited as required by 2 CFR Part 200, Subpart F, met this requirement. Cause: UWNYC’s internal controls over subrecipient monitoring lacked the requirement to ensure that UWNYC complied with 2 CFR 200.332(g). However, UWNYC requested and obtained the most recent audit report required by 2 CFR Part 200, Subpart F for each of the sampled subrecipients as part of CBIZ CPAs’ Single Audit requests. Effect: UWNYC was noncompliant with the subrecipient monitoring requirement described in 2 CFR 200.332(g). Questioned Costs: None. Identified as a Repeat Finding: No. Recommendation: UWNYC should implement a procedure within its subrecipient monitoring process and internal control to ensure that, each year, program staff verify whether subrecipients are expected to be audited by 2 CFR Part 200, Subpart F. For those subrecipients that expect to be audited by 2 CFR Part 200, Subpart F, program staff should also obtain and review the final audit report. If the final audit report includes any audit findings, including those specifically related to the subaward, UWNYC should consider such audit findings as part of UWNYC’s assessment of the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Views of Responsible Officials: We acknowledge and accept this finding. To address this gap and prevent recurrence, we will implement a formal annual verification and documentation process requiring program staff to determine audit applicability, obtain and review final Single Audit reports, and incorporate any audit findings into subrecipient risk assessments to inform ongoing monitoring. These procedures will be documented and integrated into UWNYC’s internal controls to ensure future compliance.

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