New York State Sheriffs' Association, Inc.

2024-002 Compliance with Reporting Requirements Information on Federal Programs: U.S. Department of Transportation State and Community Highway Safety, federal assistance listing number 20.600. U.S. Department of Transportation National Priority Safety Programs, federal assistance listing number 20.616. U.S. Department of Health and Human Services Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 VFR section 200.512(a) requires the reporting package and data collection form to be submitted to the Federal Audit Clearing House the earlier of 30 calendar days after the reports are received from the auditor or 9 months after the end of the reporting period. Therefore, the December 31, 2024 reporting package deadline was September 30, 2025. Statement of Condition: The Single Audit was not filed within 9 months after year-end as required by the Federal Audit Clearing House. Statement of Cause: Difficulties were encountered in performing and completing the audit process, which caused delays in preparing accurate financial data. As a result, the December 31, 2024 audit was not issued until December 21, 2025. Statement of Effect: The Association was not in compliance with federal guidelines. Questioned Cost: None Repeat Finding: Yes Recommendation: We recommend management review policies and procedures to ensure timely and accurate information is available in order to complete the audit process timely. Views of the Responsible Officials and Planned Corrective Actions: Modified internal procedures and performance of reconciliations, as well as complete entry posting will make future audits more effective and efficient, allowing for the timely submission to the Federal Audit Clearing House.

Internal Control Over Compliance Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 CFR Section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards incompliance with federal statutes, regulations, and the terms and conditions of the federal awards. Statement of Condition: Adequate internal controls over compliance are not established. Specifically, there is a lack of segregation of duties. Statement of Cause: Segregation of these duties has not been achieved due to the small size of the Association and current procedures. Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Section 200.303. There is a reasonable possibility that noncompliance would not be prevented or detected and corrected in a timely basis. Questioned Cost: None Repeat Finding: Yes Perspective Information: Management did have a process to identify and track costs under the grant through the use of separate general ledger accounts for purposes of claiming reimbursement. Recommendation: We recommend a review of policies and procedures to update and determine where changes may provide opportunities for segregation of duties. Views of responsible officials and planned corrective actions: Invoices received by NYSSA pertaining to Federal Grants will be given to the Deputy Director, Lucas Ashby for review. (current procedure). Invoices to be paid will be entered into Quickbooks financial software by the Finance Manager, Jon Greenwalt (current procedure). Checks for payment to grant vendors follow the same procedures and processes as listed in 2022-001 above, numbers 1 and 2 [New procedure implemented] Based on the timeline of the 2022 audit, many of the corrective actions were made in late Oct/November 2023.

Procurement – Suspension and Debarment Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs. Statement of Condition: During our testing for procurement compliance, it was determined that the New York State Sheriffs’ Association, Inc. did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs. Questioned Cost: None Statement of Cause: Management was not aware of the requirement to review an entity’s status. Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Association could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs. Repeat Finding: Yes Perspective Information: There was one vendor in excess of the $25,000 threshold which was reviewed to determine eligibility for participation noting they are not debarred, suspended, or otherwise excluded from participation in federal award programs. Recommendation: We recommend management review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs. Views of the Responsible Officials and Planned Corrective Actions: Vendors will be reviewed and documented that they are not debarred, suspended, or otherwise excluded from participation in federal award programs by use of the System for Award Management (SAM), the Official U.S. Government system. Based on the timeline of the 2022 audit, many of the corrective actions were made in late Oct/November 2023.

Compliance with Reporting Requirements Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 CFR section 200.512(a) requires the reporting package and data collection form to be submitted to the Federal Audit Clearing house the earlier of 30 calendar days after the reports are received from the auditor or 9 months after the end of the reporting period. Therefore, the December 31, 2023, reporting package deadline was September 30, 2024. Statement of Condition: The Single Audit was not filed within 9 months after year end as required by the Federal Audit Clearing House. Statement of Cause: Difficulties were encountered in performing and completing the audit process, which caused delays in preparing accurate financial data. As a result, the December 31, 2023 audit was not issued until January 22, 2025. Statement of Effect: The Association was not in compliance with federal guidelines. Questioned Cost: None Repeat Finding: No Recommendation: We recommend management review policies and procedures to ensure timely and accurate information is available in order to complete the audit process timely. Views of the Responsible Officials and Planned Corrective Actions: The amount of backup source documents and intensity of the single audit was very unfamiliar to staff responsible for providing those materials. Recent hire of Finance Assistant, Paula Gwinnell and her gained experience will help move the audit along in a more timely manner.

Internal Control Over Compliance Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 CFR Section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards incompliance with federal statutes, regulations, and the terms and conditions of the federal awards. Statement of Condition: Adequate internal controls over compliance are not established. Specifically, there is a lack of segregation of duties. Statement of Cause: Segregation of these duties has not been achieved due to the small size of the Association and current procedures. Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Section 200.303. There is a reasonable possibility that noncompliance would not be prevented or detected and corrected in a timely basis. Questioned Cost: None Repeat Finding: No Recommendation: We recommend a review of policies and procedures to update and determine where changes may provide opportunities for segregation of duties.Views of responsible officials and planned corrective actions: Invoices received by NYSSA pertaining to Federal Grants will be given a supervisory designee for review (current procedure) and logged on a spreadsheet prior to being delivered to the Finance Office for processing. [New procedure implemented] Invoices to be paid will be entered into Quickbooks financial software by the Finance Manager (current procedure). Checks for payment to grant vendors follow the same procedures and processes as listed in 2022-001 above, numbers 1 and 2 [New procedure implemented] Perspective Information: Management did have a process to identify and track costs under the grant through the use of separate general ledger accounts for purposes of claiming reimbursement.

Procurement – Suspension and Debarment Information on Federal Program: U.S. Department of Health COVID-19 Detection and Mitigation of COVID-19 in Confinement Facilities, federal assistance listing number 93.323. Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs. Statement of Condition: During our testing for procurement compliance, it was determined that the New York State Sheriffs’ Association, Inc. did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs. Questioned Cost: None Statement of Cause: Management was not aware of the requirement to review an entity’s status. Statement of Effect: The New York State Sheriffs’ Association, Inc. is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Association could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs. Repeat Finding: No Recommendation: We recommend management review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs. Views of the Responsible Officials and Planned Corrective Actions: Vendors will be reviewed and documented that they are not debarred, suspended, or otherwise excluded from participation in federal award programs by use of the System for Award Management (SAM), the Official U.S. Government system. [New procedure implemented] Perspective Information: There was one vendor in excess of the $25,000 threshold which was reviewed to determine eligibility for participation noting they are not debarred, suspended, or otherwise excluded from participation in federal award programs.