IX. Federal Grants

Guide to Financial Operations

IX.10.B Federal Treasury Offset Program (TOP) Background

IX. Federal Grants
Guide to Financial Operations

All New York State agencies are required to provide the state's Federal Employer Identification Number (FEIN) (also known as the Taxpayer Identification Number or TIN) when dealing with the federal government. This number is used for billing purposes, grant award applications and drawdowns of federal grant funds from the Department of Treasury.

The Department of Treasury’s Financial Management Service established a centralized process called the “Treasury Offset Program” (TOP) that matches federal payments to New York State against debts owed by any state agency to the federal government. Billing records for services provided by federal agencies to all state agencies contain the same FEIN or TIN that is used to draw down federal grant award funds. When a TOP match occurs, the payment is “offset” against the state’s request for federal grant funds, thereby reducing that day’s federal grant payment without regard to which state agency is drawing federal funds.

Department of Treasury offsets have been taken against federal grant award drawdowns needed to finance important and critical agency programs because a debt was owed to the federal government by a second (uninvolved) state agency. Since the drawdown was reduced by the amount of the offset, funds to finance state payments are insufficient to reimburse the state for the vouchers that were paid.

When the offset is taken, a notice is sent to the debtor state agency but no notice is provided to the Office of the State Comptroller (OSC) or the agency whose drawdown was reduced. For accounts that are cash managed by OSC, when an offset occurs, OSC is notified by the Department of Taxation and Finance’s Treasury staff. For accounts that are not cash managed by OSC, the agency will be contacted by Taxation and Finance’s Treasury staff.

On a monthly basis, the Department of the Treasury sends OSC a report detailing all offsets from the previous month. For OSC-managed accounts, once the debtor is identified, OSC works with the debtor agency to reverse the impact of the offset. This will involve a revenue transfer between the two agencies whose accounts are impacted. For non-OSC-managed accounts, OSC will notify the impacted agency who the debtor agency is. Those two agencies should then work together to reverse the impact of the offset. This will also involve a revenue transfer between the two agencies.

Guide to Financial Operations

REV. 07/31/2015