You will want to contact a local Administrative Law Attorney - the reason is that they will have a better idea of who exactly to direct the complaint against than I can offer you in a "general information" forum.
As I noted above, the OCFS is not interpreting their code properly, but there isn't an administrative appeal process in place to deal with it.
Your remedy is to file a lawsuit against them for breach of the administrative procedure act - but this isn't going to compensate you for anything (I understand that money is a significant factor, and I don't want to send you off to spend a huge sum of money on a lawsuit that will not be concluded until after the 2 years has already passed).
The goal with hiring a local attorney is that hopefully they will already be in touch with (or know) the individuals at issue - you can improve your chances of finding the right attorney by screening them upfront - start by looking for administrative law attorneys (they do not even have to be in your same community - they can be anywhere in the state of NY - usually these attorneys/firms tend to be in the state capitol, so look in the Albany region)
When you contact the firm ask if they have recent work/experience with OCFS - this will let you know how good their familiarity/contact is with the agency.
You are then going to rely on that attorney to make a few phone calls or write a letter or two on your behalf. (This should limit how much is spent on legal fees).
Tell the attorney upfront how much you have available to spend.
(The state is not going to be liable to you for libel or any other defamation/interference with potential economic advantage claims).