Audit 379422

Criteria: In accordance with 2 CFR Section 200.319(c) the Organization must have written procedures for procurement transactions. Condition: The Organization does not have a written procurement policy as required by the Uniform Guidance. Context: During the audit it was noted that the Organization lacked a documented procurement policy. Cause: The Organization did not have an adequate procurement policy Questioned Costs: None Effect: An important component of internal controls and compliance is the existence of operating policies and procedures. Without those, there is a higher risk of noncompliance with program requirements. Repeat Finding: No Recommendation: Management should determine the scope of written policies and procedures to comply with the Uniform Guidance. Views of Responsible Officials (unaudited): The Organization agrees with the finding and recommendation. The Board of Directors of the Organization will develop policies and procedures to ensure they meet the Uniform Guidance Requirements.

Criteria: The Uniform Guidance (2 CFR 200.213) requires non-federal entities to ensure that federal funds are not awarded to or expended with parties that are suspended, debarred, or otherwise excluded. This requirement can be satisfied by obtaining a vendor certification or by checking the SAM.gov system prior to entering into covered transaction. Condition: We noted that the Organization did not perform or document required suspension and debarment checks for certain vendors and contractors paid with federal funds. The Organization did not obtain or retain evidence, such as a certification from the vendor or verification from the System for Award Management (SAM), to ensure the vendors were not suspended, debarred, or otherwise excluded from federal programs. Context: The Organization did not perform the suspension and debarment check. Cause: The Organization did not have an adequate procedures in place to ensure that suspension and debarment checks were consistently performed and documented. Questioned Costs: None Effect: Without performing suspension and debarment checks, the Organization risks expending federal funds on ineligible vendors, which could result in questioned costs and potential repayment of federal funds. Repeat Finding: No Recommendation: We recommend that the Organization implement procedures to ensure suspension and debarment check are performed for all covered transactions and that evidence of such checks is retained in the procurrent files. Views of Responsible Officials (unaudited): The Organization agrees with the finding and recommendation. The Board of Directors of the Organization will develop policies and procedures to ensure they meet the Uniform Guidance Requirements.

Criteria: In accordance with 2 CFR Section 200.517(c) the Organization must keep and make audit documentation available for review. Condition: The Organization does not have all supporting documentation requested as required by the Uniform Guidance. Context: During the audit it was noted that the Organization lacked supporting documentation. The Organization did not have documentation for the 23 out of 35 tested samples. Cause: The Organization did not have adequate supporting documentation. Questioned Costs: None Effect: The absence of required documentation may result in noncompliance with program requirements and expose the Organization to reputational risks. Repeat Finding: No Recommendation: We recommend that management reinforce training for all relevant documentation requirements. Procedures should be strengthened to ensure that all files include complete and accurate documentation. Views of Responsible Officials (unaudited): The Organization will develop a procurement and payment procedure to ensure all proper supporting documentation is obtained prior to the check disbursement.