Suspension and Debarment: Ensure Recipients of Federal Monies are not Suspended or Debarred. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to ensure they are not entering into a covered transaction with another entity or individual that has been debarred, suspended, or otherwise excluded from receiving federal funds. The Organization did not have policies and procedures to ensure compliance with this federal requirement throughout the entire year. Prior Year Audit Finding: N/A Cause and Effect: The Organization did not have suspension and debarment policies and procedures in place for the entire year to ensure compliance with federal guidelines. This could have resulted in possible federal dollars being paid to a suspended or debarred entity or individual and resulted in the potential loss of funding. Context: The audit finding represents a systemic problem. No instances of noncompliance were noted. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: The Organization has experienced an increase in federal funding across multiple different programs during the current year. As the funding sources have increased and are likely to continue, it is imperative that the Organization implement and maintain policies and procedures to ensure compliance with all federal guidelines. Due to the increase in funding and changes in operations and programs, the Organization did revise its overall financial policies and procedures in August 2022, and specifically implemented a verification policy to ensure recipients of federal funds are eligible to receive federal funds. To maintain compliance with this federal regulation and all other federal regulations, we recommend for the policies and procedures to be reviewed on a regular basis to ensure there are no changes in federal requirements and that the policies and procedures are still adequate for the staffing and operations of the Organization. Management?s Response: Beginning in August 2022, we implemented a verification policy to ensure that recipients of federal funds are eligible to receive federal funds. We also checked our payees for the previous three years to ensure that no previous recipients were disbarred. We have also included this verification policy in our newest version of the financial policies.
Procurement: Implement Procurement Policy Guidelines. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to have written procedures for procurement transactions that ensure clear and accurate description of the technical requirements for material, products, or services. The procurement policy must define the number of quotes to obtain and the manner in which quotes should be obtained. Federal guidelines define three types of procurements: micro-purchases, items less than $10,000 which require no extensive documentation of procurement history; small purchases, items not to exceed $250,000 which require price and rate quotes from multiple qualified sources, and purchases greater than $250,000, for which the Organization must obtain sealed bids or competitive proposals. The Organization?s procurement policy does not require extensive documentation history for any purchases. Prior Year Audit Finding: N/A Cause and Effect: The Organization?s procurement policy does not comply with the applicable Federal requirements to provide open and full competition, nor does it address the requirements of the micro-purchase threshold or small purchase procedures. This has resulted in improper supporting documentation for all purchases greater than the micro-purchase threshold of $10,000. Context: For the year ended December 31, 2022, there was one procurement identified that exceeded the micro-purchase threshold totaling $24,533. The audit finding represents a systemic problem. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: We recommend the Organization update the procurement policy to be in compliance with the procurement Uniform Guidance guidelines. Management?s Response: Management is in agreement that the Organization?s policy does not properly reflect the Uniform Guidelines standards for procurement. Management will review the Organization?s policies and revise them as soon as possible to be in accordance with federal regulations.
Suspension and Debarment: Ensure Recipients of Federal Monies are not Suspended or Debarred. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to ensure they are not entering into a covered transaction with another entity or individual that has been debarred, suspended, or otherwise excluded from receiving federal funds. The Organization did not have policies and procedures to ensure compliance with this federal requirement throughout the entire year. Prior Year Audit Finding: N/A Cause and Effect: The Organization did not have suspension and debarment policies and procedures in place for the entire year to ensure compliance with federal guidelines. This could have resulted in possible federal dollars being paid to a suspended or debarred entity or individual and resulted in the potential loss of funding. Context: The audit finding represents a systemic problem. No instances of noncompliance were noted. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: The Organization has experienced an increase in federal funding across multiple different programs during the current year. As the funding sources have increased and are likely to continue, it is imperative that the Organization implement and maintain policies and procedures to ensure compliance with all federal guidelines. Due to the increase in funding and changes in operations and programs, the Organization did revise its overall financial policies and procedures in August 2022, and specifically implemented a verification policy to ensure recipients of federal funds are eligible to receive federal funds. To maintain compliance with this federal regulation and all other federal regulations, we recommend for the policies and procedures to be reviewed on a regular basis to ensure there are no changes in federal requirements and that the policies and procedures are still adequate for the staffing and operations of the Organization. Management?s Response: Beginning in August 2022, we implemented a verification policy to ensure that recipients of federal funds are eligible to receive federal funds. We also checked our payees for the previous three years to ensure that no previous recipients were disbarred. We have also included this verification policy in our newest version of the financial policies.
Procurement: Implement Procurement Policy Guidelines. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to have written procedures for procurement transactions that ensure clear and accurate description of the technical requirements for material, products, or services. The procurement policy must define the number of quotes to obtain and the manner in which quotes should be obtained. Federal guidelines define three types of procurements: micro-purchases, items less than $10,000 which require no extensive documentation of procurement history; small purchases, items not to exceed $250,000 which require price and rate quotes from multiple qualified sources, and purchases greater than $250,000, for which the Organization must obtain sealed bids or competitive proposals. The Organization?s procurement policy does not require extensive documentation history for any purchases. Prior Year Audit Finding: N/A Cause and Effect: The Organization?s procurement policy does not comply with the applicable Federal requirements to provide open and full competition, nor does it address the requirements of the micro-purchase threshold or small purchase procedures. This has resulted in improper supporting documentation for all purchases greater than the micro-purchase threshold of $10,000. Context: For the year ended December 31, 2022, there was one procurement identified that exceeded the micro-purchase threshold totaling $24,533. The audit finding represents a systemic problem. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: We recommend the Organization update the procurement policy to be in compliance with the procurement Uniform Guidance guidelines. Management?s Response: Management is in agreement that the Organization?s policy does not properly reflect the Uniform Guidelines standards for procurement. Management will review the Organization?s policies and revise them as soon as possible to be in accordance with federal regulations.
Suspension and Debarment: Ensure Recipients of Federal Monies are not Suspended or Debarred. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to ensure they are not entering into a covered transaction with another entity or individual that has been debarred, suspended, or otherwise excluded from receiving federal funds. The Organization did not have policies and procedures to ensure compliance with this federal requirement throughout the entire year. Prior Year Audit Finding: N/A Cause and Effect: The Organization did not have suspension and debarment policies and procedures in place for the entire year to ensure compliance with federal guidelines. This could have resulted in possible federal dollars being paid to a suspended or debarred entity or individual and resulted in the potential loss of funding. Context: The audit finding represents a systemic problem. No instances of noncompliance were noted. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: The Organization has experienced an increase in federal funding across multiple different programs during the current year. As the funding sources have increased and are likely to continue, it is imperative that the Organization implement and maintain policies and procedures to ensure compliance with all federal guidelines. Due to the increase in funding and changes in operations and programs, the Organization did revise its overall financial policies and procedures in August 2022, and specifically implemented a verification policy to ensure recipients of federal funds are eligible to receive federal funds. To maintain compliance with this federal regulation and all other federal regulations, we recommend for the policies and procedures to be reviewed on a regular basis to ensure there are no changes in federal requirements and that the policies and procedures are still adequate for the staffing and operations of the Organization. Management?s Response: Beginning in August 2022, we implemented a verification policy to ensure that recipients of federal funds are eligible to receive federal funds. We also checked our payees for the previous three years to ensure that no previous recipients were disbarred. We have also included this verification policy in our newest version of the financial policies.
Procurement: Implement Procurement Policy Guidelines. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to have written procedures for procurement transactions that ensure clear and accurate description of the technical requirements for material, products, or services. The procurement policy must define the number of quotes to obtain and the manner in which quotes should be obtained. Federal guidelines define three types of procurements: micro-purchases, items less than $10,000 which require no extensive documentation of procurement history; small purchases, items not to exceed $250,000 which require price and rate quotes from multiple qualified sources, and purchases greater than $250,000, for which the Organization must obtain sealed bids or competitive proposals. The Organization?s procurement policy does not require extensive documentation history for any purchases. Prior Year Audit Finding: N/A Cause and Effect: The Organization?s procurement policy does not comply with the applicable Federal requirements to provide open and full competition, nor does it address the requirements of the micro-purchase threshold or small purchase procedures. This has resulted in improper supporting documentation for all purchases greater than the micro-purchase threshold of $10,000. Context: For the year ended December 31, 2022, there was one procurement identified that exceeded the micro-purchase threshold totaling $24,533. The audit finding represents a systemic problem. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: We recommend the Organization update the procurement policy to be in compliance with the procurement Uniform Guidance guidelines. Management?s Response: Management is in agreement that the Organization?s policy does not properly reflect the Uniform Guidelines standards for procurement. Management will review the Organization?s policies and revise them as soon as possible to be in accordance with federal regulations.
Suspension and Debarment: Ensure Recipients of Federal Monies are not Suspended or Debarred. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to ensure they are not entering into a covered transaction with another entity or individual that has been debarred, suspended, or otherwise excluded from receiving federal funds. The Organization did not have policies and procedures to ensure compliance with this federal requirement throughout the entire year. Prior Year Audit Finding: N/A Cause and Effect: The Organization did not have suspension and debarment policies and procedures in place for the entire year to ensure compliance with federal guidelines. This could have resulted in possible federal dollars being paid to a suspended or debarred entity or individual and resulted in the potential loss of funding. Context: The audit finding represents a systemic problem. No instances of noncompliance were noted. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: The Organization has experienced an increase in federal funding across multiple different programs during the current year. As the funding sources have increased and are likely to continue, it is imperative that the Organization implement and maintain policies and procedures to ensure compliance with all federal guidelines. Due to the increase in funding and changes in operations and programs, the Organization did revise its overall financial policies and procedures in August 2022, and specifically implemented a verification policy to ensure recipients of federal funds are eligible to receive federal funds. To maintain compliance with this federal regulation and all other federal regulations, we recommend for the policies and procedures to be reviewed on a regular basis to ensure there are no changes in federal requirements and that the policies and procedures are still adequate for the staffing and operations of the Organization. Management?s Response: Beginning in August 2022, we implemented a verification policy to ensure that recipients of federal funds are eligible to receive federal funds. We also checked our payees for the previous three years to ensure that no previous recipients were disbarred. We have also included this verification policy in our newest version of the financial policies.
Suspension and Debarment: Ensure Recipients of Federal Monies are not Suspended or Debarred. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to ensure they are not entering into a covered transaction with another entity or individual that has been debarred, suspended, or otherwise excluded from receiving federal funds. The Organization did not have policies and procedures to ensure compliance with this federal requirement throughout the entire year. Prior Year Audit Finding: N/A Cause and Effect: The Organization did not have suspension and debarment policies and procedures in place for the entire year to ensure compliance with federal guidelines. This could have resulted in possible federal dollars being paid to a suspended or debarred entity or individual and resulted in the potential loss of funding. Context: The audit finding represents a systemic problem. No instances of noncompliance were noted. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: The Organization has experienced an increase in federal funding across multiple different programs during the current year. As the funding sources have increased and are likely to continue, it is imperative that the Organization implement and maintain policies and procedures to ensure compliance with all federal guidelines. Due to the increase in funding and changes in operations and programs, the Organization did revise its overall financial policies and procedures in August 2022, and specifically implemented a verification policy to ensure recipients of federal funds are eligible to receive federal funds. To maintain compliance with this federal regulation and all other federal regulations, we recommend for the policies and procedures to be reviewed on a regular basis to ensure there are no changes in federal requirements and that the policies and procedures are still adequate for the staffing and operations of the Organization. Management?s Response: Beginning in August 2022, we implemented a verification policy to ensure that recipients of federal funds are eligible to receive federal funds. We also checked our payees for the previous three years to ensure that no previous recipients were disbarred. We have also included this verification policy in our newest version of the financial policies.
Procurement: Implement Procurement Policy Guidelines. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to have written procedures for procurement transactions that ensure clear and accurate description of the technical requirements for material, products, or services. The procurement policy must define the number of quotes to obtain and the manner in which quotes should be obtained. Federal guidelines define three types of procurements: micro-purchases, items less than $10,000 which require no extensive documentation of procurement history; small purchases, items not to exceed $250,000 which require price and rate quotes from multiple qualified sources, and purchases greater than $250,000, for which the Organization must obtain sealed bids or competitive proposals. The Organization?s procurement policy does not require extensive documentation history for any purchases. Prior Year Audit Finding: N/A Cause and Effect: The Organization?s procurement policy does not comply with the applicable Federal requirements to provide open and full competition, nor does it address the requirements of the micro-purchase threshold or small purchase procedures. This has resulted in improper supporting documentation for all purchases greater than the micro-purchase threshold of $10,000. Context: For the year ended December 31, 2022, there was one procurement identified that exceeded the micro-purchase threshold totaling $24,533. The audit finding represents a systemic problem. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: We recommend the Organization update the procurement policy to be in compliance with the procurement Uniform Guidance guidelines. Management?s Response: Management is in agreement that the Organization?s policy does not properly reflect the Uniform Guidelines standards for procurement. Management will review the Organization?s policies and revise them as soon as possible to be in accordance with federal regulations.
Suspension and Debarment: Ensure Recipients of Federal Monies are not Suspended or Debarred. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to ensure they are not entering into a covered transaction with another entity or individual that has been debarred, suspended, or otherwise excluded from receiving federal funds. The Organization did not have policies and procedures to ensure compliance with this federal requirement throughout the entire year. Prior Year Audit Finding: N/A Cause and Effect: The Organization did not have suspension and debarment policies and procedures in place for the entire year to ensure compliance with federal guidelines. This could have resulted in possible federal dollars being paid to a suspended or debarred entity or individual and resulted in the potential loss of funding. Context: The audit finding represents a systemic problem. No instances of noncompliance were noted. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: The Organization has experienced an increase in federal funding across multiple different programs during the current year. As the funding sources have increased and are likely to continue, it is imperative that the Organization implement and maintain policies and procedures to ensure compliance with all federal guidelines. Due to the increase in funding and changes in operations and programs, the Organization did revise its overall financial policies and procedures in August 2022, and specifically implemented a verification policy to ensure recipients of federal funds are eligible to receive federal funds. To maintain compliance with this federal regulation and all other federal regulations, we recommend for the policies and procedures to be reviewed on a regular basis to ensure there are no changes in federal requirements and that the policies and procedures are still adequate for the staffing and operations of the Organization. Management?s Response: Beginning in August 2022, we implemented a verification policy to ensure that recipients of federal funds are eligible to receive federal funds. We also checked our payees for the previous three years to ensure that no previous recipients were disbarred. We have also included this verification policy in our newest version of the financial policies.
Procurement: Implement Procurement Policy Guidelines. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to have written procedures for procurement transactions that ensure clear and accurate description of the technical requirements for material, products, or services. The procurement policy must define the number of quotes to obtain and the manner in which quotes should be obtained. Federal guidelines define three types of procurements: micro-purchases, items less than $10,000 which require no extensive documentation of procurement history; small purchases, items not to exceed $250,000 which require price and rate quotes from multiple qualified sources, and purchases greater than $250,000, for which the Organization must obtain sealed bids or competitive proposals. The Organization?s procurement policy does not require extensive documentation history for any purchases. Prior Year Audit Finding: N/A Cause and Effect: The Organization?s procurement policy does not comply with the applicable Federal requirements to provide open and full competition, nor does it address the requirements of the micro-purchase threshold or small purchase procedures. This has resulted in improper supporting documentation for all purchases greater than the micro-purchase threshold of $10,000. Context: For the year ended December 31, 2022, there was one procurement identified that exceeded the micro-purchase threshold totaling $24,533. The audit finding represents a systemic problem. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: We recommend the Organization update the procurement policy to be in compliance with the procurement Uniform Guidance guidelines. Management?s Response: Management is in agreement that the Organization?s policy does not properly reflect the Uniform Guidelines standards for procurement. Management will review the Organization?s policies and revise them as soon as possible to be in accordance with federal regulations.
Suspension and Debarment: Ensure Recipients of Federal Monies are not Suspended or Debarred. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to ensure they are not entering into a covered transaction with another entity or individual that has been debarred, suspended, or otherwise excluded from receiving federal funds. The Organization did not have policies and procedures to ensure compliance with this federal requirement throughout the entire year. Prior Year Audit Finding: N/A Cause and Effect: The Organization did not have suspension and debarment policies and procedures in place for the entire year to ensure compliance with federal guidelines. This could have resulted in possible federal dollars being paid to a suspended or debarred entity or individual and resulted in the potential loss of funding. Context: The audit finding represents a systemic problem. No instances of noncompliance were noted. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: The Organization has experienced an increase in federal funding across multiple different programs during the current year. As the funding sources have increased and are likely to continue, it is imperative that the Organization implement and maintain policies and procedures to ensure compliance with all federal guidelines. Due to the increase in funding and changes in operations and programs, the Organization did revise its overall financial policies and procedures in August 2022, and specifically implemented a verification policy to ensure recipients of federal funds are eligible to receive federal funds. To maintain compliance with this federal regulation and all other federal regulations, we recommend for the policies and procedures to be reviewed on a regular basis to ensure there are no changes in federal requirements and that the policies and procedures are still adequate for the staffing and operations of the Organization. Management?s Response: Beginning in August 2022, we implemented a verification policy to ensure that recipients of federal funds are eligible to receive federal funds. We also checked our payees for the previous three years to ensure that no previous recipients were disbarred. We have also included this verification policy in our newest version of the financial policies.
Procurement: Implement Procurement Policy Guidelines. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to have written procedures for procurement transactions that ensure clear and accurate description of the technical requirements for material, products, or services. The procurement policy must define the number of quotes to obtain and the manner in which quotes should be obtained. Federal guidelines define three types of procurements: micro-purchases, items less than $10,000 which require no extensive documentation of procurement history; small purchases, items not to exceed $250,000 which require price and rate quotes from multiple qualified sources, and purchases greater than $250,000, for which the Organization must obtain sealed bids or competitive proposals. The Organization?s procurement policy does not require extensive documentation history for any purchases. Prior Year Audit Finding: N/A Cause and Effect: The Organization?s procurement policy does not comply with the applicable Federal requirements to provide open and full competition, nor does it address the requirements of the micro-purchase threshold or small purchase procedures. This has resulted in improper supporting documentation for all purchases greater than the micro-purchase threshold of $10,000. Context: For the year ended December 31, 2022, there was one procurement identified that exceeded the micro-purchase threshold totaling $24,533. The audit finding represents a systemic problem. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: We recommend the Organization update the procurement policy to be in compliance with the procurement Uniform Guidance guidelines. Management?s Response: Management is in agreement that the Organization?s policy does not properly reflect the Uniform Guidelines standards for procurement. Management will review the Organization?s policies and revise them as soon as possible to be in accordance with federal regulations.
Suspension and Debarment: Ensure Recipients of Federal Monies are not Suspended or Debarred. Federal Program Information: Sustainable Agriculture Research and Education Program (Assistance Listing 10.215), Food Insecurity Nutrition Incentive Grants Program (Assistance Listing 10.331), and Soil and Water Conservation Program (Assistance Listing 10.902). Condition and Criteria: Federal guidelines require all entities to ensure they are not entering into a covered transaction with another entity or individual that has been debarred, suspended, or otherwise excluded from receiving federal funds. The Organization did not have policies and procedures to ensure compliance with this federal requirement throughout the entire year. Prior Year Audit Finding: N/A Cause and Effect: The Organization did not have suspension and debarment policies and procedures in place for the entire year to ensure compliance with federal guidelines. This could have resulted in possible federal dollars being paid to a suspended or debarred entity or individual and resulted in the potential loss of funding. Context: The audit finding represents a systemic problem. No instances of noncompliance were noted. The sampling was a statistically valid sample. Questioned Costs: None. Recommendation: The Organization has experienced an increase in federal funding across multiple different programs during the current year. As the funding sources have increased and are likely to continue, it is imperative that the Organization implement and maintain policies and procedures to ensure compliance with all federal guidelines. Due to the increase in funding and changes in operations and programs, the Organization did revise its overall financial policies and procedures in August 2022, and specifically implemented a verification policy to ensure recipients of federal funds are eligible to receive federal funds. To maintain compliance with this federal regulation and all other federal regulations, we recommend for the policies and procedures to be reviewed on a regular basis to ensure there are no changes in federal requirements and that the policies and procedures are still adequate for the staffing and operations of the Organization. Management?s Response: Beginning in August 2022, we implemented a verification policy to ensure that recipients of federal funds are eligible to receive federal funds. We also checked our payees for the previous three years to ensure that no previous recipients were disbarred. We have also included this verification policy in our newest version of the financial policies.