Views of Responsible Officials and Planned Corrective Action The Organization understands the criteria cited re: Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), §200.334, requiring “Fina...
Views of Responsible Officials and Planned Corrective Action The Organization understands the criteria cited re: Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), §200.334, requiring “Financial records, supporting documents, statistical records, and all other non-Federal records must be retained for a period of three years from the date of submission of the final expenditure report…”, and recommendation made. However, because two programs are listed U.S. Department of Education and the U.S. Department of Health and Human Services, the Organization will work with the auditors to: A. Better understand the findings (i.e., inconsistent document retention substantiating contractor performance of services) identified by the field work and expenditure and contractor testing, as it relates to which program, and which subrecipient contractor the findings relate to; B. Clarify the specific source and subcontractor awarding and payment criteria as noted in the Organization’s award and sub-award criteria, and subsequently reflected in the subcontractor contract(s); C. Analyze the findings to identify root causes and/or conditions in related contract monitoring processes that resulted in inconsistent document retention practices; and D. Address and implement corrective actions through identified needs (e.g., policy development and implementation, contract monitoring processes and procedures). The Organization will prioritize the above with the auditors as soon as possible, so the appropriate corrective actions can be addressed.