2024-001 - (Noncompliance) Uniform Guidance Written Policies/Procedures
Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758
Condition/Context: While the Organi...
2024-001 - (Noncompliance) Uniform Guidance Written Policies/Procedures
Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758
Condition/Context: While the Organization has informal policies and procedures surrounding the administration of its federal programs, these policies and procedures have not been formally documented to ensure compliance with the areas of allowability of costs, cash management, procurement, travel, conflict of interest or subrecipient monitoring as required under the Uniform Guidance.
Corrective Action Plan:
To address this finding and strengthen our internal controls and compliance framework, CCAP will be implementing the following corrective actions:
1. Policy Development and Documentation:
o We will be initiating a project to develop and formalize comprehensive written policies and procedures in the following required areas:
Allowability of Costs (2 CFR §200.403–§200.405)
Cash Management (2 CFR §200.305)
Procurement Standards (2 CFR §200.317–§200.326)
Travel Costs (2 CFR §200.474)
Conflict of Interest (2 CFR §200.112)
Subrecipient Monitoring (2 CFR §200.331–§200.333)
o These policies will reference relevant Uniform Guidance sections and incorporate internal controls, approval processes, and documentation standards.
2. Internal Review and Approval:
o Draft policies will be reviewed by senior leadership, legal counsel (if necessary), and the finance and grants teams to ensure alignment with regulatory requirements and operational realities.
3. Training and Dissemination:
o Once finalized, all relevant staff (including program managers, finance personnel, and procurement staff) will receive training on the new policies.
o Policies will be made available on CCAP’s intranet.
4. Ongoing Maintenance and Review:
o A process will be established for annual review and update of these policies to incorporate regulatory changes and feedback from internal audits or grantor reviews.