Type of Finding: Material Weakness in Internal Control Over Compliance – Suspension and Debarment; Other Matter Recommendation: We recommend that the Organization implement procedures to verify vendors against applicable suspension and debarment requirements prior to the disbursement of funds and re...
Type of Finding: Material Weakness in Internal Control Over Compliance – Suspension and Debarment; Other Matter Recommendation: We recommend that the Organization implement procedures to verify vendors against applicable suspension and debarment requirements prior to the disbursement of funds and retain documentation evidencing the verification performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding is a repeat of prior-year finding 2024-001. The vendor selections identified in the auditor's test sample were engaged prior to November 2025, before the Organization's enhanced verification procedures were implemented. Building on the corrective action plan submitted for fiscal year 2024, the Organization has taken the following corrective actions: ● Beginning in November 2025, the Organization has required completion of a standardized Vendor Eligibility & Compliance Review Form, including documented SAM.gov verification, before engaging any vendor that will be paid in whole or in part with federal funds and before any federal funds are disbursed to that vendor. This procedure continues to be used for all applicable vendors. ● The Organization's Procurement and Vendor Management Policy was formally updated, effective March 3, 2026, as part of the corrective action plan submitted to and approved by the U.S. Department of Labor. The policy explicitly requires suspension and debarment verification, in accordance with 2 CFR 200.214 and 2 CFR Part 180, before a vendor is engaged or paid with federal funds, memorializing the procedures in practice since November 2025. ● All staff involved in procurement have been trained on the updated policy and documentation requirements. ● The Operations Director performs quarterly monitoring of vendor files to confirm that vendor verification procedures are consistently followed and documented. This monitoring has been implemented and is continuing. These controls have been in practice since November 2025 and were formally documented in policy effective March 3, 2026. They continue to be monitored on an ongoing basis to prevent recurrence. The vendor selections cited in the current year finding predate the November 2025 implementation. Name(s) of contact person(s) responsible for corrective action: Cory Finley, Operations Director, with oversight by Brandi Jahnke, Chief Executive Officer Planned completion date for corrective action plan: Implemented in practice as of November 2025 and formalized in written policy effective March 3, 2026. Quarterly monitoring by the Operations Director is ongoing.