Condition: The Organization does not maintain formal written policies governing several key compliance areas required under Uniform Guidance, including financial management, procurement, conflict of interest, and travel costs. Management Response: Management concurs with the finding. The Organizatio...
Condition: The Organization does not maintain formal written policies governing several key compliance areas required under Uniform Guidance, including financial management, procurement, conflict of interest, and travel costs. Management Response: Management concurs with the finding. The Organization recognizes that it has historically relied on established practices and institutional knowledge rather than formally documented policies and procedures governing Federal award compliance. Management acknowledges that written policies are necessary to establish consistent expectations, clearly assign responsibilities, and strengthen internal controls over compliance with Uniform Guidance requirements. Planned Corrective Action: To address this finding, management will develop, approve, and implement formal written policies and procedures addressing significant Uniform Guidance compliance requirements applicable to the Organization’s Federal awards. The process will require: 1. The Organization to develop written policies and procedures addressing applicable Federal award compliance requirements, including financial management, procurement, conflict of interest, travel costs, and other significant areas applicable to the Organization’s Federal awards. 2. The policies and procedures to establish clear requirements for approvals, supporting documentation, record retention, responsible personnel, and compliance monitoring. 3. Management to review the policies and procedures to ensure they are consistent with applicable Uniform Guidance requirements, Federal award terms and conditions, and the Organization’s current practices. 4. The policies and procedures to be formally approved by management and communicated to employees and other individuals responsible for administering or expending Federal award funds. 5. Appropriate training or guidance to be provided to personnel responsible for Federal award activities to promote consistent application of the policies and procedures. 6. Management to periodically review the policies and procedures and update them, as necessary, when Federal regulations, Uniform Guidance requirements, Federal award terms and conditions, or organizational practices change. The Organization will also assess staffing responsibilities to ensure that appropriate responsibility for implementing, maintaining, and monitoring compliance with the written policies is assigned despite limited personnel. Responsible Party: Robert L. Grossman, Managing Director Anticipated Completion Date: August 28, 2026