Management Response and Planned Corrective Action 1. While the current Internal Controls Manual allows for certain expenditures to be made with verbal and/or written approval from the Executive Director, the control does not state a dollar amount or specific circumstance for verbal approval and the...
Management Response and Planned Corrective Action 1. While the current Internal Controls Manual allows for certain expenditures to be made with verbal and/or written approval from the Executive Director, the control does not state a dollar amount or specific circumstance for verbal approval and therefore the control has been clarified as follows: All funds to be expended must be approved by the Executive Director, either verbally or in writing, prior to the expenditure. Program staff may then request that the FA, OM or Administrative Associate purchase the needed expense either by debit card or credit card or produce a check for the ED?s signature. All requests for purchase must follow the same backup paperwork procedures outlined in the AP Procedures section. For all routine essential office supply individual item purchases $250 and under, the OM or FA has approval to make these purchases without ED verbal or written approval prior to the expenditure. All expenditures for individual items above $250 must be verbally approved by the ED prior to purchase and documented via email which then should be attached to the purchase documentation. Purchases $1,500 and above should follow the procurement policy outlined below in Control No. 21. In addition, the procurement control has been clarified with updated language as follows: For goods and services $1,499 and under, Executive Director approval is required as per the purchase policy above referenced in Control No. 17. 2. NBCC maintains an onboarding process and checklist which includes the completion of the I-9 for each employee. This process is strictly followed. The three employees identified during the testing that lacked a completed I-9 on file were for one employee who was hired during the initial period of the COVID lockdown when all processes were significantly impacted by the initial COVID quarantine, and the remaining two were onboarded by a staff member serving temporarily in the human resources position after the exiting human resources staff member did not return from a medical leave of absence. All current staff have completed I-9?s on file and there is every expectation that this control will continue to be enforced. As an additional guarantee of having a completed I-9 in place, NBCC has asked our external accounting firm, Vista Financial, to create an additional control where a new employee is not onboarded into Quickbooks for payroll without the completed I-9.