CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Cowlitz-Wahkiakum Council of Governments January 1, 2024 through December 31, 2024 This schedule presents the corrective action the Council is planning to take for findings included in this report in accordance with Title 2 U.S. Cod...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Cowlitz-Wahkiakum Council of Governments January 1, 2024 through December 31, 2024 This schedule presents the corrective action the Council is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-002 Finding caption: The Council did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of Council contact person: William A. Fashing, Executive Director / Anisa Kisamore, Administrative Director Cowlitz-Wahkiakum Council of Governments PO Box 128, Kelso, WA 98626 (360) 577-3041 Corrective action the auditee plans to take in response to the finding: The Council of Governments has a process to verify the suspension and debarment status of contractors paid above $25,000. The Council followed this process as usual, which includes not only checking with SAM.gov but also with state listings as well, and felt at that time that it had properly documented and ensured that the contractor hired was not debarred or suspended before commencing with a contractual agreement. These documents were provided to the auditing team upon request. During the audit process, however, the reviewing auditor discovered that though the permissible SAM.gov documentation included both the name and UBI number, the combination of a typo in the contractor’s business name and the choice of searching for “all” words (system default) versus changing to “any” words returned a false narrative. Thus, the determination that the Council did not properly verify the contractor’s status within the acceptable forms of documents. To ensure that the Council no longer relies on just one level of verification and shores up effective controls, the Council will immediately implement two (2) additional processes into its contractor procurement policy. Not only will staff continue to verify contractors’ status through SAM.gov and state listings, but the Council will 1) require all contractors to submit a written certification prior to contractual negotiations and 2) request the agency’s attorney to draft a debarment and suspension clause that will be added to all contract templates and future agreements. Anticipated date to complete the corrective action: Immediately