Corporación La Fondita de Jesús
Corrective Action Plan
December 27, 2024
Finding number: 2024-001
Federal program: 14.267 Continuum of Care
Category: Compliance/internal control
Condition: An immediate family member of the Executive Director was promoted to Director
of Services, and the safeguard me...
Corporación La Fondita de Jesús
Corrective Action Plan
December 27, 2024
Finding number: 2024-001
Federal program: 14.267 Continuum of Care
Category: Compliance/internal control
Condition: An immediate family member of the Executive Director was promoted to Director
of Services, and the safeguard measures established in the Conflict-of-Interest policy and the
new organizational protocol were not followed.
The following instances were noted:
• The Employment Agreement was signed exclusively by the Executive Director and the
Director of Services.
• The Reasonable Accommodation of the Supervisory Role of the Director of Services
Agreement was signed exclusively by the Executive Director and the Director of Services.
In addition, another immediate family member of the Director of Services was hired as a
professional contractor. At the time of the recruitment, the document establishing the
relationship was not signed. Subsequently, the referred document was signed, but it did not
specify the existing conflicts between the Director of Services and the Executive Director.
Views of responsible officials: Management agrees with the audit findings and is committed
to addressing the issues identified to ensure compliance with CFR 200.318, our Conflict-of-
Interest policy, and new organizational protocols. We would like to bring to your attention
that effective on November 30, 2024, the Executive Director resigned from his position with
Corporacion La Fondita de Jesus. We will review and revise our Conflict-of-Interest policy and
protocols to ensure they are comprehensive and clear. This includes detailing the steps to be
followed when hiring or promoting individuals with familial relationships within the
organization. We will establish an independent review and approval process for all
employment and promotion agreements involving immediate family members of senior
management. This process will include an additional review by a member of the executive
committee of the Board of Directors to ensure objectivity and compliance with policies. We
will review all contracts to ensure that they comply with the conflict-of-interest clause.
Names of the contact persons responsible for the corrective action plan: Geraldine Bayron,
Interim Executive Director, and Javier Fraguela, Board of Directors
Anticipated completion date: March 31, 2025