CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Spokane Conservation District January 1, 2025 through December 31, 2025 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regula...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Spokane Conservation District January 1, 2025 through December 31, 2025 This schedule presents the corrective action planned by the District for findings reported 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: 2025-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal subrecipient monitoring and suspension and debarment requirements, and it did not comply with federal suspension and debarment requirements.Name, address, and telephone of District contact person: Cori Turntine, Operations Director 4422 E 8th Avenue, Spokane Valley, WA 99212 (509) 535-7274 Corrective action the auditee plans to take in response to the finding: The District concurs with Finding 2025-001. The District acknowledges that although staff performed searches of the Federal Audit Clearinghouse for both subrecipients and were aware of the suspension and debarment requirements, the District did not retain documentation demonstrating these verifications, as required by 2 CFR 200.303 and 2 CFR 200.332. The District has taken the following corrective action: Subrecipient Monitoring: District staff performed searches of the Federal Audit Clearinghouse for both subrecipients during the audit period; however, documentation of those searches was not retained. The District has since followed up in writing with both subrecipients and obtained written confirmation that neither subrecipient exceeded $1,000,000 in federal expenditures during fiscal year 2025 and that neither expects to exceed the single audit threshold in fiscal year 2026. This written correspondence is retained in the subaward files. Going forward, all subrecipient monitoring activities - including Federal Audit Clearinghouse searches, single audit determinations, follow-up on audit findings, and management decisions - will be documented and retained in each subaward file at the time the verification is performed. Suspension and Debarment: The District concurs that documentation was not retained for the suspension and debarment verification of the contractor paid $185,998 in federal funds. The contractor was subsequently verified as not suspended or debarred, and no further contracting activity occurred under the affected award. The District has implemented controls requiring verification of suspension and debarment status (via SAM.gov exclusion checks, written certification, or contract clause) before entering into any contract or purchase expected to equal or exceed $25,000, paid in whole or in part with federal funds, consistent with 2 CFR 200.214 and 2 CFR Part 180. Documentation of each verification is retained in the procurement file at the time of award. Project Management System: To provide sustained assurance and to address both components of this finding, the District is implementing a project management system with automated reminders and checklists covering the full life cycle of federal awards, subawards, and procurements. Training: Suspension and debarment and subrecipient monitoring requirements will be incorporated into the District's annual contract and procurement training for all relevant staff. Anticipated date to complete the corrective action: 12/31/2026