Corrective Action Plans

Regarding the debarment status, the Policy has been updated to include that and says : Compliance with this Policy. KHDA Management shall maintain oversight to ensure that contractors and vendors perform in accordance with the terms, conditions, and specifications of contracts or purchase orders. Violations of this policy may result in disciplinary action, up to and including termination. KHDA will hire a CPA firm to oversee this process.

Management response: Warren Easton is reviewing and updating the procurement section of the policy manual to explicitly include procedures for verifying the suspension and debarment status of all vendors and contractors receiving federal funds. Documentation of each vendor's verification will be maintained in procurement files. A printed or PDF record from SAM.gov showing the vendor's status will be retained as audit evidence.

THE EXECUTIVE DIRECTOR AND FINANCE OFFICER WILL IMPLEMENT A DEBARMENT CHECK WITH VENDORS WITH SIGNIFICANT AMOUNTS OF FEDERAL GRANT FUNDING THROUGHOUT THE YEAR TO ENSURE DEBARMENT STATUS. THIS WILL BE ADDED TO THE INTERNAL CONTROL POLICY

The College agrees that a checklist for procurement requirements related to suspension and debarment is needed. The College will review the procurement manual and update to ensure compliance.