Corrective Action Plans

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The Management Agent will determine that the Project will have proper documentation for small purchases by having price or rate quotations from an adequate number of qualified sources.
The Management Agent will determine that the Project will have proper documentation for small purchases by having price or rate quotations from an adequate number of qualified sources.
This was oversight by the Management Agent. The Project has worker compensation insurance for the current year ending December 31, 2023 for the coverage period of 1/23/2023 to 1/19/2024.
This was oversight by the Management Agent. The Project has worker compensation insurance for the current year ending December 31, 2023 for the coverage period of 1/23/2023 to 1/19/2024.
The Project will have procedures in place to complete Income Verification for Form HUD-50059 accurately.
The Project will have procedures in place to complete Income Verification for Form HUD-50059 accurately.
The Project will have procedures in place to follow HUD directives in obtaining the EIV within 90 days of move-in and/or recertification date.
The Project will have procedures in place to follow HUD directives in obtaining the EIV within 90 days of move-in and/or recertification date.
The Corporation will contact PNC to establish a payment arrangement to pay off the line of credit with its funds.
The Corporation will contact PNC to establish a payment arrangement to pay off the line of credit with its funds.
The Management Agent will follow HUD Disbursements Control policies and procedures.
The Management Agent will follow HUD Disbursements Control policies and procedures.
The Management Agent will deposit the unfunded amount of $2,503.13 in the Replacement Reserve and contact the Mortgage Company to inform them that the monthly deposits to the Replacement Reserve should be $5,514.24. Also, The Management Agent will compute the total amount of unfunded Replacement Res...
The Management Agent will deposit the unfunded amount of $2,503.13 in the Replacement Reserve and contact the Mortgage Company to inform them that the monthly deposits to the Replacement Reserve should be $5,514.24. Also, The Management Agent will compute the total amount of unfunded Replacement Reserve for the period January 1, 2023 through May 1, 2024, and deposit the unfunded amount in the Replacement Reserve mortgage account.
The Management Agent will properly review all statement of financial position and statement of activity accounts to determine no material misstatements every month.
The Management Agent will properly review all statement of financial position and statement of activity accounts to determine no material misstatements every month.
CORRECTIVE ACTION PLAN: DEVELOP AND IMPLEMENT PROCEDURES TO MAINTAIN ADEQUATE ACCOUNTING RECORDS THAT ACCURATELY TRACK EXPENDITURES BY INDIVIDUAL FEDERAL PROGRAMS, ENSURING COMPLIANCE WITH REPORTING REQUIREMENTS AND TRANSPARANCY IN FUND UTILIZATION. 1. IMMEDIATE ASSESSMENT: CONDUCT A COMPREHENSIVE A...
CORRECTIVE ACTION PLAN: DEVELOP AND IMPLEMENT PROCEDURES TO MAINTAIN ADEQUATE ACCOUNTING RECORDS THAT ACCURATELY TRACK EXPENDITURES BY INDIVIDUAL FEDERAL PROGRAMS, ENSURING COMPLIANCE WITH REPORTING REQUIREMENTS AND TRANSPARANCY IN FUND UTILIZATION. 1. IMMEDIATE ASSESSMENT: CONDUCT A COMPREHENSIVE ASSESSMENT OF CURRENT ACCOUNTING PRACTICES AND RECORDS TO IDENTIFY DEFICIENCIES IN TRACKING EXPENDITURES BY FEDERAL PROGRAMS. DETERMINE THE SCOPE AND EXTENT OF INACCURACIES OR GAPS IN DOCUMENTATION. 2. ENGAGE ACCOUNTING EXPERTISE: ENGAGE A THIRD-PARTY CPA FIRM EXPERIENCED IN GOVERNMENTAL ACCOUNTING AND FEDERAL GRANT COMPLIANCE TO ASSIST IN RESOLVING THE ISSUE. 3. REVIEW FEDERAL PROGRAM REQUIREMENTS: REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM UNDER WHICH FUNDS ARE RECEIVED. IDENTIFY SPECIFIC REPORTING AND EXPENDITURE TRACKING REQUIREMENTS MANDATED BY EACH PROGRAM. 4. DEVELOP CHART OF ACCOUNTS: DEVELOP OR REVISE A DETAILED CHART OF ACCOUNTS THAT CLEARLY DISTINGUISHES EXPENDITURES BY EACH FEDERAL PROGRAM. ASSIGN UNIQUE CODES OR IDENTIFIERS TO TRANSACTIONS ASSOCIATED WITH EACH PROGRAM. 5. IMPLEMENT SEGREGATION OF EXPENDITURES: IMPLEMENT PROCEDURES TO SEGREGATE EXPENDITURES BY FEDERAL PROGRAM AT THE TIME OF RECORDING. ENSURE ALL TRANSACTIONS ARE ALLOCATED ACCURATELY TO THE APPROPRIATE PROGRAM BASED ON THE CHART OF ACCOUNTS. 6. DOCUMENT EXPENDITURE ALLOCATION: DOCUMENT THE ALLOCATION OF EXPENDITURES TO SPECIFIC FEDERAL PROGRAMS CLEARLY AND COMPREHENSIVELY. MAINTAIN SUPPORITNG DOCUMENTATION SUCH AS INVOICES, RECEIPTS, AND PAYROLL RECORDS THAT SUBSTANTIATE THE ALLOCATION. 7. TRAINING AND CAPACITY BUILDING: CONDUCT TRAINING SESSIONS FOR ACCOUNTING STAFF INVOLVED IN RECORDING AND REPORTING EXPENDITURES. TRAIN THEM ON THE NEW PROCEDURES, CHART OF ACCOUNTS, AND THE IMPORTANCE OF ACCURATELY TRACKING EXPENDITURES BY FEDERAL PROGRAM. 8. REGULAR RECONCILIATION AND REPORTING: IMPLEMENT A PROCESS FOR REGULAR RECONCILIATION OF EXPENDITURES WITH FEDERAL PROGRAM REQUIREMENTS. ENSURE RECONCILIATION IS PERFOMRED MONTHLY OR QUARTERLY TO IDENTIFY DISCREPANCIES PROMPTLY. 9. INTERNAL CONTROLS AND MONITORING: STREGTHEN INTERNAL CONTROLS TO PREVENT FUTURE INACCURACIES IN EXPENDITURE TRACKING. ASSIGN RESPONSIBILITY FOR OVERSIGHT AND MONITORING OF COMPLIANCE WITH THE NEW PROCEDURES. - TIMELINE FOR IMPLEMENTATION: ONGOING: MAINTAIN VIGILANCE OVER COMPLIANCE AND ADJUST AS NEEDED. - CONCLUSION: BY IMPLEMENTING THIS CORRECTIVE ACTION PLAN, WE AIM TO ESTABLISH ROBUST ACCOUNTING PRACTICES THAT ACCURATELY TRACK EXPENDITURES BY INDIVIDUAL FEDERAL PROGRAMS. THIS WILL ENSURE COMPLIANCE WITH REPORTING REQUIREMENTS, ENHANCE TRANSPARENCY IN FUND UTILIZATION, AND MITIGATE RISKS ASSOCIATED WITH INACCURATE FINANCIAL REPORTING. THIS PLAN OUTLINES OUR COMMITMENT TO ADDRESSING THE CURRENT DEFICIENCIES AND ESTABLISHING A SUSTAINABLE FRAMEWORK FOR FUTURE OPERATIONS. - RESPONSIBLE PARTY: KIMBERLEY CHAFFIN, EXECUTIVE DIRECTOR- DATE OF IMPLEMENTATION: OCTOBER 1, 2023.
Corrective action plan over control environment over lost revenue COVID – 19 – Provider Relief Funding (Assistance Listing #93.498) Recommendation: The Authority’s procedures for calculating lost revenues for the purposes of PRF reporting should be designed to ensure that audited year end numbers ar...
Corrective action plan over control environment over lost revenue COVID – 19 – Provider Relief Funding (Assistance Listing #93.498) Recommendation: The Authority’s procedures for calculating lost revenues for the purposes of PRF reporting should be designed to ensure that audited year end numbers are reported and/or tied back to amounts that are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: As of July 2024, there is no further lost revenue reporting that is required to be reported. Management will implement more robust internal controls in preparation for similar future grant reporting. For lost revenues that have been submitted for PRF that do not tie back to an audited financial statement, a reconciliation will be completed and documented. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 703-629-8155 Planned completion date for corrective action plan: July 31, 2024 and going forward.
Timely Preparation of Schedule of Expenditures of Federal Awards (SEFA) COVID – 19 – Provider Relief Funding (Assistance Listing #93.498) Recommendation: The Authority’s policy and procedure should be designed to ensure timely reporting as required by the Uniform Guidance. Explanation of disagreeme...
Timely Preparation of Schedule of Expenditures of Federal Awards (SEFA) COVID – 19 – Provider Relief Funding (Assistance Listing #93.498) Recommendation: The Authority’s policy and procedure should be designed to ensure timely reporting as required by the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management will enhance its procedures around the preparation of the SEFA to include a timely year-end reconciliation between the general ledger and all source documentation to ensure that all Federal expenditures are complete and accurately reported in the SEFA in fiscal 2024. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 703-629-8155 Planned completion date for corrective action plan: For the creation of the Schedule for FY2023.
2022-006 – Allowable Costs Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Immunization Cooperation Agreements Assistance Listing Number: 93.268 Federal Award Identification Number and Year: FY 21/22 and 22/23 Pass-Through Agency: Pennsylvania Department of Health...
2022-006 – Allowable Costs Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Immunization Cooperation Agreements Assistance Listing Number: 93.268 Federal Award Identification Number and Year: FY 21/22 and 22/23 Pass-Through Agency: Pennsylvania Department of Health Pass-Through Number(s): None Award Period: 1/1/2022 – 12/31/22 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition and Context: While testing allowable costs relating to payroll expenditures, sixteen out of forty transactions were identified that could not be appropriately re-calculated per the amount that was charged to the grant. The County was not able to provide support for payroll expenditure amounts charged to the grant for part-time hourly employees. Recommendation: We recommend management should review the process of timekeeping for grant eligible employees for daily time input, as well as grant authorized wages. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grant Accountant met with department staff to review the time tracking process for grant-eligible employees to ensure that all payroll expenditures charged to the grant are eligible, authorized, and charged on an individual employee basis. Project codes in Infor allow salary distribution and personnel information to be assigned to each grant. Where possible, this function is to assist in supporting the amounts charged to the grant program. The department will maintain documentation to support the amounts and allowability of the charges applied to the grant for payroll. The County is evaluating new time tracking systems to be implemented in 2025 that will allow for time tracking and reporting at a grant/program level. Name(s) of the contact person(s) responsible for corrective action: Thomas Landauer and Dean Dortone Planned completion date for corrective action plan: March 2025
View Audit 316613 Questioned Costs: $1
Finding 480352 (2022-005)
Significant Deficiency 2022
2022-005 – Completion and Submission of the Annual Single Audit Federal Agency: U.S. Department of the Treasury and U.S. Department of Health and Human Services Federal Program Name: Various Assistance Listing Numbers: 21.023, 21.027, 93.268, 93.323, 93.575, 93.596, 93.778 Federal Award Identificati...
2022-005 – Completion and Submission of the Annual Single Audit Federal Agency: U.S. Department of the Treasury and U.S. Department of Health and Human Services Federal Program Name: Various Assistance Listing Numbers: 21.023, 21.027, 93.268, 93.323, 93.575, 93.596, 93.778 Federal Award Identification Number and Year: Various Pass-Through Agency: Various Pass-Through Number(s): Various Award Period: 1/1/2022 – 12/31/22 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Condition and Context: The County’s single audit and reporting package was delayed for the year ended December 31, 2022, beyond the due date. Recommendation: The County should evaluate its procedures around timely submission of the single audit. Views of Responsible Officials: There is no disagreement with the audit finding. Corrective Action: The reason for the finding recurrence is in part a result of the timing of when the finding was issued. For example, the 2021 Single Audit was issued in December 2023. At this point, the 2022 fiscal year was already complete. Additionally, the implementation of corrective actions are in progress, including providing training, oversight and guidance to departments administering the grants, but these efforts take time to complete and or are ongoing. The County is implementing best practices in grant administration to ensure the timely submission of the Single Audit. A Deputy Controller, Grant Accounting was hired in February 2023. This position provides oversight, training, communications and regular review of grant receivables and expenditures, along with their inclusion in the General Ledger. Additionally, continued use of Infor’s grant management system and Project codes are increasing efficiency in accurately completing the SEFA and providing documentation as requested for programs being audited. The County began implementing a grant accounting system as part of our implementation of Infor in mid-2021 and are continuing to work with departments to refine their use of the system. The County has prioritized completion of the 2022 Single Audit and has allocated staff time from the Controller’s department and other departments to complete the audit. Throughout the process, the Grant Accountant and Controller staff have facilitated communication and information between grant-funded departments and CLA. These changes in part contribute to the completion of the 2022 Single Audit in less than half the time required to complete the 2021 Single Audit. Depending on external auditor availability and other Financial Audits being conducted, the 2023 SEFA will be complete and ready for review by November 2024, with a goal of completion of the 2023 Single Audit by early 2024. We anticipate a timely submission of the 2024 Single Audit by the due date of September 30, 2025. Name(s) of the contact person(s) responsible for corrective action: Thomas Landauer and Fonta Reilly Planned completion date for corrective action plan: September 2025
Name of Auditee: Town of Volney, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by the Audit: Year ended December 31, 2022 CAP Prepared by: Garry Stanard, Town Supervisor Phone: 315-593-8288 Current Findings on the Schedule of Findings and Questioned Costs (1) Finding 2022-001 - ...
Name of Auditee: Town of Volney, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by the Audit: Year ended December 31, 2022 CAP Prepared by: Garry Stanard, Town Supervisor Phone: 315-593-8288 Current Findings on the Schedule of Findings and Questioned Costs (1) Finding 2022-001 - The Data Collection Form for the year ended December 31, 2022 was not filed with the Federal Audit Clearinghouse within nine months of year end. a. Implementation of Plan of Action - Management will work with the auditors for timely completion of the audit and filing of the Data Collection Form. b. Implementation Date - Management expects to have this completed December 31, 2024. c. Persons Responsible for the Implementation - The Board of Trustees and the Town Supervisor.
Finding 480339 (2022-002)
Significant Deficiency 2022
Finding #SA2022-002: Timely Submission of Financial and Performance Reports Assistance Listing Number 97.083 Assistance Listing Title Staffing for Adequate Fire and Emergency Responses (SAFER) Name of Federal Agency Department of Homeland Security Federal Award Identification number: EMW-2018-...
Finding #SA2022-002: Timely Submission of Financial and Performance Reports Assistance Listing Number 97.083 Assistance Listing Title Staffing for Adequate Fire and Emergency Responses (SAFER) Name of Federal Agency Department of Homeland Security Federal Award Identification number: EMW-2018-FH-00543 • Name(s) of the contact person: Shay Narayan, Director of Finance; Carmen Gusman, Deputy Director of Finance • Corrective Action Plan: The City is implementing procedures to ensure timely submission of Financial and Performance Reports. • Anticipated Completion Date: 10/30/24
Finding #SA2022-006 Compliance with Grant Documentation Requirements Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Con...
Finding #SA2022-006 Compliance with Grant Documentation Requirements Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Control Board Federal Award Identification Number: 68-0281986 • Name(s) of the contact person: Shay Narayan, Director of Finance; Carmen Gusman, Deputy Director of Finance • Corrective Action Plan: The City will develop procedures to ensure all documentation is provided • Anticipated Completion Date: 06/30/24
View Audit 316559 Questioned Costs: $1
Finding #SA2022-005 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California Stat...
Finding #SA2022-005 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Control Board Federal Award Identification Number: 68-0281986 • Name(s) of the contact person: Shay Narayan, Director of Finance; Carmen Gusman, Deputy Director of Finance • Corrective Action Plan: The City will develop procedures to ensure all documentation is provided for contracts and subcontracts. • Anticipated Completion Date: 06/30/24
Finding 480332 (2022-004)
Significant Deficiency 2022
Finding #SA2022-004 Compliance with Grant Reporting Deadlines Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Control B...
Finding #SA2022-004 Compliance with Grant Reporting Deadlines Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Control Board Federal Award Identification Number: 68-0281986 • Name(s) of the contact person: Shay Narayan, Director of Finance; Carmen Gusman, Deputy Director of Finance • Corrective Action Plan: The City is implementing procedures to ensure all Grant reporting’s are filed on time. Enhanced collaboration between the Finance Department and other Departments, especially regarding agreed upon procedures for Federal Grants record keeping, will help with timely and accurate submissions of reimbursement claims and reporting. Finance staff is currently reviewing a draft procedures document which comprehensively outlines the City’s responsibilities for administrating Federal Grants. Once City Departments begin utilizing the procedures document, the timeliness and accuracy of filing and reporting should improve. • Anticipated Completion Date: 12/31/24
Finding #SA2022-003 Compliance with Grant Management Deadlines Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Control ...
Finding #SA2022-003 Compliance with Grant Management Deadlines Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Control Board Federal Award Identification Number: 68-0281986 • Name(s) of the contact person: Shay Narayan, Director of Finance; Carmen Gusman, Deputy Director of Finance • Corrective Action Plan: The City is implementing procedures for grant management, accounting, and reporting to ensure that only allowable costs are claimed and have proper support, and reimbursements include all allowable costs and support. Enhanced collaboration between the Finance Department and other Departments, especially regarding agreed upon procedures for Federal Grants record keeping, will help with timely and accurate submissions of reimbursement claims and reporting. Finance staff is currently reviewing a draft procedures document which comprehensively outlines the City’s responsibilities for administrating Federal Grants. Once City Departments begin utilizing the procedures document, the timeliness and accuracy of filing and reporting should improve. • Anticipated Completion Date: 12/31/24
Finding #SA2022-008: Accurate Review and Payment of Vendor Reimbursement Requests Assistance Listing Number: 14.218 Assistance Listing Title: COVID-19 - Community Development Block Grants/Entitlement Grants Name of Federal Agency: Department of Housing and Urban Development Pass Through Entity...
Finding #SA2022-008: Accurate Review and Payment of Vendor Reimbursement Requests Assistance Listing Number: 14.218 Assistance Listing Title: COVID-19 - Community Development Block Grants/Entitlement Grants Name of Federal Agency: Department of Housing and Urban Development Pass Through Entity: San Joaquin County Community Development Department Federal Award Identification Number: A-93-916 • Name(s) of the contact person: Shay Narayan, Director of Finance; Carmen Gusman, Deputy Director of Finance • Corrective Action Plan: The City will develop procedures to ensure accurate review and payment of vendor reimbursement requests, including providing training to administrative staff as necessary. • Anticipated Completion Date: 06/30/24
View Audit 316559 Questioned Costs: $1
Finding #SA2022-007: Cash Management Assistance Listing Number: 14.218 Assistance Listing Title: COVID-19 - Community Development Block Grants/Entitlement Grants Name of Federal Agency: Department of Housing and Urban Development Pass Through Entity: San Joaquin County Community Development D...
Finding #SA2022-007: Cash Management Assistance Listing Number: 14.218 Assistance Listing Title: COVID-19 - Community Development Block Grants/Entitlement Grants Name of Federal Agency: Department of Housing and Urban Development Pass Through Entity: San Joaquin County Community Development Department Federal Award Identification Number: A-93-916 • Fiscal Year of Initial Finding: 2021 • Name(s) of the contact person: Shay Narayan, Director of Finance; Carmen Gusman, Deputy Director of Finance • Corrective Action Plan: The City will develop procedures to ensure all grant-funded expenditures are included on drawdown request and prepared quarterly. Finance staff plan to have regular check-ins with department staff administering federal grants to obtain status updates on expenditures and drawdowns, and reconcile activities accordingly. • Anticipated Completion Date: 10/30/24
Transitions in WCSC financial personnel during and after year-end resulted delays to the audit process for the audit period ending September 30, 2022. To address this problem, WCSC hired a fiscal consultant in August 2022 to oversee the fiscal office, prepare and complete all grant reports, and to c...
Transitions in WCSC financial personnel during and after year-end resulted delays to the audit process for the audit period ending September 30, 2022. To address this problem, WCSC hired a fiscal consultant in August 2022 to oversee the fiscal office, prepare and complete all grant reports, and to coordinate all fiscal audits. WCSC also hired a full-time bookkeeper in October 2022 to conduct day-to-day financial transactions and to assist with audit and grant reporting. WCSC has already engaged its Auditors to conduct the FY2023 audit, which will commence immediately following the completion of the FY2022 audit. Estimated Completion Date : October 31, 2024
TINDLEY ACTION PLAN 1. Develop and implement Procurement Policy (completed and on-going by CFO/Accounting Manager/Accountant/Grants Manager/Network President/Department Heads) a. Enhance written procedures for procurement and accounts payable. i. Purchases between $15,000-$25,000 will require two qu...
TINDLEY ACTION PLAN 1. Develop and implement Procurement Policy (completed and on-going by CFO/Accounting Manager/Accountant/Grants Manager/Network President/Department Heads) a. Enhance written procedures for procurement and accounts payable. i. Purchases between $15,000-$25,000 will require two quotes for all new vendors; purchases between $25,000-$75,000 will require three quotes for all vendors; and purchases over $75,000 will require a competitive bid process for all vendors. ii. Establish a Master Vendor list. 1. Master Vendors may be used for up to $20,000 for regular services and products in the normal course of business with dual approval by the Network President and CFO. b. Require vendor bids/quotes for services. c. Segregate purchasing duties. 2. Research new vendors prior to utilization (implemented and ongoing by CFO/Accountant) a. Are these vendors commonly known in the industry or the community? b. Does the vendor have a valid website, phone number, address and email address? 3. Conduct Periodic/Continuous Fraud-Detection Monitoring (CFO – at every fiscal year end) a. Annually identify (1) Tindley’s top 20 vendors, (2) all Tindley vendors receiving annual payments totaling more than $10,000, and (3) any new vendors receiving annual payments totaling more than $5,000. i. Ensure there are valid and updated contracts for these vendors. ii. Ensure the description for services on the corresponding. invoices are detailed and complete. iii. Assess multiple corresponding invoices that have the same total amounts. 4. Refine and codify job descriptions/job duties for Network President, CFO, Grants & Compliance Manager, and Director of Development (HR/Board to be completed by 9/30/24) a. Keep these job descriptions in a database to ensure a smooth transition in the event of a departure or retirement. b. The job descriptions should highlight the financial compliance aspects of each position. 5. Change reporting structure for CFO (to be implemented by HR/Board 9/30/24) a. CFO will report directly to the Board with a dotted line to the Network President. 6. Provide anti-fraud training for Network President, CFO, Director of Development, Grants & Compliance Manager, and in-house accounting professionals (to be implemented by Network President/CFO and completed by 11/30/24) 7. Establish a Whistleblower/Ethics hotline to report suspected fraud (to be implemented by HR 9/30/24) a. Ensure employees understand that it is available to report suspected fraud. b. Develop procedures for responding to whistleblower allegations. PROCUREMENT POLICIES AND PROCEDURES I. INTRODUCTION AND PURPOSE Tindley should adhere to strict ethical and legal standards to prevent fraud and ensure accountability. This procurement policy should be cross-referenced with current local, state, and federal laws. II. CODE OF CONDUCT A. Conflict of Interest Tindley purchasers shall not participate in the selection, award, or administration of a contract if they have a real or apparent conflict of interest. Such a conflict arises when the Tindley purchaser; any immediate family member (spouse, child, parent, parent in law, sibling, or sibling in law); partner; or an organization that employs, or is about to employ, any of the above has a direct or indirect financial or other interest in, or will receive a tangible personal benefit from, a firm or individual considered for the contract award. An “organizational conflict of interest” is created because of a relationship that a Tindley employee has with a parent, affiliate, or subsidiary organization that is involved in the transaction such that the Tindley employee is or appears to be unable to be impartial in conducting a procurement action involving the related organization. B. Gifts, Money, Gratuities Tindley employees involved in the purchasing process shall not solicit or accept gifts, money, gratuities, favors, or anything of monetary value, except unsolicited items or services of nominal value from vendors, prospective vendors, parties to subcontracts, or any other person or entity that receives, or may receive compensation for providing goods or performing services to Tindley. All Tindley purchasers shall review and comply with Tindley’s procedures for disclosing, reviewing, and addressing actual and potential conflicts of interest. III. PROCUREMENT PROCEDURES A. Procurement Procedure See chart at the end of document B. Bid Procedures All procurement shall be conducted in a manner that provides, to the maximum extent practical, a full and open competition. Tindley bid procedures should always follow local, state, and federal requirements. Procurement Processes should include the following: 1. Assemble a Procurement Committee consisting of the Network President, CFO, Grant Manager, and the requestor of the product or service. i. In the event that the requestor of the product or service is the Network President, a Tindley Board member of the applicable committee that corresponds to the request will be asked to participate. 2. Pre-Bid Phase. i. If an outside vendor is needed to develop the bid specifications for a bid project, the vendor, or related parties to the vendor cannot participate in the bid. ii. The procurement committee should have specific criteria of the bid specifications including how bids will be judged based on price, quality, experience of vendors, etc. iii. All solicitations shall incorporate a clear and accurate description of the technical requirements for products or services to be procured. iv. Identify all requirements which offerors must fulfill and all other factors to be used in evaluating bids and proposals. v. If required by local, state, and or federal laws, Tindley should publicly announce in advance of projects that require a competitive bid process. vi. Vendors should not be allowed to interface with Tindley procurement committee members before any public bids are announced, and post-bid announcement, interactions should occur only as part of the formal bid process (questions and answers in writing, face-to-face walk-throughs, proposal phases, and actual bid submissions). 3. Bid Phase. i. All bidders should have adequate time to respond to a bid, including Q&A sessions, and a face-to-face walk-through if necessary. ii. The Tindley employee sending out bid packages including specifications, should not be the same person receiving the vendor bid submissions. iii. The Tindley employee receiving the bid submissions should time and date stamp each bid received and the committee should exclude any bids submitted after the bid deadline. iv. Tindley employees are forbidden to disclose to vendors information about other bidders, including bid proposal contents such as pricing. 4. Bid Selection Phase. i. The procurement committee should develop a bid template and checklist that ranks bids based on criteria developed by the committee and ensures bid procedures are followed. ii. If the procurement committee chooses the winning bid on criteria other than what is stated in the original specifications, the committee must document the reasons why. For example, if the winning bid was not the lowest price, the committee must justify in writing why the vendor was selected. C. Competition All procurement shall be conducted in a manner that provides, to the maximum extent practical, a full and open competition. 1. Procurements shall avoid noncompetitive practices that may restrict or eliminate competition, including but not limited to: a. Unreasonable qualification requirements. b. Unnecessary experience and excessive bonding requirements. c. Non-competitive pricing practices between firms or affiliated companies. d. Non-competitive contracts to consultants on retainer contracts e. Organizational conflicts of interest. f. Specifying “brand name” only instead of allowing “an equal to product.” 2. Procurements shall not intentionally split a single purchase into two or more separate purchases to avoid dollar thresholds that require more formal procurement methods. 3. Procurements shall include in any pre-qualified list an adequate number of current qualified vendors firms or products. 4. Procurements shall not preclude potential bidders from qualifying during the solicitation period. 5. Procurements shall not use any geographic preferences (state local or tribal) in the evaluation of bid proposals except where expressly mandated or encouraged by applicable federal statutes. 6. The procurement team must find, when possible, bidders to compete that were not provided by the Tindley requester. 7. The procurement committee must use independent judgment and notify the Board of Directors and ethics hotline if the requester of products or services is attempting to use undue influence for the team to select specific vendors. D. Considerations Tindley purchasers should take the following actions when procuring goods and services. 1. Conduct a lease versus purchase analysis when appropriate, including for property and large equipment. 2. Consolidate or break out procurements to obtain a more economical purchase if possible. 3. Use state and local intergovernmental or inter-entity agreements, or common or shared goods and services, where appropriate. 4. Use federal excess and surplus property in lieu of purchasing new equipment and property if it is feasible and reduces project costs. 5. Use time and materials contracts only if no other contract is suitable and the contract includes a ceiling price that the contractor exceeds at their own risk. If such a contract is negotiated and awarded, Tindley must assert a high degree of oversight to obtain reasonable assurance that the contractor is using efficient methods and effective cost controls. IV. PROCUREMENT METHODS A. All procurements made under this policy shall: 1. Be necessary, at a reasonable cost, documented, not prohibited by law or the applicable funding source, and made in accordance with this policy. 2. Avoid acquiring unnecessary or duplicative items. 3. Engage responsible vendors who possess the ability to perform successfully under the terms and conditions of a proposed procurement. 4. Tindley purchasers shall consider vendor integrity, public policy compliance, past performance record, and financial and technical resources. B. Procurement Parameters For all transactions, Tindley shall follow the applicable procurement method set forth in Appendix 1 C. Exceptions to Standards Methods Solicitation of a proposal from a single source may only be used if the following apply and are documented: 1. The item is only available from single source. 2. Public exigency or emergency will not permit any delay. 3. The Federal awarding agency or pass-through expressly authorizes the sole source in response to a Tindley request. 4. After soliciting a number of sources, competition is determined inadequate. V. DOCUMENTATION A. Records Tindley shall maintain records sufficient to detail the history of each procurement transaction. These records must include, but are not limited to: 1. A description and supporting documentation showing the rationale for the procurement method (e.g., cost estimates). 2. Selection of contract type. 3. Written price or rate quotations (such as catalog price, online price, e-mail or written quote), if applicable. 4. Copies of advertisements, requests for proposals, bid sheets or bid proposal packets. 5. Reasons for vendor selection or rejection, including Finance Committee and Board Minutes, rejection letters, and award letters. 6. And the basis for the contract price. VI. COMPLIANCE WITH THIS POLICY Program directors and, where applicable, the purchasing committee, 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. VII. VENDOR SELECTION CRITERIA For vendors that have been selected in a competitive bid or that will provide critical services to the school, Tindley should evaluate them based on cost, quality, past performance, experience, and financial stability. Before providing services or products, the selected vendor can be asked to provide references, allow for background checks, and provide documentation such as certificate of insurance, certificate standing, adherence to anti-fraud policies, and contracts with right-toaudit clauses.
View Audit 316515 Questioned Costs: $1
Responsible Individual: Ambrosia Ermenc, Business Manager Corrective Action Plan: The district agrees with the finding and accepts the risk. This swill continue until the district completes audits within 9 months after fiscal year and submitted to the federal audit clearinghouse and ND DPI. Anticip...
Responsible Individual: Ambrosia Ermenc, Business Manager Corrective Action Plan: The district agrees with the finding and accepts the risk. This swill continue until the district completes audits within 9 months after fiscal year and submitted to the federal audit clearinghouse and ND DPI. Anticipated Completion Date: ongoing
Responsible Individual: Ambrosia Ermenc, Business Manager Corrective Action Plan: The district will create requirement within policy and internal controls for time allocation / time logs to be utilized for every staff member salaried out of federal funds. Anticipated Completion Date: ongoing
Responsible Individual: Ambrosia Ermenc, Business Manager Corrective Action Plan: The district will create requirement within policy and internal controls for time allocation / time logs to be utilized for every staff member salaried out of federal funds. Anticipated Completion Date: ongoing
View Audit 316501 Questioned Costs: $1
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