Management has developed internal controls to ensure compliance with Procurement and Suspension and Debarment, Reporting, and Subrecipient Monitoring of Federal Awards requirements is maintained with an appropriate segregation of duties and fully documented. The following internal control process wi...
Management has developed internal controls to ensure compliance with Procurement and Suspension and Debarment, Reporting, and Subrecipient Monitoring of Federal Awards requirements is maintained with an appropriate segregation of duties and fully documented. The following internal control process will be implemented into the Financial and Accounting Policies within the Organization’s Procurement Procedures specific to Federal Grant Awards: The Assistant Project Manager shall adhere to all Federal requirements related to confirmation of any third-party provider to verify Compliance or Non-Compliance with Procurement and Suspension and Debarment requirements. All searches shall be completed before entering into any contractual agreement and must be included in the Procurement Process documentation required for approval. The search shall be conducted through the Federal Government’s sam.gov website. Each search shall be downloaded and saved to the appropriate program file on the Organization’s SharePoint site. A copy of each search must be emailed to the Project or Grant Manager confirming compliance status. Management has implemented an updated policy for risk assessment related to Federal Grant Award subrecipient pass-through entities, which shall require a written assessment of each proposed pass-through entity prior to any contractual agreement being signed. The Project or Grant Manager shall prepare a risk assessment for all proposed pass-through entities related to any Federal Grant Award. The assessment document at a minimum shall include the following: • Identification of the pass-through entity and key partners. • Summary of their relevant work history that uniquely qualifies them for the proposed grant. • Supporting documentation showing the pass-through entity meets the financial qualifications, if applicable to the proposed grant. • Provide an assessment of potential risks related to the above The Project or Grant Manager shall submit in writing the risk assessment to the CEO and either the CFO or CAO for review and discussion. The CEO and either CFO or CAO shall review and either approve or deny in writing the pass-through entity. To the extent the financial commitment exceeds $1,500,000 the CEO shall be required to obtain approval from the Board Chair, Vice Chair or Treasurer as required under the contract approval policy. Management shall implement a new Federal Grant Award Reporting and Compliance section to the Organization’s Financial and Accounting Procedures as follows: Federal Grant Award Reporting: The process for preparing, reviewing and approving both financial and non-financial reports required for all Federal Grant Awards shall be performed as defined below: Preparer: Financial Information: Project Accountant Nonfinancial Information: Assistant Project Manager • Consolidate data from all departments into a single report • Draft the narrative of the report • Provide supporting documentation for preparation Reviewer: Financial Information: CFO Nonfinancial Information: Project/Grant Manager • Review the draft report and underlying data to ensure accuracy and consistency with all federal reporting and compliance requirements. • Check for compliance with external reporting standards (e.g., change in standards, grant agreements, etc.). • Work with the preparer and data owners to resolve any data inconsistencies. • Sign-off on the final report, confirming its accuracy and completeness. Final Submission: The submission of either financial or non-financial reports must have written approval by the Reviewer prior to submittal. Contact Person: Cari Easterday, Chief Financial Officer Expected Completion: Prior to December 31, 2025