Corrective Action Plans

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1. Updated drawdown procedures have been incorporated into SCMRC’s financial policies and will be re-reviewed annually.
1. Updated drawdown procedures have been incorporated into SCMRC’s financial policies and will be re-reviewed annually.
2. Refresher training on 2 CFR § 200.305 and internal drawdown requirements will be conducted by Q4 2025.
2. Refresher training on 2 CFR § 200.305 and internal drawdown requirements will be conducted by Q4 2025.
3. Results of monthly drawdown audits will be included in the Finance Committee compliance dashboard starting in September 2025.
3. Results of monthly drawdown audits will be included in the Finance Committee compliance dashboard starting in September 2025.
4. SCMRC will continue to require documented CEO approval on all federal drawdown submissions to ensure sustained internal control.
4. SCMRC will continue to require documented CEO approval on all federal drawdown submissions to ensure sustained internal control.
1. In May 2024, SCMRC adopted a revised Purchasing and Procurement Policy that includes specific procedures for suspension and debarment screening for all covered transactions ≥$25,000.
1. In May 2024, SCMRC adopted a revised Purchasing and Procurement Policy that includes specific procedures for suspension and debarment screening for all covered transactions ≥$25,000.
2. SAM.gov verification and/or vendor self-certification is now required prior to contract execution or payment, with documentation filed in the procurement record.
2. SAM.gov verification and/or vendor self-certification is now required prior to contract execution or payment, with documentation filed in the procurement record.
3. Procurement and grant staff received training in Spring 2024 on 2 CFR § 200.214 and Part 180, using materials from HRSA technical assistance and compliance consultants.
3. Procurement and grant staff received training in Spring 2024 on 2 CFR § 200.214 and Part 180, using materials from HRSA technical assistance and compliance consultants.
4. A centralized procurement review process was established in 2024, with required sign-off by the CEO or Controller for all covered transactions.
4. A centralized procurement review process was established in 2024, with required sign-off by the CEO or Controller for all covered transactions.
5. Monthly procurement file audits began in 2025 to verify that S&D documentation is consistently completed and retained.
5. Monthly procurement file audits began in 2025 to verify that S&D documentation is consistently completed and retained.
1. SAM.gov searches or vendor certifications will continue to be required and documented for all covered transactions and reviewed by the CEO or Controller before final approval.
1. SAM.gov searches or vendor certifications will continue to be required and documented for all covered transactions and reviewed by the CEO or Controller before final approval.
2. Beginning Q4 2025, procurement files will be audited quarterly (instead of the current monthly cadence) for S&D compliance, with results reported to the CEO and incorporated into continuous improvement efforts.
2. Beginning Q4 2025, procurement files will be audited quarterly (instead of the current monthly cadence) for S&D compliance, with results reported to the CEO and incorporated into continuous improvement efforts.
3. Procurement compliance, including S&D verification, will be included in SCMRC’s annual fiscal review and addressed in new staff onboarding and annual training.
3. Procurement compliance, including S&D verification, will be included in SCMRC’s annual fiscal review and addressed in new staff onboarding and annual training.
4. SCMRC will maintain documentation for each verification in alignment with federal requirements and internal procurement policy.
4. SCMRC will maintain documentation for each verification in alignment with federal requirements and internal procurement policy.
1. In May 2024, SCMRC adopted a new Purchasing and Procurement Policy aligned with 2 CFR §§ 200.317–327. The policy includes required contract clauses, competition thresholds, conflict-of-interest standards, and documentation requirements.
1. In May 2024, SCMRC adopted a new Purchasing and Procurement Policy aligned with 2 CFR §§ 200.317–327. The policy includes required contract clauses, competition thresholds, conflict-of-interest standards, and documentation requirements.
2. Procurement responsibilities were centralized under the CEO and Controller, with all federally funded purchases above the micro-purchase threshold requiring formal documentation and pre-approval.
2. Procurement responsibilities were centralized under the CEO and Controller, with all federally funded purchases above the micro-purchase threshold requiring formal documentation and pre-approval.
3. Standardized templates for vendor selection, procurement method, and price justification were implemented.
3. Standardized templates for vendor selection, procurement method, and price justification were implemented.
4. SCMRC initiated monthly internal procurement audits in 2025.
4. SCMRC initiated monthly internal procurement audits in 2025.
1. The CEO and Controller will continue to review and approve all procurement actions above the micro-purchase threshold, ensuring compliance with policy and federal regulations.
1. The CEO and Controller will continue to review and approve all procurement actions above the micro-purchase threshold, ensuring compliance with policy and federal regulations.
2. Internal procurement audits will be conducted quarterly, with findings reviewed by leadership and incorporated into SCMRC’s CQI process.
2. Internal procurement audits will be conducted quarterly, with findings reviewed by leadership and incorporated into SCMRC’s CQI process.
3. SCMRC will include procurement compliance in the annual fiscal compliance review and maintain documentation for all purchases in accordance with the updated policy.
3. SCMRC will include procurement compliance in the annual fiscal compliance review and maintain documentation for all purchases in accordance with the updated policy.
4. Ongoing staff training will be provided at least annually, with procurement compliance
4. Ongoing staff training will be provided at least annually, with procurement compliance
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