Procurement – policies related to procurement for the APRA contract were not followed, effective internal controls were not in place to ensure policies related to procurement were followed.
ACLAMO acknowledges and agrees with Finding 2024-002 regarding the lack of adherence to procurement policies a...
Procurement – policies related to procurement for the APRA contract were not followed, effective internal controls were not in place to ensure policies related to procurement were followed.
ACLAMO acknowledges and agrees with Finding 2024-002 regarding the lack of adherence to procurement policies and internal controls under the ARPA (American Rescue Plan Act) contract.
To address this issue, the Interim Executive Director and the Financial Team have taken immediate steps to strengthen compliance and oversight. Specifically:
Oversight and Delegation: ACLAMO and its Board of Directors have agreed to hire a full-time finance director for the organization. In conjunction with the ongoing designated Construction Manager, these individuals will ensure that all procurement and financial reporting actions are in accordance with internal policies and federal guidelines stated in the contract, and that project documentation is compiled and securely stored in a timely
manner for audit readiness.
Infrastructure Committee Procedures: The Interim Executive Director, alongside other members of ACLAMO management, are committed to developing and implementing standardized procedures for documenting meetings and procurement-related decisions, in collaboration with a delegate from the Infrastructure Committee. These procedures
are being led by ACLAMO and will involve the designated Construction Manager to monitor compliance with standardized procedures & reporting throughout the project, that meeting minutes are properly recorded by the grantor's requirements, and that all activities are compliant with the grant and contract requirements. The Infrastructure Committee delegate’s role will be to ensure alignment and transparency.
Training and Capacity Building: To ensure consistent application of procurement policies, ACLAMO will provide and require mandatory training for all staff involved in procurement and contract management. Training will cover federal procurement standards, internal procedures, and documentation protocols.
Policy Review and Update: As part of our continuous improvement efforts, ACLAMO will conduct a comprehensive review of its procurement policy to ensure it fully aligns with federal Uniform Guidance (2 CFR 200) and make updates where needed. The revised policy will be disseminated to all relevant personnel.
ACLAMO is committed to strengthening internal controls, ensuring transparency, and maintaining full compliance with all contractual and federal requirements.