Finding Text
Criteria or specific requirement: Title 2 CFR §200.318(c)(1)–(2) requires non-Federal entities to maintain written standards of conduct governing conflicts of interest for employees, officers, and agents engaged in the selection, award, and administration of contracts supported by Federal awards. The standards must prohibit participation in procurement actions where a real or apparent conflict of interest exists, restrict the solicitation or acceptance of gratuities or items of monetary value, provide for disciplinary actions for violations, and address District conflicts of interest when applicable. Condition: The District did not maintain written standards of conduct covering conflicts of interest related to procurement activities. Specifically, the District lacked formal written policies addressing employee and District conflicts of interest, acceptance of gifts or gratuities from contractors, and disciplinary actions for violations of conflict-of-interest requirements. Questioned costs: None Context: The District does not have a policy in place surrounding conflict of interest. Cause: The District had not established or formally adopted procurement policies incorporating the conflict-of-interest requirements of Uniform Guidance. Effect: The absence of written standards of conduct increases the risk that procurement actions may be influenced by real or apparent conflicts of interest and may result in noncompliance with Federal procurement requirements. Repeat Finding: No Recommendation: We recommend that the District develop, approve, and implement written standards of conduct in compliance with 2 CFR §200.318(c)(1)–(2). The standards should address individual and District conflicts of interest, restrictions on gifts and gratuities, and disciplinary actions for violations, and should be communicated to all personnel involved in procurement activities. Views of responsible officials: [There is no disagreement with the audit finding.] Action taken in response to finding: We will create a policy for conflict of interest requirements of Uniform Guidance. Name of the contact person responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025