Finding 2025-002 – Material Weakness in Internal Controls over Federal Award Compliance Criteria – 2 CFR 200.303 requires the recipient to establish, document, and maintain effective internal control over federal awards. Condition – The Organization has not established and documented internal control policies and procedures over compliance with federal award requirements other than procurement. It is also noted that the procurement policy that is documented does not conform to current federal limits. Context and Cause – The Organization’s current policies do not include a review of the fiscal policy for required changes on a scheduled basis. Effect of Condition – Incomplete documentation of policies regarding federal compliance could prevent management and the Board from providing adequate oversight over compliance activities of the Organization. Questioned Cost – None. Recommendation – We recommend the Organization develop and implement policies and procedures addressing the applicable federal compliance requirements for each federal program. Action Taken – Management concurs with the finding and has developed a corrective action plan. We understand that a material weakness is identified in internal controls over compliance. The material weakness is in internal controls over compliance, and not a compliance finding. Draft and adopt written internal control policies and procedures addressing each applicable compliance requirement, including defined roles, responsibilities, and approval processes. Update the Organization's procurement policy to conform to current Federal procurement thresholds and methods under 2 CFR §§ 200.317–200.327, including micro-purchase and simplified acquisition thresholds. Establish a recurring (at least annual) fiscal policy review cycle, with responsibility assigned to a specific role, to identify and incorporate required regulatory changes, including updates to Federal thresholds. Present the updated policies and procedures to the Board (or Finance/Audit Committee) for formal review and approval. Responsible parties: Fiscal Director. Anticipated completion date: October 31, 2026.