Finding 396651 (2023-004)

SIGNIFICANT DEFICIENCY 2023-004 – Coronavirus State and Local Fiscal Recovery Funds – Procurement, Suspension, and Debarment Criteria or specific requirement Entities are required to have written policies, procedures, and standards of conduct per 2 CFR 200, Subparts D and E. Condition During inquiry of Foundation management, it was determined that the Foundation did not have the required written policies. Context Although the Foundation operates based on procedures and controls that were sufficient to prevent any known noncompliance, those procedures and controls should be turned into a formal policy. Cause The Foundation has not received large amounts of federal funding in the past, and, as a result, was not aware of the requirement. Effect The Foundation’s informal procedures were not documented as a written policy. Recommendation We recommend that the Foundation’s written policies be updated to properly reflect all requirements. Views of responsible officials See Corrective Action Plan.