Finding 477862 (2023-001)

W.E. Upjohn Unemployment Trustee Corporation 12/31/2023 Corrective Action Plan Finding Number: 2023-001 Condition: The Corporation did not perform the suspension or debarment check for contractors before entering into a contract with them. Planned Corrective Action: Our workforce development program has policies and procedures that ensure verification of organizations’ eligibility to receive federal funds prior to executing contracts for a covered transaction. Under unusual circumstances, when the Corporation agreed to serve as fiscal sponsor for a nonprofit after the nonprofit had selected the organizations with which it would contract, it did not verify federal funds eligibility for those contractors. In the future, to ensure the eligibility check is done before we enter into covered transactions with any organization, we will adapt the existing workforce development policies and procedures and expand the required application to all of our programs and departments. Management will create a job aid for all staff who are considering submitting a federal grant proposal that will include: 1. A procurement decision tree with requirements for each type of purchase (micro, simplified acquisition, competitive proposals), with an explanation of acceptable exceptions to the procurement process. 2. A listing of federal requirements for each type of purchase. 3. A form to be signed by all potential recipients of Federal awards, certifying their status regarding debarment, suspension, or ineligibility from participation by any federal department or agency. 4. A form for staff to complete before accepting a proposal or making a commitment to purchase goods or services that confirms all federal requirements have been met. The accounting office will verify that requirements have been met prior to the execution of any contract involving procurement of goods or services using federal grant funding. Additionally, subawards and subcontracts will include contract language that requires the contractor notify Upjohn of any change in its eligibility status. Contact person responsible for corrective action: Kathy Breyfogle Anticipated Completion Date: 07/01/2024