Finding: The Foundation is responsible for implementing policies, including internal
controls, that are designed to provide reasonable assurance regarding the achievement of
the following objectives: effectiveness and efficiency of operations, reliability of
reporting for internal and external use; and compliance with applicable laws and
regulations. During the audit, it was identified that the federal procurement and other
policies surrounding federal funds, as required under the Uniform Guidance (2 CFR Part
200), were not fully implemented until the latter part of the year. Consequently, certain
procedures conducted prior to the implementation of the new policies did not incorporate
all required federal standards.
Corrective Action Taken: Management, under the leadership of the Chief Executive
Officer, Josh Goldberg, has developed and fully implemented a comprehensive
procurement policy compliant with federal regulations under the Uniform Guidance (2
CFR Part 200) starting October 2024. This policy ensures adherence to all required
federal standards, including competitive bidding, vendor selection, conflict of interest, and
documentation requirements. Staff have been thoroughly trained on the new procedures to
ensure consistent application across the organization. Internal monitoring controls are in
place to ensure ongoing compliance for all federally funded procurements. Management
also maintains active communication with awarding agencies to ensure a clear
understanding and proper implementation of all compliance requirements related to
federal funds.
Completion Date: January 1, 2025