Management Response and Planned Corrective Action:
We partially concur with the Federal Award Findings outlined above of the auditors and have implemented a corrective action plan, including updating internal control policies and procedures.
Views of Responsible Officials and Corrective Actions:
The management team of the Council of Western State Foresters believe in the values of transparency, justification, and documentation for transactions made in the course of conducting job related duties.
As a small organization with limited staff, suggested reasonable improvements to processes are always welcome. It is in this spirit that the below corrective actions for the compliance issues noted in the findings from the 2023 audit are put forward.
2023-005 Corrective Action Plan:
Management affirms that, in accordance with 2 CFR requirements, the organization has been verifying contractor eligibility through the System for Award Management (SAM) to ensure that no contractors are debarred or suspended. To further strengthen internal controls and align with best practices, the organization’s procurement policy will be updated to formally require the following:
• A signed Form AD-1048 (Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion) must be obtained prior to the execution of any procurement contract.
• A copy of the executed AD-1048 will be retained in both the organizational and accounting filing systems.
• For entities with a UEI, a screenshot of active registration and status verification from the SAM.gov system will be maintained in the contract file.
These procedures have already been implemented in practice for all new contracts executed in the current fiscal year. As an added measure of diligence and compliance, the Executive Director will review existing contracts and ensure the required documentation is filed in the appropriate contract folders for applicable vendors.
Anticipated Completion:
Implemented for all new contracts for 2025.