Management agrees with the finding and is implementing the accompanying corrective action plan.
Views of Responsible Officials:
Jacy Hyde, Executive Director
Joel Rusco, Chief Financial and Administrative Officer
Jessica Martinez, Deputy Director
Contact Person:
Joel Rusco, Chief Financial and Administrative Officer
Jessica Martinez, Deputy Director
Corrective Action Plan:
In response to the FY21 Corrective Action Plan, CFSC implemented a Subrecipient Monitoring Policy in June 2024 to ensure compliance with the Uniform Guidance for monitoring subrecipients of federal funding, including audit requirements and the verification of suspension and debarment status. To further strengthen compliance and ensure timely verification, CFSC will implement the following actions:
1. Mandatory Pre‐Award Verification Timing & Documentation:
a. Suspension and debarment status must be verified on SAM.gov by the assigned Grant Specialist before the execution of any subaward agreements.
b. The verification data and results will be documented by the assigned Grant Specialist and included in the Risk Assessment process prior to award issuance.
c. Any subrecipients flagged as high risk due to past audit findings will undergo enhanced pre‐award due diligence before subaward execution to be carried out by the assigned Grant Specialist.
2. Grant Compliance Oversight & Approval:
a. The Grants Manager (or designee) will review and approve all subrecipient compliance checks before final award execution.
b. Any exceptions or delays in verification must be documented and approved by the CFAO & Deputy Director before proceeding.
3. Quarterly Compliance Audits:
a. The Grants Manager (or designee) will conduct quarterly internal audits of subrecipient monitoring files to confirm that suspension & debarment verification was completed timely before subaward execution.
b. The Grants Manager will be responsible for reporting any identified deficiencies to senior management and ensuring timely correction for policy reinforcement.
Anticipated Completion Date:
These corrective actions will be fully implemented by the end of FY25, with ongoing monitoring and enforcement thereafter.