Finding Text
Criteria: Uniform Guidance [(CFR 2, §200.318(c)(1)] requires a non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the action of its employees engaged in the selection, award and administration of contracts.
Condition: The District does not have a written conflict of interest policy.
Context: During our consideration of compliance requirements of Uniform Guidance, we noted the District had not adopted a conflict of interest policy.
Effect: The District is not in compliance with requirements of Uniform Guidance.
Cause of Condition: The District has not finalized its evaluation of existing policies for compliance with Uniform Guidance requirements.
Recommendation: We recommend the District finalize its evaluation of existing policies and formally adopt a written conflict of interest policy.
Views of Responsible Officials and Planned Corrective Actions: The District concurs with the recommendation to adopt a written conflict of interest policy and the District has implemented a written conflict of interest policy for the next fiscal year.