Community Action for Better Housing, Inc.

Finding: CABH Developed Written Policies, Procedures and Standards of Conduct Relative to Federal Awards as Required by Uniform Guidance (Significant Deficiency ? Other Non-Compliance) but did not Reference all of the Required Elements. Condition: CABH developed written policies, procedures and standards of conduct relative to Federal awards as required by Uniform Guidance (2 CFR 200), Subparts D (Post Federal Award Requirements) and E (Cost Principles), however, the policies did not contain the required elements or references to the Uniform Guidance. This applies not only to the major programs tested during the fiscal year 2019 audit, but all Federal programs. Criteria: Uniform Guidance requires nonfederal entities that receive federal awards to establish written policies, procedures or standards of conduct for the following sections: ? Financial management (200.302) ? Payment (200.305) ? General procurement standards (200.318) (see below) ? Competition (200.319) ? Methods of procurement to be followed (200.320) (see below) ? Compensation ? personal services (200.430) ? Compensation ? fringe benefits (200.431) ? Relocation costs of employees (200.464) ? Travel costs (200.474) The Uniform Guidance establishes requirements for written policies approximately 25 times. The list above is not all inclusive. Initially, the OMB gave entities the option to elect to delay the implementation of the Uniform Guidance procurement standards for two full fiscal years beginning with the nonfederal entity?s fiscal year that began on or after December 26, 2014. On May 17, 2017, the OMB extended the grace period for implementation of the procurement standards for an additional year. With this amendment, the new procurement standards will apply to the nonfederal entity?s fiscal year that begins on or after December 26, 2017 (i.e. July 1, 2018). If this election is made, the entity must document whether it is in compliance with the old or new standard, including if it chooses to utilize the 2017 extension, and must meet the standard as documented.The documented policies should, at a minimum, be updated to include the following: ? References to the applicable Uniform Guidance sections ? Data retention requirements for records in accordance with 2 CFR ? 200.302 ? Procurement o In accordance with 2 CFR ? 200.318 ? Written standards of conduct over conflict of interest ? Records for procurement must be maintained sufficiently to detail the history of procurement to include: ? Rationale for the method of procurement ? Selection of contract type and contractor selection or rejection ? Basis for contract price o Open competition in accordance with 2 CFR ? 200.319 o Micropurchase threshold of $10,000 in accordance with 2 CFR ? 200.67 o Simplified acquisition threshold of $250,000 in accordance with 2 CFR ? 200.88 Cause: CABH has created a policy but should be enhanced to reference specific Uniform Guidance standards. Effect: Failure to establish these policies, procedures or standards of conduct puts CABH in noncompliance with current Federal regulations and increases the likelihood of fraud, waste and abuse of Federal funds. It also may increase the likelihood of findings in subsequent Single Audits due to lack of adequate internal controls. Isolated Instance or Systemic Problem: We consider this issue to be a ?systemic problem?. Repeat of a Finding in the Immediately Prior Audit (with Prior Year Audit Finding Number (where applicable)): Yes - 2018-001 Recommendation to Prevent Future Occurrence: It is recommended that CABH enhance their Written Policies, Procedures and Standards of Conduct Relative to Federal Awards as Required by Uniform Guidance.

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