SELF INITIATED LIVING OPTIONS, INC.Non-Profit

FINDING REFERENCE NUMBER: 2023-001 FEDERAL PROGRAMS: 93.778: Medicaid Cluster – Medical Assistance Program; 93.464: ACL Assistive Technology COMPLIANCE REQUIREMENT: Reporting TYPE OF FINDING: Noncompliance and Significant Deficiency in Internal Control Statement of Condition The Uniform Guidance report for the year ended September 30, 2023, will be submitted with SILO’s Federal Audit Clearinghouse filing during September 2024, which is after its due date. Criteria or Specific Requirement The Federal Audit Clearinghouse filing, inclusive of SILO’s Uniform Guidance report, is due thirty days after the receipt of the auditor’s report or nine months after the end of the fiscal year – whichever comes first. Questioned Costs Not applicable. Effect SILO did not comply with the reporting requirements established by the Federal Agency. Cause Additional time past the filing deadline was required to complete the financial statement and Uniform Guidance audits. Recommendation SILO should closely monitor compliance with reporting requirements established by the Federal Agency and consider commencing its financial statement and Uniform Guidance audits earlier. Views of Responsible Officials and Corrective Action Plan SILO will make sure the financial statement and Uniform Guidance audits are started earlier to ensure enough time to file timely in the future.

2021-001 ? Procurement Program: CFDA 93.791 ? Money Follows the Person Rebalancing Demonstration Sponsor Award Number: N/A Sponsor Agency: New York State Department of Health passed through the New York Association on Independent Living Criteria: The final regulations of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (?UG?) contain cost principles related to procurement. Under the UG, there are several methods that must be followed: ? Micro purchases, which apply to goods and services less than $10,000, do not require competitive quotes but does require attempts at equitable distribution to avoid all purchases from the same vendor. ? Small purchases, which apply to goods and services directly charged to federal awards that are more than $10,000 but below the Simplified Acquisition Threshold ($250,000), require multiple rate quotes from qualified sources. ? Sealed bids when services are above the $250,000 level and which are most applicable for construction. ? Competitive proposals to be used when sealed bids are not practical. There are 5 standards that an organization must comply with regardless of which procurement method is used: ? Written procedures, ? Expenses must be necessary and reasonable, ? Subject to open competition, ? Code of conduct and conflict of interest policies must be adhered to, and ? Contain proper documentation including the detail of the purchase transaction, support of the procurement method used and the basis of the award and price. Citation: 2 CFR 200.320 Condition: While SILO has a procurement policy that contains the criteria outlined in the regulation, it did not follow the policy when selecting its health insurance provider. Cause: The organization was not aware of the need to annually document its compliance with its procurement policy when continuing to have health insurance coverage through its current provider. Effect: There is a risk that purchases will be made that do not contain the proper bids or be documented in a manner that is consistent with federal guidelines. Questioned Costs: None. Context: Management did not have formal documentation regarding the procurement procedures followed and decisions made selecting its health insurance provider.. Repeat Finding: No Recommendation: We recommend that for all purchases above the requirement threshold, that the organization obtain and maintain proper documentation as evidence that all purchases are in accordance with Uniform Guidance and the organization?s procurement policy. Views of Responsible Officials: See Corrective Action Plan attached.