Ascendus, Inc.

CFDA #59.046 ? Microloan Program U.S. Department of Small Business Administration Compliance Requirement ? Procurement and Suspension and Debarment Criteria: The Compliance Requirement under Uniform Guidance requires that non-federal entities document their own procurement procedures which reflect state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR ?200.320. Implementation of the procurement standards is required for auditee fiscal years beginning on or after December 26, 2017. Condition: Ascendus has not implemented a written procurement policy in accordance with the procurement requirements identified in 2 CFR ?200.320. This is a repeat finding from the prior year. See Summary Schedule of Prior Year Findings. Cause: Ascendus has not adopted a new procurement policy in accordance with the requirements of the Uniform Guidance. Effect: The lack of a written procurement standard results in noncompliance. Recommendation: We carry forward the recommendation that Ascendus adopt a procurement policy that complies with the Uniform Guidance. Views of Responsible Officials: See Management?s Corrective Action Plan.

Responsible Personnel: ? Paul Quintero, CEO Planned Action: Management will work with the Finance and Audit Committee of the Board of Directors to finalize and approve a procurement policy before December 31, 2021. In 2020, there were no purchases that would require a written policy. Completion Date: December 31, 2021

2019-001

ACCION has not implemented a written procurement policy in accordance with the procurement requirements identified in 2 CFR ?200.320.

The Office of Management and Budget (?OMB?) issued a memorandum dated June 20, 2018 titled ?Memorandum for Chief Financial Officers and Heads of Small Executive Agencies?, referencing the National Defense Authorization Acts (?NDAA?) for Fiscal Years 2017 and 2018, in which the thresholds for procurements under federal awards were amended. The memo notes that these higher thresholds would not be effective until implemented in the Federal Acquisition Regulation (?FAR?), but granted an exception to all federal recipients pursuant to 2 C.F.R 200.102 to utilize the higher thresholds in advance of revisions to the FAR and the Uniform Guidance. Based on this OMB guidance, Accion did not change its procurement thresholds in 2019 because they were in-line with pending revisions to FAR and Uniform Guidance, and for which OMB has granted an exception to use such higher thresholds pending such revisions. Accion?s existing procurement policy is substantively in-line with Uniform Guidance procurement standards and was updated in 2019 to remove references to prior circulars as well as to reflect the Uniform Guidance as the primary source of federal procurement guidance. Accion will continue to monitor and evaluate any additional guidance on procurement standards as they materialize.

2018-001

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