AMERICAN NURSES ASSOCIATION, INC.Non-Profit

AMERICAN NURSES ASSOCIATION CORRECTIVE ACTION PLAN For the Year Ended December 31, 2021 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES American Nurses Association submits the following corrective action plan for the year ended December 31, 2021. Independent Public Accounting Firm: MARCUM LLP 1899 L Street NW, Suite 850 Washington, DC 20036 Audit Period: The findings from the December 31, 2021 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - FEDERAL AWARD PROGRAM AUDIT Finding No. 2021-001: Procurement and Suspension and Debarment ? Compliance Finding and Significant Deficiency in Internal Control Over Compliance CFDA 93.421 ? Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation?s Health, Grant Period: May 1, 2020 to May 31, 2022, Grant Number 6NU38OT000282-02-03 Views of Responsible Officials and Planned Corrective Actions The Organization understands and is aware of the procurement requirements of the grant agreement and OMB Uniform Guidance. Several meetings had been conducted throughout the grant period on the basic requirements of federal grants including sole source justification, suspension and debarment checks, and vendor verification processes. The Organization revisited its policies and procedures starting in July 2021 when external auditors brought this finding to the Organization?s attention. As a result, the Organization reviewed supporting documentation of all payments made to vendors where federal procurement requirements would apply. Supporting documentation such as the debarment search, sole source justification memo, price, and rate quotations from an adequate number of qualified sources are now being submitted as part of the revised procedures. However, for some existing vendors, while the compliance procedures were performed prior to entering into the contract with the vendors, the creation of formal written documentation occurred during the latter part of 2021, after the organization?s external auditors brought it to the Organization?s attention.. The Organization will continue to revisit its policies and procedures and if an update is needed, the Organization will plan to have those updates completed by December 2022. The Organization will make sure that all payments made to vendors associated with federal grants have sufficient documentation to support compliance with federal procurement requirements. The Organization will ensure that all necessary supporting documentation are submitted as part of the new vendor set up. All program staff will be reminded about the Organization?s policies and procedures on compliance with laws, regulations, and provisions of federal awards. When documentation is required, program staff will be alerted to complete and submit the required documentation. In addition, for recurring vendors the Organization will perform an independent check of debarment at least once a year. Contact Person Responsible for Corrective Action: Daniel Warco, Chief Financial Officer _______________ If the US Department of Health and Human Services has questions regarding this plan, please call Daniel Warco, Chief Financial Officer, 301-628-5156. Sincerely, Daniel Warco Chief Financial Officer American Nurses Association

2020-001

AMERICAN NURSES ASSOCIATION CORRECTIVE ACTION PLAN For the Year Ended December 31, 2020 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES American Nurses Association submits the following corrective action plan for the year ended December 31, 2020. Independent Public Accounting Firm: MARCUM LLP 1899 L Street NW, Suite 850 Washington, DC 20036 Audit Period: The findings from the December 31, 2020 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - FEDERAL AWARD PROGRAM AUDIT Finding No. 2020-001: Procurement and Suspension and Debarment ? Compliance Finding and Significant Deficiency in Internal Control Over Compliance CFDA 93.421 ? Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation?s Health, Grant Period: May 1, 2020 to July 31, 2021, Grant Number 6NU38OT000282-02-0 Criteria For acquisitions exceeding the micro-purchase threshold, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the Organization. If the procurement is sole sourced, an adequate written justification for noncompetitive procurement is required. In addition, the Organization should verify that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. This verification may be accomplished by checking the Excluded Parties List System maintained by the General Services Administration, collecting a certification from the entity, or adding a clause or condition to the covered transaction with the entity. Condition and Context The Organization did not prepare the sole source justification timely for the two vendors we selected for testing, and suspension and debarment checks for these two vendors were also not performed before entering into contract with the vendors. Recommendation It was recommended that the Organization implement procedures and enhance internal controls to ensure appropriate and timely compliance with all applicable federal regulations. Views of Responsible Officials and Planned Corrective Actions The Organization understands and is aware of the procurement requirements of the grant agreement and OMB Uniform Guidance. Several meetings had been conducted during the initial stage/inception of the grant in 2020 with the project team to discuss the basic requirements of federal grants. Due to the timing of the creation of the grant, which was during the pandemic, there was a delay in formalizing the justification for noncompetitive procurement and in documenting verification of the vendors with which it planned to enter a covered transaction, are not debarred, suspended, or otherwise excluded. Formal discussions on sole source justifications and equitable outsourcing and bidding for contracts occurred in January 2021 between the Organization and the prime recipient of the grant. This included review of all the vendors and contractors associated with the grant. Results of this process was formally documented in 2021. While the initial agreement covers May 2020 through October 2020, the agreement was signed and executed in October 2020. The Organization had several discussions with the grantor as to the scope of work and compliance requirements which resulted to the finalization of the grant agreement towards the end of the term of the agreement. The limited time to execute the scope of work along with limited availability of resources within the Organization created the need to recruit an agency specializing in digital marketing and personalization. The agency role is to capture business requirements, design, develop and deploy subject specific digital content. An existing vendor had an on-going services contract and previous experience working with the Organization?s staff and technology portfolio. This allowed the agency to begin work quickly and to deliver artifacts needed in a timely manner. This was required to meet the projects overall schedule. In addition, the co-lead role is key to the initiation of the entire grant, and it was important to establish that early. An existing contractor, who was later on hired by the Organization, was readily available to take on this responsibility and was one of the most qualified candidates based on the job description requirements. The Organization will revisit its policies and procedures and if an update is needed, the Organization will plan to have those updates completed by December 2021. The Organization will make sure that all payments made to vendors associated with federal grants have sufficient documentation to support compliance with federal procurement requirements. The Organization will ensure that supporting documentation such as debarment search, sole source memo, price, or rate quotations from adequate number of qualified sources are submitted as part of the new vendor set up. All program staff will be reminded about the Organization?s policies and procedures on compliance with laws, regulations, and provisions of federal awards. When documentation is required, program staff will be alerted to complete and submit the required documentation in 15 days. In addition, for recurring vendors the Organization will enforce independent check of debarment at least once a year. Contact Person Responsible for Corrective Action: Gregory Dyson, Chief Operating Officer _______________ If the US Department of Health and Human Services has questions regarding this plan, please call Gregory Dyson, Chief Operating Officer, 301-628-5127. Sincerely, Gregory Dyson Chief Operating Officer American Nurses Association