COORDINATED ADVICE AND REFERRAL PROGRAM FOR LEGAL SERVICESNon-Profit

PROCUREMENT POLICY - CONTROL FINDING: The Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance. 0MB Uniform Guidance §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. The Organization's federal funding significantly increased in the year ended June 30, 2022 and was the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicity comply with the standards in the Uniform Guidance. In the absence of a written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment (see finding 2023-002) and documentation of procurement activities (see finding 2023-003).

SUSPENSION AND DEBARMENT - COMPLIANCE FINDING: The Organization did not verify that contractors used were not suspended, debarred or otherwise excluded prior to entering into a contract with them. 0MB Uniform Guidance §200.180 provides that non-federal entities cannot enter into transactions with parties that are suspended or debarred from doing business with the federal government. The Organization's federal funding significantly increased in the year ended June 30, 2022 and was the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance. As noted in finding 2023- 001, the Organization's purchasing policies did not comply with the Uniform Guidance. The Organization was not aware that contractors should be verified prior to entering into a contract under the Uniform Guidance. It is possible that the Organization enters into a contract with a contractor that has been suspended, debarred or otherwise excluded. The Organization's written procurement policies should include a procedure to verify that contractors are not suspended, debarred or otherwise excluded prior to entering into a contract, and the Organization should perform and document these procedures performed.

PROCUREMENT DOCUMENTATION - COMPLIANCE FINDING: The Organization did not maintain documentation of its procurement decisions. 0MB Uniform Guidance §200.320 details various methods of procurement to be followed based on the intended dollar value and nature of the contract. While the specific required documentation may vary based on each of the five methods, all mandate specific documentation concerning procurement decisions. The Organization's federal funding significantly increased in the year ended June 30, 2022 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance. As noted in finding 2023-001, the Organization's purchasing policies did not comply with the Uniform Guidance. The Organization was not aware of the specific documentation requirements under the Uniform Guidance. In the absence of a written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization's written procurement policies should include details of required documentation in accordance with the Uniform Guidance, and the Organization should maintain such documentation.

COST PRINCIPLE - COMPLIANCE FINDING: The Organization did not use actual expense amounts in payroll expense calculations. 0MB Uniform Guidance §200.400 details the policy guide for cost principles to ensure proper and efficient administration of the Federal award of which only actual expenses incurred are to be charged against the funds. The Organization's federal funding significantly increased in the year ended June 30, 2022 and wass the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance. The Organization was not aware of the requirements to charge actual expense amounts under the Uniform Guidance. During the year ended June 30, 2023, corrective actions were taken but the condition was still present during the year. Estimated amounts were used in calculating monthly invoices, so it is more likely that the Organization's expense practices will not comply with the Uniform Guidance. The Organization should use actual wage expense amounts rather than estimates in accordance with the Uniform Guidance.

Condition: The Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance. Criteria: OMB Uniform Guidance ?200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in ?200.317 through ?200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2022 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicity comply with the standards in the Uniform Guidance. Effect: In the absence of a written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment (see finding 2022-002) and documentation of procurement activities (see finding 2022-003). Recommendation: A written procurement policy and a written standard of conduct should be established in accordance with the procurement requirements contained in Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Written procurement and conflict of interest policies, in accordance with the Uniform Guidance, will be established and implemented during the year ended June 30, 2023.

Condition: The Organization did not verify that contractors used were not suspended, debarred or otherwise excluded prior to entering into a contract with them. Criteria: OMB Uniform Guidance ?200.180 provides that non-federal entities cannot enter into transactions with parties that are suspended or debarred from doing business with the federal government. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2022 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance. As noted in finding 2022-001, the Organization's purchasing policies did not comply with the Uniform Guidance. The Organization was not aware that contractors should be verified prior to entering into a contract under the Uniform Guidance. Effect: It is possible that the Organization enters into a contract with a contractor that has been suspended, debarred or otherwise excluded. Recommendation: The Organization's written procurement policies should include a procedure to verify that contractors are not suspended, debarred or otherwise excluded prior to entering into a contract, and the Organization should perform and document these procedures performed. Views of Responsible Officials and Planned Corrective Actions: Two of the contracts noted were originally entered into prior to the increase in the Organization's federal funding and being subject to the Uniform Guidance. No contracts were entered into with vendors that were suspended, debarred, or otherwise excluded. Written procurement and conflict of interest policies, in accordance with the Uniform Guidance, will be established and implemented during the year ended June 30, 2023.

Condition: The Organization did not maintain documentation of its procurement decisions. Criteria: OMB Uniform Guidance ?200.320 details various methods of procurement to be followed based on the intended dollar value and nature of the contract. While the specific required documentation may vary based on each of the five methods, all mandate specific documentation concerning procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2022 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance. As noted in finding 2022-001, the Organization's purchasing policies did not comply with the Uniform Guidance. The Organization was not aware of the specific documentation requirements under the Uniform Guidance. Effect: In the absence of a written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization's written procurement policies should include details of required documentation in accordance with the Uniform Guidance, and the Organization should maintain such documentation. Views of Responsible Officials and Planned Corrective Actions: While documentation was not maintained, the procurement methods followed by the Organization did comply with the requirements based on the sizes of the contracts. Written procurement and conflict of interest policies, in accordance with the Uniform Guidance, will be established and implemented during the year ended June 30, 2023.