TRUE NORTH OF COLUMBIA, INC.Non-Profit

True North of Columbia's Response and Corrective Action Plan and Planned Completion Date for the Corrective Action Plan: True North was in the process of releasing its contracted HR firm and implementing an in-house process to ensure all required personnel forms (including I-9 forms) were completed appropriately and in a timely manner, when this oversight occurred. Two new personnel had I-9 forms that were completed, but mistakenly filed prior to being appropriately signed. Both were hired on the same day and the i-9s were completed during the brief interim period when new HR protocol was just being established. True North correct this error immediately upon notification by our auditors. The in-hosue protocol was implemented during the same week of their hire and has built-in safe-guards to aviod something like this from happening in the future. First teh Executive Director and/or the new employee's supervisor complete (and ensure the new employee appropriately completed all required employement paperwork) during a formal employee intake meeting. Completed paperwork is reviewed by the Executive Director and/or the employee's supervisor and is then routed to the Director of Finance and Grants who reviews the completed paperwork (again) and completes the E-verification proess, notifies the State of Missouri of the new hire, and enters the new employee's informaiton into the agency's online HR and payroll system. Once all information has been entered appropriately, the paperwork is routed to the Operations Specialist who checks each document against a checklist to ensure completeness and correctness. We believe this process is sufficient to ensure the agency does not miss signing or dating a personal document again. Official Responsible for Ensuring the Corrective Action Plan: Michele Snodderly

True North of Columbia, Inc?s Response and Corrective Action Plan: Once management was made aware of this issue, a completed Form I-9, or e-verify report, was obtained for each individual working under the award. The agency is now working with an HR firm who ensures this documentation is included in the employee's personnel file at hire. Official Responsible for Ensuring the Corrective Action Plan: Elizabeth Herrera-EichenbergerPlanned Completion Date for the Corrective Action Plan: As of the date of the audit report, True North of Columbia, Inc. has implemented the corrective action plan and obtained a completed Form I-9, or e-verify report, for each individual working under the award.

True North of Columbia, Inc?s Response and Corrective Action Plan: Once management was made aware of this issue, an updated procurement policy was approved by the Board of Directors and implemented by the organization. The new policies did not change the agency's practice - just put current protocols in writing. Therefore, purchases made under any grant agreement were made in compliance with 2 CFR 200.Official Responsible for Ensuring the Corrective Action Plan: Elizabeth Herrera-EichenbergerPlanned Completion Date for the Corrective Action Plan: As of the date of the audit report, True North of Columbia, Inc. has implemented new procurement policies and procedures that are in compliance with Uniform Guidance (2 CFR 200).