Siena Francis House and SubsidiariesNon-Profit

Identification of the Federal Program - Emergency Solutions Grant Program; Federal Assistance Listing ? 14.231 Criteria: The program is subject to the general procurement standards as applicable in Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance). 2 CFR 200.318 indicates that non-Federal entities must have and use documented procurement procedures consistent with state, local and tribal laws and regulations. Condition: The Organization?s procurement policy is not consistent with the general procurement standards as defined in Title 2, CFR Part 200. Certain provisions of the Organization?s policies were lacking or not consistent with the policies outlined in the general procurement standards. Cause: The Organization historically had not received a significant amount of federal grant awards and did not have a control structure in place to ensure that existing policies met the required elements. Since the COVID-19 pandemic, the Organization has been awarded several federal grant awards and as a result have needed some updates in policies. Effect: The Organization?s policies are not in compliance with the Uniform Guidance. Recommendation: We recommend that management review and revise its procurement policy to ensure it is in compliance with federal standards. Views of Responsible Officials: Management is aware of the deficiency of internal control over compliance related to the general procurement standards. The Organization is in the process of amending its financial policies and procedures to be more consistent with the requirements of 2 CFR 200.