AMERICAN REGISTRY OF PATHOLOGY

2016-001: Conflicts of Interest Policy Criteria and Condition: According to 2 CFR ?200.112, ?The Federal awarding agency must establish conflict of interest policies for Federal awards. The non-Federal entity must disclose in writing any potential conflict of interest to the Federal awarding agency or pass-through entity in accordance with applicable Federal awarding agency policy.? 2 CFR ?200.113 further notes, ?The non-Federal entity or applicant for a Federal award must disclose, in a timely manner, in writing to the Federal awarding agency or pass-through entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. Failure to make required disclosures can result in any of the remedies described in ?200.338, Remedies for Noncompliance, including suspension or debarment.? Context: ARP has established a conflict of interest policy but it does not specifically address the requirements under Uniform Guidance. Cause: ARP did not believe they were subject to Uniform Guidance until notified by the Federal awarding agency during year ended September 30, 2016. Effect: In the event of a conflict of interest, the situation may not be documented or addressed in accordance with Uniform Guidance. Repeat Finding: This is a repeat finding as the prior year finding is identified as 2016-001. Recommendation: We recommend that ARP update the conflict of interest policy to comply with the requirements under Uniform Guidance and specifically address federal awards. Views of Responsible Officials: ARP?s practices informally reflect federal requirements and ARP is planning to formalize the policies in the future to be in compliance.

2016-002: Cash Management Policy Criteria and Condition: Under the Uniform Guidance rules, there are documentation requirements related to cash management as it pertains to requesting federal funds for reimbursement after expenses have been incurred. Context: ARP has not implemented a formal cash management policy as required under the Uniform Guidance rules. Cause: ARP did not believe they were subject to Uniform Guidance until notified by the Federal awarding agency during year ended September 30, 2016. Effect: Without a formal policy, there is the opportunity for ARP to operate outside of the requirements of Uniform Guidance. Repeat Finding: This is a repeat finding as the prior year finding is identified as 2016-002. Recommendation: We recommend that ARP adopt a Cash Management policy that complies with 2 CFR ?200.302, which requires the financial management system of each non-federal entity to provide written procedures to implement the requirements of ?200.305, Payment. Views of Responsible Officials: ARP?s practices informally reflect federal requirements and ARP is planning to formalize the policies in the future to be in compliance.

2019-003: Procurement Policy Criteria and Condition: Non-federal entities are required to comply fully with the procurement rules in the Uniform Guidance. Context: ARP follows procurement rules under the Federal Acquisition Regulations (FAR) but does not have a formal procurement policy that addresses Federal awards under the Uniform Guidance. Cause: ARP did not believe they were subject to Uniform Guidance until notified by the Federal awarding agency during year ended September 30, 2016. Effect: Without a formal policy, there is the opportunity for ARP to operate outside of the requirements of Uniform Guidance Recommendation: ARP should examine current procurement policies and procedures to ensure compliance with the following sections of 2 CFR: o ?200.318, General Procurement Standards o ?200.319, Competition o ?200.320, Methods of Procurement to be Followed o ?200.321, Contracting with Small and Minority Businesses, Women?s Business Enterprises, and Labor Surplus Area Firms o ?200.322, Procurement and Recovered Materials o ?200.323, Contract Cost and Price o ?200.324, Federal Awarding Agency or Pass-through Entity Review o ?200.325, Bonding Requirements Views of Responsible Officials: ARP?s practices informally reflect federal requirements and ARP is planning to formalize the policies in the future to be in compliance.

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