VIXEN WATER SYSTEM, INC.

2019-003. Noncompliance with Federal Procurement Standards Criteria: Title 2 U. S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that non-federal entities that expend federal funds to meet the general procurement standards in 2 CFR section 200.318. These standards include having written standards of conduct for employees and officials involved in awarding contracts to contractors. In addition, the USDA letter of conditions dated December 06, 2017, requires the water system to have a written conflict of interest policy. Condition: The Board of Directors of the water system did not adopt a written conflict of interest policy as required by the Uniform Guidance and the letter of conditions. Cause: Oversight. Effect: A water system official could have an undisclosed financial interest in a contract funded by a federal award. Recommendation: The Board of Directors of the water system should adopt a written conflict of interest policy that meets the requirements of 2 CFR section 200.318 and the letter of conditions. Management?s Response: The Vixen Board of Directors will approve a conflict of interest policy.

Finding No. 2019-003 Corrective Action Planned: The Vixen Board of Directors will approve a conflict of interest policy. Person Responsible for Corrective Action: Tommie Chatham, President of Vixen Water Anticipated Completion Date: Not later than the Board of Directors meeting date of September 17, 2020.