Dave Purchase Project

Criteria Per OMB guidance and contractual terms, the non-federal entity (the "Organization") is required to conduct criminal background checks and maintain related policies, procedures and personnel files consistent with the requirements of RCW 43.43 and WAC 246-341. Condition The Organization was not able to produce evidence that background checks in accordance with the criteria described above were conducted in certain instances in relation to personnel involved in carrying out the activities of the federal program. Context Per our testing of the internal controls surrounding the direct and material compliance requirements in relation to payroll and human resource policies and processes in conjunction with the delivery of goods and service associated with the Federal program, there was insufficient documentation supporting whether background checks were completed for certain employees. Cause Background checks were either not completed, or the entity's record keeping was not sufficient to provide evidence that background checks had been completed appropriately. Effect The Organization would possibly employ and assign duties in performing services under the federal program with individuals that potentially may have had a criminal record, which is in violation of the contract. Auditor's Recommendations The Organization should ensure human resource policies and procedures are sufficient and in compliance with all applicable laws, regulations and compliance requirements of contracts.

In response to audit finding 2023-001, Dave Purchase Project will immediately implement the following corrective actions: • DPP will review all current employee files by 03.08.2023 to ensure that a background check has been completed and evidence of the check is present in each employee file; • All current staff will have a new background check run and placed in their file: • All new hires/volunteers/interns will have a background check conducted on their first day of employment/volunteering/internship, while they fill out their new hire/volunteer/internship paperwork;No new staff/volunteers/interns will be deployed to their work site until the check has been completed, and; • any background check findings are satisfactorily addressed; • their paperwork is appropriately filed; No new staff/volunteers/interns will be deployed if background check findings conflict with federal requirements regarding employment i.e ., OIG is required by law to exclude from participation in all Federal health care programs individuals and entities convicted of the following types of criminal offenses: Medicare or Medicaid fraud, as well as any other offenses related to the delivery of items or services under Medicare, Medicaid, SCHIP, or other State health care programs; patient abuse or neglect; felony convictions for other health care - related fraud, theft, or other financial misconduct; and felony convictions relating to unlawful manufacture, distribution, prescription , or dispensing of controlled substances; • Every January all current DPP staff will have an updated background check completed and evidence of such placed in their employee file