COOS WATERSHED ASSOCIATION

Funding Agency: Department of Commerce Program: Habitat Conservation Assistance Listing Number: 11.463 Criteria or Specific Requirement: Internal controls should be implemented to ensure procurements subject to the Uniform Guidance included procedures to ensure covered transactions are not entered into with entities suspended or debarred from receiving federal funding. Condition: Internal controls were not in place to perform a check on www.sam.gov for an entity?s suspension or debarment status prior to entering into the covered transactions. Context: For covered transactions no procurement or debarment check was performed by management prior to entering into the transaction. Management performed a check during the audit and verified the Organization did not enter into a covered transaction with a suspended or debarred entity. Questioned Costs: None Cause/Effect:. The Organization could enter into a covered transaction with an entity that is suspended or debarred from receiving federal funding. Recommendation: CLA recommends the Organization updated its policies and procedures to include the check on www.sam.gov for entities it intends to enter into a covered transaction with. View of Responsible Official: Management agrees with the finding and has provided its corrective action plan.

RE: Management Corrective Action Letter - FY2022 Federal Single Audit: Significant Deficiency in Internal Controls - Procurement, Suspension and Debarment To Whomever it May Concern, This letter is in response to Clifton Larson Allen LLP finding of "Significant Deficiency in Internal Controls - Procurement, Suspension and Debarment" in their federal single audit of our organization's 2022 fiscal year Upon notification of this finding, Coos Watershed Association (Association) management immediately drafted a revision to our fiscal policy to include a policy and procedure for ensuring that covered transactions are not entered into with entities suspended or debarred from receiving federal funding. This policy was approved by the Board of Directors on March 14th, 2023 and is included below. Coos Watershed Association Fiscal Policy Section 7b, page 16: "If the Contract is being paid for with federal funding, the Executive Director will ensure that the selected Contractor is not suspended or debarred from doing business with federal contracts by conducting an exclusion search on sam.gov before entering into the Contract. The Association will not enter into Contracts with Contractors who are not legally allowed to work on state or federal contracts." Additionally, the Executive Director performed an exclusion search and found that all contractors working for the Association on covered transactions are not excluded from working on federal contracts.