Common Site Visit Findings

1.)  Federal Civil Rights Compliance

Citation:  Title VI Civil Rights Act 1964
Critical issues:

  1. Equal Employment Opportunity Plan  (EEOP)
  2. EEOP Certification Form
  3. Limited English Proficiency (LEP) Requirements

2.)  Accounting Systems and Processes

Citation:  2CFR 215 (Non –Profits) and A-102 (State & Local Gov.)
Critical issues:

  1. Grants funds are not tracked separately
  • Agency funding sources do not list grants awarded by CJCC as a distinct funding category.
  • Accounting Systems fail to demonstrate a clear trail of grant expenses and reimbursements.

3.)  General Financial Policies and Procedures

Citation:  2CFR 215 (Non –Profits) and A-102 (State & Local Gov.)
Critical issues:

  1. Subgrantees fail to develop written financial management/accounting policies and procedures.
  2. The existing policies do not include specific guidelines for the fiscal management of grant funds.
  3. There are no clear policies on purchasing and procurement practices.
  • Services are being procured without following federal / state guidelines that promote free and open competition.
  • Goods (equipment and supplies) are being purchased with disregard to any established thresholds, and with minimal oversight ensuring that costs are in fact reasonable, allocable and necessary, hence allowable.

4.)  Source Documentation

Citation:  2CFR 215 (Non –Profits) and A-102 (State & Local Gov.)
Critical issues:

  1. In the review of formula grants, it has been determined that subgrantees are not properly maintaining supporting documentation of grant related expenses.