Personnel Policies

SAMPLE CDC

POLICIES AND PROCEDURES

MANUAL v. 2.1

February 2015

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Introduction

The attached sample Policies and Procedures Manual was developed to assist community

development corporations (CDCs) in their administration of federal funds. It includes sample

personnel, accounting, financial management, procurement, and records management

policies, and has two distinct purposes:

 To provide emerging CDCs with sample policies and procedures so that they may be

able to develop policies and procedures appropriate to their specific circumstances,

and to provide their staff members with information regarding the type of systems

that may be adopted in their administration of federal funds; and

 To provide mature CDCs with sample policies and procedures to compare with their

existing manual and assess whether adequate systems are in place particularly with

respect to the administration of federal funds.

Please note that the sample policies and procedures presented in this manual is only one

of many possible models that could meet federal regulations. In many instances, an

existing policies and procedures manual may be suffice. Prior to developing a policies and

procedures manual or adopting any of the sample policies and procedures attached, LISC

strongly encourages an organization to consult with legal counsel, accounting, financial,

and/or human resource professionals. By doing so, the organization will be able to

develop policies and procedures to reflect its own organizational philosophy and include

information consistent with applicable state and local laws.

* LISC makes no legal representation concerning the accuracy of the information presented in

these sample policies and procedures manual or the manual’s compliance with federal, state

or local laws.

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Table of Contents

Introduction ...................................................................................................................... 2

PURPOSE ........................................................................................................................... 7

PERSONNEL POLICIES ......................................................................................................... 8

Policy on Affirmative Action/Equal Employment Opportunity Statement .............................. 8

Compliant Procedure ............................................................................................................... 8

Employment ............................................................................................................................. 9

Vacancies ................................................................................................................................. 9

Hiring ....................................................................................................................................... 9

Employment at Will ............................................................................................................... 10

Employment at Will Disclaimer .......................................................................................... 10

Employment Status ................................................................................................................ 11

Full-time ............................................................................................................................. 11

Part-time ............................................................................................................................ 11

Temporary Employees ....................................................................................................... 11

Non-Exempt and Exempt Employees ................................................................................. 11

Consultants ......................................................................................................................... 11

Attendance ............................................................................................................................ 11

Work Schedule and Pay Periods ............................................................................................ 12

Work Schedule ................................................................................................................... 12

Time Reporting ................................................................................................................... 12

Non-exempt employees ......................................................................................................... 12

Exempt Employees ................................................................................................................. 13

Pay Practices .......................................................................................................................... 13

Pay Period ........................................................................................................................... 13

Direct Deposit ..................................................................................................................... 13

Wage Garnishments .............................................................................................................. 14

Outside Employment ............................................................................................................. 14

Conflict of Interest ................................................................................................................. 14

Policy Prohibiting Unlawful Harassment, Including Sexual Harassment............................... 15

Personnel Files and Employment Information ....................................................................... 17

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Resignation, Suspension, Termination, Reduction ................................................................ 17

Resignation ......................................................................................................................... 17

Suspension ......................................................................................................................... 17

Termination ........................................................................................................................ 17

Reduction ........................................................................................................................... 18

Grievance Procedure .............................................................................................................. 18

Travel and Other Expenses .................................................................................................... 19

PERFOMANCE AND DISCIPLINE ........................................................................................ 20

Pay Raises and Bonuses ......................................................................................................... 20

Performance Appraisals ......................................................................................................... 20

Supervision and Evaluation ................................................................................................ 20

Performance Evaluations ................................................................................................... 20

Initial Evaluation ................................................................................................................. 20

Corrective Action and Employment Termination .................................................................. 21

Forms of Corrective Action ................................................................................................ 21

Occasions for Corrective Action ............................................................................................. 22

BENEFITS ......................................................................................................................... 23

Benefits .................................................................................................................................. 23

Vacation Days ..................................................................................................................... 23

Personal Excused Absence ................................................................................................. 24

Personal Sick Leave ............................................................................................................ 24

Bereavement ...................................................................................................................... 24

Holidays .............................................................................................................................. 24

Leave of Absence (non FMLA) ............................................................................................ 24

Jury Duty ............................................................................................................................. 25

Worker’s Compensation..................................................................................................... 25

Disability Leave ................................................................................................................... 25

Military Service ................................................................................................................... 25

National Guard/Reserves ................................................................................................... 26

Parental Leave .................................................................................................................... 26

Family and Medical Leave .................................................................................................. 27

Notice and Medical Certification ....................................................................................... 28

Insurance Retirement ......................................................................................................... 29

Group Insurance ................................................................................................................. 29

Short Term Disability .......................................................................................................... 29

ACCOUNTING, AUDIT AND FINANCIAL MANAGEMENT POLICIES ...................................... 30

Accounting Policies ................................................................................................................ 30

Cash Management................................................................................................................. 30

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Payments ............................................................................................................................... 30

Checks ................................................................................................................................. 30

Payment of Bills .................................................................................................................. 31

Cash/Petty Cash ................................................................................................................. 31

Cash Receipts ..................................................................................................................... 32

SAMPLE SEGREGATION OF DUTIES ........................................................................................ 33

Cash Disbursements ............................................................................................................... 35

General Ledger Account Coding ....................................................................................... 35

Revenue .......................................................................................................................... 35

Expense and Cost Allowability ......................................................................................... 35

Loan Loss Reserve (Only Applicable for CDCs that Make Loans) ........................................... 36

Collection of Delinquent Accounts. .................................................................................... 36

Write-off of Delinquent Debts/Charges ............................................................................. 36

Financial Reporting Procedures ............................................................................................. 37

Investment/Banking Policies ................................................................................................. 37

Principles: ........................................................................................................................... 37

Procedures: ........................................................................................................................ 38

Budget Principles/Procedures ................................................................................................ 38

Budget Principles ................................................................................................................ 38

Procedures ......................................................................................................................... 38

Adjustments in Budget/Spending Plans ............................................................................. 39

Audit Procedure ................................................................................................................. 39

Whistleblower Policy ............................................................................................................. 39

PROCUREMENT POLICIES ................................................................................................. 42

Introduction and Scope .......................................................................................................... 42

Code of Conduct ..................................................................................................................... 42

Requirements and Protocol ............................................................................................... 42

Disciplinary Actions ............................................................................................................ 43

Acquisition Planning .............................................................................................................. 43

Principles of Acquisition Planning ...................................................................................... 43

Procedures and Documentation Requirements ................................................................ 44

Retention of Documentation ............................................................................................. 44

Solicitations for Goods and Services ...................................................................................... 45

Objective ............................................................................................................................ 45

Principles ............................................................................................................................ 45

Procurement Methods (Types of Solicitations) ................................................................. 47

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Procurement Instruments (Type of Contract) ........................................................................ 51

Objective ............................................................................................................................ 51

Procedures ......................................................................................................................... 51

Procurement Instruments .................................................................................................. 51

Additional Considerations for Procurement of Office Supplies and Equipment ............... 52

Contract Cost and Price and Other Selection Criteria ............................................................ 54

Requirement ....................................................................................................................... 54

Procedures......................................................................................................................... 54

Contractor Monitoring ........................................................................................................... 57

Monitoring Performance. ................................................................................................... 57

Procurement Records ............................................................................................................. 57

Requirement ....................................................................................................................... 57

Solicitation Documentation ............................................................................................... 57

Federal Agency Reviews. .................................................................................................... 57

Contract Provisions and Bonding Requirements Award and Administration ........................ 58

Requirement ....................................................................................................................... 58

Other Award Administration Requirements ...................................................................... 58

PROPERTY/EQUIPMENT STANDARDS ............................................................................... 59

RECORDS MANAGEMENT POLICY..................................................................................... 59

Records Management Policy ................................................................................................. 59

Drug-Free Work Place Policy ............................................................................................ 63

COMPUTER AND INTERNET SECURITY .............................................................................. 64

The Internet and e-mail ......................................................................................................... 64

Computer viruses ................................................................................................................... 64

Access and passwords ........................................................................................................... 65

Physical security ..................................................................................................................... 65

Employee responsibilities .................................................................................................. 65

Copyrights and license agreements ....................................................................................... 66

ACKNOWLEDGEMENT FORM ........................................................................................... 67

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PURPOSE

The Board of Directors of Community Development Corporation (“CDC”), has

developed and enacted the following policies and procedures by virtue of the by-laws of the

organization. This manual was voted on by the board of directors and made effective on

The purpose of this manual is to serve as a reference tool to guide managers in the

administration of the company’s everyday operations and to acquaint employees with the

information they need to understand those policies, practices and procedures.

Since it is not possible to anticipate every situation that may arise in the work place or to

provide information that answers every question, circumstances will undoubtedly require

that policies, practices, procedures and benefits change from time to time. Accordingly, the

Board of Directors for Community Development Corporation reserves the right to

modify, supplement, or rescind any of its policies, practices, procedures and benefits at any

time.

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PERSONNEL POLICIES

Policy on Affirmative Action/Equal Employment Opportunity

Statement

CDC is an Equal Opportunity Employer and recruits, employs, retains, and promotes

persons in all job titles without regard to gender, sexual orientation, race, religion, color,

alienage or citizenship, national or ethnic origin, age, transgender status, marital status,

veteran status, carrier status or disability, except where there is a bonafide occupation

qualification for the job tasks to be performed. In such circumstances reasonable

accommodations for qualified individuals with known disabilities will be made unless doing

so would result in an undue hardship.

CDC will also ensure that all personnel actions such as compensation, benefits,

transfers, layoffs, recalls, transfers, leaves of absences compensation, and training will be

administered in accordance with the principles of equal employment opportunity.

Compliant Procedure

CDC does not discriminate against any employee, volunteer or consultant on the basis

of race, color, cultural heritage, national origin, religion, age, sex, sexual orientation, marital

status, physical or mental disability, political affiliation, source of income, veteran status or

any other status protected under local, state, or federal law. This policy extends to all

personnel decisions, terms and conditions of employment, vendor contracts and provision of

services.

At CDC, we are committed to providing a safe and respectful work environment for all

staff and customers. No one, whether a manager, an employee, a consultant, or a member

of the public, has to put up with harassment at CDC, for any reason, at any time. And,

no one has the right to harass anyone else, at work or in any situation related to

employment.

Harassment is any behavior that degrades, demeans, humiliates, or embarrasses a person,

and that a reasonable person should have known would be unwelcome. It includes actions

(e.g. touching, pushing), comments (e.g. jokes, name-calling) or displays (e.g. posters,

cartoons). Sexual harassment includes offensive or humiliating behavior related to a person’s

sex, as well as behavior of a sexual nature that creates an intimidating, hostile, or “poisoned”

work environment, or that could reasonably be thought to put sexual conditions on a

person’s job or employment opportunities.

If you experience any job related discrimination or harassment based on race, color, religion,

sexual orientation, national origin, age, disability, marital status, amnesty, or if you believe

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you have been treated in an unlawful, discriminatory manner, promptly report the incident

to your supervisor.

CDC will not disclose a complainant’s or alleged harasser’s name, or any circumstances

related to a complaint, to anyone, except as necessary to investigate the complaint or take

disciplinary action related to the complaint, or as required by law. Managers involved in a

complaint are reminded to keep all information confidential, except in the above

circumstances.

Employment

CDC does not offer tenured or guaranteed employment. Thus, the Company or the

employee can terminate the employment relationship at any time for any lawful reason,

with or without cause, with or without notice.

Vacancies

All positions not filled by internal promotion of existing employees will be advertised, and all

applicants will be considered for employment in compliance with all applicable federal, state

and local laws.

Hiring

Board of Directors has the responsibility of hiring the Executive Director upon

recommendation of the Executive Committee, which will interview and screen applicants.

The Executive Director, with consultation of the Executive Committee and appropriate staff,

has the responsibility of hiring all other staff.

During the recruitment, hiring, and orientation process, no statement is to be made promising

permanent or guaranteed employment; and no document should be called a contract unless, in

fact, a written employment agreement is to be used. When candidates from outside of the

company are to be considered for job openings, the following procedures should be followed:

a) All candidates for employment must submit a resume.

b) An interview will be arranged between the applicant and the Executive Director or head

of the department with the job opening.

c) The Executive Director or department head has the responsibility to determine whether

an applicant is technically qualified for the position and if the applicant is compatible

with the work environment.

d) Reference checks are required from all final stage candidates. Written references and

notes on verbal references, if any, become part of the employee's personnel file.

e) Any offer of employment is contingent on a satisfactory check of references and

misrepresentations in the process of application for employment may be grounds

for termination.

f) Applicants must fill out and sign a Conflict of Interest Form and other pertinent

employment forms.

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g) Following a decision to hire the applicant, the Executive Director, department head or

Human Resources will make an offer of employment which should include any

contingencies or disclaimers deemed necessary. This may include a limited term of

employment if a specified funding source, of limited duration, is to be used to fund

the position.

If the background, educational, conflict of interest, or other subsequent investigation discloses

any misrepresentation on the resume or any other written material submitted to CDC

indicating that the individual is not suited for employment the applicant will be refused

employment or, if already employed, will be subject to appropriate disciplinary action up to and

including termination.

A member of an employee's immediate family will be considered for employment provided the

applicant possesses qualifications for employment. An immediate family member may not be

hired, if such employment would:

a) Create either a direct or indirect supervisor/subordinate relationship with a family

member; or

b) Create either an actual conflict of interest or the appearance of a conflict of interest.

These criteria will also be considered when assigning, transferring, or promoting an employee.

For purposes of this policy, "immediate family" includes: the employee's spouse, common-law

spouse, qualified domestic partner, brother, sister, parents, children, step-children, father-in-

law, mother-in-law, sister-in-law, brother-in-law, daughter-in-law, son-in-law, and any other

member of the employee's household.

Employees who marry or become members of the same household may continue

employment as long as there is not:

a) A direct or indirect supervisor/subordinate relationship between such employees; or

b) An actual conflict of interest or the appearance of a conflict of interest.

Employment at Will

Employees hereby understand and acknowledge that, unless otherwise defined by applicable

law, any employment relationship with CDC is of an “at-will” nature.

Employment at Will Disclaimer

This handbook does not constitute as a contract for employment for any period of time but

merely sets forth policies and procedures in effect on the date it was issued. The handbook

may be amended from time to time without prior notice to employees. Furthermore,

additional policies and procedures specific to particular job classifications may be added as

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needed. The Executive Director, is the only person, who has authority to enter into any

agreement or make any promises or commitments contrary to the foregoing.

Employment Status

A normal workweek is Monday through Friday, during the hours of 8:30am to 7:00pm and

consists of thirty-five hours. A normal workday consists of eight consecutive hours of work

with a one hour unpaid lunch period usually taken between the hours of 12pm and 2pm.

Breaks are considered as time worked except as otherwise provided by law. The exact

schedule of hours of work, including lunch and breaks are determined individually by the

department or office which employs the employee.

Full-time

A full-time regular employee is one who works between and hours per week.

Part-time

Part-time employees work less than full-time in a regular job slot.

Temporary Employees

A temporary employee is a person who is hired for a temporary period, generally less than

( ) months. Temporary employees should have no expectation of continued or

regular employment and cannot become a regular employee unless an offer of regular

employment has been made. Unless otherwise specified or as required by law, temporary

employees are not eligible for employee benefits.

Non-Exempt and Exempt Employees

The Federal Fair Labor Standards Act classifies employees as either non-exempt or exempt.

Non-exempt employees receive hourly wages. Under federal law, non-exempt employees

are entitled to minimum wage and, if they work more than hours in a work week, they

are entitled to overtime.

An exempt employee is salaried and is exempt from the provisions of the Fair Labor

Standards Act. This customarily refers to professional, administrative and executive

personnel.

Consultants

Consultants are contracted for a specific scope of work and/or time period and are not

employees of CDC.

Attendance

Employees are required to notify their immediate supervisor within one hour of the scheduled

starting time in the event of illness or other unforeseen circumstances that will result in

tardiness or absence from work.

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Absence without prior approval, including illness, will not be compensated unless the employee

provides proper notification of absence. Proper notification should be given to the immediate

supervisor or the person acting in place of the supervisor in his or her absence. In case of

catastrophic emergency that makes notification impossible, an employee will provide a brief

written explanation upon return to work.

CDC may require doctor's verification for return to work after any absence for illness or

injury of more than three consecutive day’s duration. CDC reserves the right to request

doctor's verification of any illness or injury regardless of duration of absence with special

emphasis on employee's capability to return to work and work restrictions, if any.

Work Schedule and Pay Periods

Work Schedule

All full-time employees typically work a -hour, -day week including meal breaks.

The normal office hours of the organization are [Monday through Friday from

:00 a.m. to :00 p.m]. Non-exempt employees will be paid time and one half for

each hour worked beyond 40 each week or will be awarded compensatory time at a rate of

one hour for every hour over forty hours worked during a single week.

Time Reporting

All employees shall be required to complete time sheets on a weekly basis. Employees

whose salary is funded from multiple federal, state or local sources are required to allocate

their time accordingly to the various funding sources on their time sheet.

Non-exempt employees

Non-exempt employees are required to complete an individual time record showing the daily

hours worked. Timesheets cover one pay period and are to be completed at the close of each

workday and be submitted to their supervisor the last day of the pay period. The following

points should be considered in filling out time records:

a) Employees are to record their starting time, quitting time, and total hours worked for

each workday.

b) Employees are not permitted to sign in or commence work before their normal starting

time or to sign out or stop work after their normal quitting time without the prior

approval of their supervisor.

c) Employees are required to take a lunch or meal break.

d) Employee timesheets are to be checked and signed by the supervisor. Other time for

which an employee is entitled to be paid (paid absences, paid holidays, or paid vacation

time) should be entered on the time record. Overtime also should be entered. Time

sheets should be signed by an immediate supervisor.

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e) Unapproved absences are not considered as hours worked for pay purposes.

Supervisors are to inform employees if they will not be paid for certain hours of

absence.

The filling out of another employee’s time record other than by a supervisor in the employee’s

absence or the falsifying of any time record is prohibited and may be grounds for disciplinary

action, including termination.

Exempt Employees

Exempt employees are required to submit to their supervisor an Absence Record. The Absence

Record must include any vacation, sick time or other leave taken. If the supervisor completed

the Absence Record during an employee's absence, the employee must countersign the

Absence Record upon his/her return. Absence Records must be approved by the employee's

immediate supervisor and forwarded to the .

All employees have a responsibility to accurately report their time. Failure to fulfill time

reporting requirements may result in delay of salary payment or disciplinary action as

appropriate.

The filling out of another employee's Absence Record other than by a supervisor in the

employee's absence or the falsifying of any Absence Record is prohibited and may be grounds

for disciplinary action, including termination.

Pay Practices

Pay Period

Employees will be paid on a bi-weekly cycle unless pay day falls on a holiday or weekend, in

which case staff will be paid on the last working day before that holiday or weekend. Employees

are encouraged to have direct deposit payroll.

On pay day employees will be sent a check in the office which they report for work or a pay stub

showing the pay that has been deposited in their bank account. New employees will receive a

paycheck until direct deposit can be arranged.

Direct Deposit

Employees can "Direct Deposit" their payroll check into the bank of their choice by completing

the direct deposit application accompanying the package received at orientation or by

requesting a Direct Deposit form from Human Resources or the department in charge of

payroll.

The Direct Deposit process can take up to three pay periods for completion. During processing,

employees will continue to receive checks until the first electronic transfer takes place. When

the "Direct Deposit" takes effect the employee will receive a pay stub showing the details of

salary payment and total amount deposited in the bank.

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An employee should contact the promptly upon noting a problem with the Direct

Deposit process or change of banks. CDC will work with the payroll company, if

applicable, and the bank to rectify any problem, however, CDC is not responsible for any

errors with the direct deposit process.

Wage Garnishments

Garnishments are a legal procedure through which an employee's earnings must be withheld

for the payment of a debt.

When a garnishment notice is received, the will follow the appropriate Federal and State

Laws relating to wage garnishments. The or will make every effort to contact the

employee at this time concerning how the garnishment affects them and answer any questions

regarding the process.

Outside Employment

does not wish to limit your outside activities or control your time outside of work hours

as long as it does not interfere with your work performance or the business interests of the

organization. If you work on a full-time basis, considers itself your primary employer and

requires you to devote your full time and attention to your job duties each day while at work.

Employee have a full-time responsibility to CDC and may not engage in activities that

might interfere or conflict with the discharge of this responsibility, or in transactions that may

affect the judgments they exercise on behalf of the company. Accordingly, CDC requires

conformance with a variety of regulations governing service to outside organizations (as a

trustee, director, consultant, or in a similar capacity) as well as, disclosure of information, fees

and payments, investments and other related issues.

The does not automatically prohibit secondary employment however the employee

must obtain prior approval in writing for such employment.

Conflict of Interest

No employee will participate in activities or other employment that cause a conflict of

interest with the activities of CDC. Activities or employment that create possible

conflicts will be disclosed to the Executive Director in writing for review.

Any employee of the organization, who accepts gifts or gratuities from individuals,

companies, clients, or suppliers in conjunction with their job, will be subject to disciplinary

action up to and including dismissal.

No CDC employee is to become involved in real estate development, outside of his or

her work at CDC, in any neighborhood where CDC operates a program.

No officer or employee may serve as an official, director, or trustee of any for-profit or non-

profit enterprise without obtaining the approval of their immediate supervisor.

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CDC encourages service with constructive and legitimate not-for-profit organizations.

Participation in civic affairs is encouraged as part of our commitment to community

involvement. There are cases, however, in which organizations have business relationships

with the organization in which the handling of confidential information might result in a

conflict of interest. An employee’s immediate supervisor must be advised when a potential

conflict exists.

Policy Prohibiting Unlawful Harassment, Including Sexual

Harassment

It is the policy of CDC that it will not tolerate verbal or physical conduct by any

employee which harasses, disrupts, or interferes with another’s work performance or which

creates an intimidating, offensive, or hostile environment.

As an equal opportunity employer, it is CDC’s policy that every applicant and

employee shall enjoy a work environment free from all forms of unlawful harassment,

including sexual harassment. Unwelcome verbal, physical or visual conduct involving any

individual’s race, color, religion, sex, sexual orientation, pregnancy, age, national origin,

ancestry, citizenship, medical condition, physical disability, marital status, or military service,

or any other basis protected by any federal, state or local law which impairs an employee’s

ability to perform their job is illegal and is strictly prohibited.

Sexual harassment is an unlawful employment practice under Title VII of the Civil Rights Act

of 1964 and various state laws. The regulations of the Equal Employment Opportunity

Commission define “sexual harassment” as follows:

Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct

of a sexual nature constitute sexual harassment when:

a) submission to such conduct is made either explicitly or implicitly a term or a condition

of an individual’s employment; and

b) submission to or rejection of such conduct by an individual is used as the basis for

employment decisions affecting such individual; or such conduct has the purpose or

effect of unreasonably interfering with an individual’s work performance or creating

an intimidating, hostile or offensive working environment.

Some examples of sexual harassment include, but are not limited to, the following:

a) Unwelcome requests for sexual favors or dates.

b) Unwelcome physical touching.

c) Jokes or gestures that have a sexual content or sexual connotation.

d) Posters or cartoons that have a sexual content or sexual connotation.

e) Sending or forwarding written or electronic correspondence of a sexually explicit

nature.

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f) Creating an otherwise offensive working environment or unreasonably interfering

with another’s ability to perform his or her job.

CDC does not condone sexual relationships between supervisors and their staff. A

relationship of this type can easily be considered sexual harassment. If such a relationship

develops, one of the individuals must transfer to another position in the organization.

Both as a matter of law and common decency, each employee of CDC is entitled to

pursue his or her employment, free of harassment or discrimination on any of the prohibited

bases enumerated above. Accordingly, unlawful harassment or discrimination against any

employee of CDC will not be tolerated. Violation of this policy may subject an

employee to discipline, up to and including immediate termination.

Any employee who believes that he or she (or another employee) is the object of

harassment or discrimination on any of the above-enumerated bases is strongly encouraged

to follow the complaint procedure outlined below.

Any employee may initiate the complaint procedure, without fear of reprisal, by immediately

reporting such complaints to the:

a) the employee’s immediate supervisor.

b) The , if the employee feels that he or she is unable to report a complaint to his

or her immediate supervisor.

c) an officer of CDC, if the employee feels that he or she is unable to report a

complaint to the .

CDC takes all complaints of harassment or discrimination seriously. All complaints will

be investigated immediately by an impartial designee to be determined by senior

management of CDC.

Any employee who believes that the actions or words of a supervisor or fellow employee or

some other person(s) encountered in the workplace constitute unwelcome harassment has a

responsibility to report such incident as soon as possible to the appropriate supervisor,

manager or officer of CDC. Employees are encouraged to utilize the foregoing

complaint procedure. No employee will be retaliated against for having opposed unlawful

harassment or discrimination, or for having filed a complaint or otherwise participating in an

investigation concerning a complaint.

Employees are also notified that there are governmental agencies that handle claims of

unlawful discrimination and harassment. These agencies include the Equal Employment

Opportunity Commission and parallel state agencies.

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Each employee will be required to sign an acknowledgment of the Policy Prohibiting

Unlawful Harassment, Including Sexual Harassment contained at the back of this manual.

Personnel Files and Employment Information

All staff members have a right of access to their personnel file, with the exception of access

to reference checks that were obtained in confidence. The staff member may review the

folder in the presence of their immediate supervisor. It is the responsibility of the staff

member to provide information to their supervisor to keep personnel folders up-to-date

(e.g., current resumes, change in marital status, name, address, telephone numbers, number

of dependents, designated beneficiaries, education and training skills).

The employee’s immediate supervisor is authorized to verify the following information for a

prospective creditor of an employee: 1) dates of employment; 2) title; and, 3) salary.

Neither the Executive Director nor any employee is authorized to provide a prospective

employer of a present or former employee of the organization with any information other

than dates of employment and title.

Resignation, Suspension, Termination, Reduction

Resignation

Employees who wish to resign from their positions should give weeks written notice

to their immediate supervisor with the reasons stated therein. If weeks notice is not

given before resignation, the employee may lose any accumulated vacation time or other

benefits.

Suspension

Suspensions usually occur after verbal warnings or written warnings are issued. However, an

employee may be suspended by the Executive Director without pay for breach of client

confidentiality, unsatisfactory job performance, and/or just cause. The Executive Committee

must review the facts of the case at or before the next regularly scheduled board meeting to

either confirm or reverse the suspension. The decision of the Executive Committee will be

given in writing.

Termination

Dismissal will be issued for unsatisfactory job performance, violation of the Personnel

Policies and Procedures, illegal acts, or any other just cause as determined by the Executive

Director. Written notice of termination will be given with reasons for the action stated to

the employee. Immediate termination will occur for breach of client confidentiality, theft,

and/or just cause. Unsatisfactory job performance includes, but is not limited to excessive

absenteeism, tardiness, failure to cooperate with other employees, and unauthorized use of

company property. In addition, CDC reserves the right to terminate an employee at

any time with or without notice, for any reason, or for no reason at all. For more details,

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refer to Corrective Action and Termination in Section Three Performance and Discipline

section.

The Board of Directors has the responsibility for the termination of the Executive Director

upon recommendation of the Executive Committee in accordance with these policies.

If a terminating employee is eligible for any incentive compensation, bonus, and/or awards,

they must be actively employed on the date the compensation, bonus and/or awards are

paid.

Reduction

If an employee must be terminated due to a reduction in workforce, he or she will be

notified 30 calendar days prior to the event, if possible.

Grievance Procedure

An employee is encouraged to make use of the following grievance procedure after s/he has

made a good faith effort to approach the supervisor in an attempt to correct issues.

Step 1: The employee shall present the initial grievance in writing to the immediate

supervisor within ( ) working days after the event or action that is the basis for

the grievance. Promptly, and usually within three working days of receipt of the grievance,

the immediate supervisor will arrange a meeting with the employee. Soon afterwards, the

supervisor will provide the employee with a written response to the grievance. If the

employee does not agree with the response, the employee may forward the grievance to the

Executive Director within ( ) working days of receipt of the supervisor’s written

response.

Step 2: Promptly, and usually within ( ) working days of receipt of a grievance,

the Executive Director will meet with the employee and the supervisor. Following this

meeting the Executive Director will promptly provide a written response to the employee. If

the employee does not agree with the response, the employee may forward the grievance to

the Executive Committee (Board Officers) within ( ) working days of receipt of

the Executive Director’ written response.

The Executive Committee will meet promptly to hear the employee’s grievance. Under most

circumstances, the meeting shall be within ( ) working days of receipt of the

request for an appeal. The Executive Committee will promptly furnish its findings to the

Executive Director and the employee. The decision of the Executive Committee shall be final

and binding.

If the employee feels intimidated or threatened by pursuing any of the steps in this grievance

procedure, s/he is urged to bring this concern directly and immediately to the Executive

Director.

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Travel and Other Expenses

Employees will be reimbursed for approved business travel and other expenses that is pre-

approved by the employee’s immediate supervisor. Travel expenses and other expenses

include the following:

a) Mileage for employees using personal automobiles for travel will be reimbursed at

the current IRS approved mileage rate. All requests for reimbursement will be

documented on the approved reimbursement form available in the office.

b) Mass transit, taxi or car service to carry out business. Staff should consider

overall costs before selecting a mode of transportation. Mass transit is by far the

least expensive. If feasible for the nature of your journey please take mass transport.

Reimbursement will be calculated on a per trip basis.

c) Temporary dependent care costs (as defined by 26 U.S.C. 152) above and beyond

regular dependent care that directly result from travel to conferences, are a direct

result of the employee’s travel for work, and are only temporary during the travel

period. Travel expenses for dependents will not be reimbursed.

d) Personal meals incurred by an employee when eating on an out-of-town business

trip. Employees must travel more than 50 miles round trip from their home office to

qualify for reimbursement.

e) Business meals taken with clients, prospects or associates during which a specific

business discussion takes place.

f) Tips included on meal receipt will be reimbursed. Tips should be no more than 20% of

the bill.

We strongly recommend that all travel arrangements that require airfare and lodging

be book through . If you are attending a conference that offers a reduced hotel rate at

the conference hotel, you should book your room directly to access the reduced rate, rather

than using . Conference and workshop related travel must be approved by an

employee’s supervisor in advance of the trip.

When traveling by air, reimburses for economy class only. When traveling by rail,

coach travel, not the Acela, should be used.

Make every effort to purchase the lowest possible fare. All airline travel should be booked at

least 14 days in advance of the trip. If an employee is booking their travel less than 14 days in

advance, such employee must provide written explanation on the expense report explaining

why the trip was not booked 14 or more days in advance of the departure date.

Reimbursement requests may be submitted as often as once a month. Expenditures from the

previous fiscal year can be reimbursed only on requests received prior to the year-end closing

of the books, by no later than .

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PERFOMANCE AND DISCIPLINE

Pay Raises and Bonuses

Pay raises and bonuses (if applicable) will be determined annually by the Board of Directors

and the Officers of CDC. In the event that there are monies available for

compensation increases, these increases will be paid as salary and/or bonus according to

exempt or non-exempt status and determined by attainment of performance standards.

Bonus compensation may only be paid to exempt staff only. Bonuses are based on goal

achievement in the previous year and are paid to both reward over achievement and as an

incentive to continue future performance. Like pay raises bonus pay will be paid as salary.

Performance Appraisals

The Performance Appraisal process for Exempt and Non-Exempt employees is the foundation

for all compensation activity and provides a unique opportunity to unite the employee's

accountabilities and achievements to the objectives and strategic plans of the organization.

Supervision and Evaluation

The Chairman of the Board of Directors is the direct supervisor of CDC’s Executive

Director, and in conjunction with the Executive Committee of the Board of Directors, will

conduct an annual performance evaluation of the Executive Director. The Executive Director

is the direct supervisor of each individual employee. In the event that there are Program

Directors, the Program Directors are the direct supervisors of the support staff in their

program.

Performance Evaluations

believes in the importance of employee performance evaluations. All employees will

be evaluated by their direct supervisor using established standards of performance for their

position, on a semi-annual basis in January and June. The evaluation is based in job

performance with regard to applicable skills, productivity, quality of work, attitude and

cooperation, dependability, job knowledge and effectiveness, and other areas applicable to

specific employee categories. Attendance and punctuality are a major factor in an

employee’s overall review.

Initial Evaluation

The immediate supervisor or the Executive Director (see above) will perform an evaluation,

three months after employment with the organization.

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Corrective Action and Employment Termination

Most employees want to do a good job. Supervisors shall help employees succeed on the

job by:

a) Providing a thorough orientation for new employees

b) Clearly establishing expectations for behavior and performance

c) Providing training, coaching, and mentoring

d) Providing feedback through appropriate supervision

However, in every workplace there will be situations where an employee fails to meet

expectations or where an employee commits acts of misconduct. There may be times when,

despite all of the supervisor's best efforts, the employee continues to demonstrate

unsatisfactory performance or problem behavior.

Forms of Corrective Action

When corrective action is necessary, the amount and type of action taken depends on the

particular circumstances. CDC maintains the discretion to determine what corrective

action is appropriate in each situation, regardless of what correction the employee may have

received previously. For example, in some circumstances, it may be appropriate to give an

additional written warning before taking any stronger action, while in other circumstances it

may be appropriate to take strong action including termination, without any previous

warnings or suspensions.

Though other forms of corrective action are also possible, these are the types most often

taken.

a) Counseling: If a supervisor becomes concerned about an employee’s performance at

work, s/he may meet with the employee to discuss concerns and develop ways to

address the concerns.

b) Oral Warning: The supervisor meets with the employee to review the prior

discussions and state her/his continuing concern with the employee’s performance.

The supervisor should clearly identify the purpose of this meeting as an oral warning,

which is part of the corrective action. A summary of the oral warning meeting may be

given to the employee with a copy retained by the supervisor and a copy kept in the

employee’s personnel file.

c) Written Warning: If the employee’s performance does not improve after an oral

warning, or if circumstances otherwise warrant it may be necessary to give a written

warning to an employee which may include the following:

i. Current level of performance and areas requiring improvement

ii. Specific level of performance expected in each of the identified deficiencies

iii. Time frame for improvement

iv. Steps the supervisor will take to support improvement

v. Specified time for follow-up meeting

vi. Consequences if performance does not improve, the employee should read

and sign the written warning. In signing, the employee acknowledges that

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s/he has read and understood the document. The signature does not imply

agreement.

d) Termination: may dismiss an employee when this action is in the

organization’s best interest. Employees should remember that employment with the

is by mutual consent. Both employee and the agency are free to terminate the

employment relationship at any time and for any reason.

Occasions for Corrective Action

Listed below are some of the kinds of behavior or performance that may lead to corrective

action. It is, of course, not possible to list all of the kinds of problems that may occur in the

work place; other kinds of behavior or performance may also lead to corrective action.

a) Unsatisfactory job performance

b) Excessive absenteeism or tardiness, or failure to contact supervisor about absence

c) Violation of procedures or rules

d) Theft or willful damage of the property of the agency or other employees

e) Refusal to perform work as directed or willful neglect of duties

f) Violent or abusive behavior or language

g) Acceptance of any gifts, favors, other remuneration from any individual or firm

having or proposing to have any relationship with the

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BENEFITS

Benefits

CDC provides a benefits package for all eligible full and part-time employees which

include the following:

Vacation Days

Vacation is accumulated from the start of employment for full time employees at the rate of

days per month, up to the first anniversary date of employment - weeks vacation

in the first year. It is not expected that employees will take a vacation within the first

months.

Upon completion of six months of service, employees may take their accrued vacation at any

time subject to the approval of their supervisor.

a) During the second year of employment and each year thereafter, full-time employees

will accrue vacation day credit at the rate of days per month - weeks

vacation each year.

b) Accrued vacation days not to exceed days may be carried over from one calendar

year to the next calendar year.

c) Upon completion of one year service, employees may take up to a maximum of

weeks vacation at one time, subject to the approval of the supervisor. Any accumulated

vacation over days at year-end is forfeited.

d) All eligible staff members receive vacation pay based on their regular earnings, not

including overtime or other additional compensation.

e) The base period for computing vacation time is the anniversary date of employment.

f) Vacation time may be taken in full day or half day increments.

g) If an authorized holiday occurs during an employee's approved vacation period, the

employee will be paid for the holiday and therefore uses one less vacation day than

total number of days in the vacation period.

h) Part-time employees accrue vacation time on a pro-rated basis.

i) Hourly part-time employees are not eligible for vacation, personal or sick time.

j) Approval of the employee's vacation will be obtained from the immediate supervisor

subject to CDC business needs. All employees should notify their immediate

supervisors as far in advance of their planned vacation as possible. The supervisor will

forward authorized vacation requests to the Payroll Manager.

k) An employee may request that an absence for illness in excess of the time allowed

under sick day accrual be taken as vacation time and charged against his/her

accumulated vacation. This request requires approval of the staff member's immediate

supervisor and .

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Personal Excused Absence

Personal excused absence is available to staff members from date of hire. personal

excused absence days are provided on a calendar year basis and cannot be carried over.

Unused days will not be compensated.

Part-time staff members are eligible for personal excused absence days on a pro-rated basis

with prior approval of their supervisor.

Personal Sick Leave

Personal sick leave will be accumulated as follows: days at one year of service,

days at years of service, and days at years of service. Any unused sick

leave will be forfeited at year’s end. All accumulated sick time is also forfeited upon

termination of employment for any reason.

Bereavement

working days of paid bereavement leave will be granted to employees who have a

death in the immediate family. The immediate family is defined as grandparents, parents,

children, spouses, domestic partners and siblings.

Bereavement leave for death of any person other than immediate family must be approved

by your immediate supervisor and the department head. Absence for such a death is limited

to ( ) days and will be unpaid.

Holidays

CDC recognizes the following paid holidays:

1. New Year’s Day

6. Labor Day

2. Martin Luther King, Jr. Day

7. Columbus Day

3. President’s Day

8. Veteran’s Day

4. Memorial Day

9. Thanksgiving

5. Independence Day

10. Christmas Day

On National Election Day CDC allows all staff up to hours time off to vote, or time

off as required by local law An employee must notify his/her supervisor in advance when time

off to vote is to be used.

Leave of Absence (non FMLA)

Employees are eligible to apply for an unpaid leave of absence if they have been a regular

employee for at least one year and scheduled to work hours or more per week.

Employees requesting an unpaid leave of absence must do so in writing at least days

in advance unless it is impractical to do so, in which case the employee must provide as

much written notice as possible. The request must be submitted to the Executive Director.

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Granting of such leave is at the discretion of the Executive Director except in such cases

where granting of leave is required by law, such as the Family Medical Leave Act.

Jury Duty

CDC supports employees called to fulfill their civic duty to serve on jury duty. Employees

must provide his/her immediate supervisor with a copy of the jury duty summons. In

addition, the employee and will receive his/her regular salary, up to hours per week,

for a maximum of ( ) weeks.

Adequate proof of service must be provided to receive your regular salary during jury duty. If

the amount you are compensated by the court, per day, exceeds ($ ) dollars per day,

your regular pay will be offset by the excess offset.

Worker’s Compensation

Employees who are injured on the job are covered by Worker’s Compensation Insurance. It is

your responsibility to immediately notify your immediate supervisor or one on duty. The

supervisor will notify your personnel representative. CDC encourages injured

employees to seek immediate medical attention.

Disability Leave

A disability leave of absence should be requested in writing and should be submitted to an

employee’s immediate supervisor as soon as practical and with a doctor’s recommendation

and medical documentation. The request should indicate the date on which the employee

will stop work and a projected return date. CDC will hold the job or one at the same

level of any employee on disability leave for a period of up to months.

After the employee’s sick leave is exhausted, vacation and/or compensatory time may be

used for continued absence.

The employee will contact their immediate supervisor as soon as possible regarding their

intentions to return to work or not, following an absence due to illness. Pregnancy will be

considered a temporary medical disability for purposes of this document.

A leave of absence for disability purposes will not constitute a break in tenure for purposes

of calculating length of service; however, no additional sick leave or vacation time will be

accumulated during the absence.

Military Service

Full-time, regular employees who are inducted in the Armed Forces are considered to be on

leave of absence without pay and accrue only those benefits specified by law. Upon

completion of military assignment, the employee is eligible for rehire in their former job or a

job of similar status and pay providing the following conditions are met:

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The employee must have been employed in a position other than temporary before their

induction;

a) They must have left their job to enter military service;

b) They must have received certificate(s) of satisfactory completion of military service;

c) They must apply for re-employment within calendar days of their discharge;

and,

d) They must be able to perform the duties of their former job or a job of similar status.

Veterans will be re-employed with the same seniority, status, and pay they would have had if

they had not entered military service.

National Guard/Reserves

Staff members who are members of the National Guard or the Reserve will be granted a

leave of absence for any period or required service with their unit other than normal tour

duty. All benefits will accrue during such periods and such duty will not be considered a

break in service. The employee must be reinstated in their position providing they meet all

of the conditions listed under Military Service (Section G) with the following exception:

The employee must report to work at the beginning of the next regularly scheduled working

period following their release from duty.

Employees who must take time off to participate in the Reserve or National Guard must

submit a written request for leave to the immediate supervisor indicating the period of

absence and the expected return date.

Parental Leave

Parental leave is available for employees who become parents or have special needs associated

with the birth or adoption of a child. The Parental Leave Plan provides for a combination of

paid and unpaid. Employees are eligible for Parental Leave after at least one year or service and

have worked at least hours during the months before becoming a parent. The

employee must also have become a parent through birth or adoption of a child and the child

must live in the staff member's household. If all of the above circumstances are met, the

following conditions apply:

a) An eligible employee who becomes a parent may receive up to weeks of leave at

full pay per year. Leave may begin weeks before birth or adoption, or within

months after birth or adoption, at the staff member's option.

b) During the four weeks of paid leave, the employee will continue to receive and to

accrue benefits for which he/she was eligible before beginning leave, i.e. coverage

under CDC health plan, contributions to the Pension Plan and accrual of vacation

and sick leave time.

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c) Leave need not be taken consecutively, but must be taken in the time period from four

weeks before to months after the date the employee becomes a parent. A

schedule for the use of Parental Leave must be approved by the immediate supervisor.

d) Unpaid leave may be used to extend the time off due to birth or adoption of a child but

except for the employee’s medical disability total Parental Leave may not exceed three

months. Total Parental Leave is all leave paid and unpaid due to the birth or adoption of

a child. Health benefits will continue during the period of unpaid leave. Please see the

Family and Medical leave section of this Guide for additional information.

e) In cases where both parents are eligible CDC employees, a combined total of

weeks of fully paid Parental Leave will be permitted. The parents may divide the

leave between them as meets their need.

f) A staff member who returns from Parental Leave on a timely basis will be restored to his

or her former position or to an equivalent position with equivalent benefits, pay and

other terms and conditions of employment. Certain "key" employees, i.e., those who

are among the highest paid 10 percent of employees may be denied restoration to his

or her former position in order to prevent "substantial and grievous economic injury" to

the company.

g) A staff member's use of any other leave entitlement will not result in a reduction of

Parental Leave benefits, except that Parental Leave shall be counted against the time

available for childbirth or adoption and unpaid leave taken under the Family and

Medical Leave Plan for the adoption or birth of a child be counted against the maximum

leave allowed under CDC Parental Leave Plan.

h) Leave unused under this policy is not payable in cash, nor can it be converted to any

other benefit. It may not be delayed or extended beyond months from the date

that the employee became a parent.

i) Any time away from work taken by an employee under CDC Parental Leave Policy

shall be counted towards the weeks of leave available to such employee under

the Family and Medical Leave policy.

Family and Medical Leave

CDC is committed to providing family and medical leave to all eligible employees (as

described below) in compliance with the Family and Medical Leave Act ("FMLA") of 1993 (the

"Act").

Employees are eligible for an unpaid leave if they have worked for CDC at least one year,

and have worked at least hours over the months preceding leave. This policy is

applicable to eligible employees regardless of status (e.g., single, employee with spouse or

employee with domestic partner).

Reasons for Leave

An eligible employee shall be entitled to a family or medical leave for one or more of the

following reasons:

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a) the birth of a son or daughter and to care for the new born child if the leave is taken and

concluded within months of the birth of the child;

b) The placement with the employee of a child for adoption or foster care if the leave is

taken and concluded within months of the placement of the child;

c) to care for an employee's spouse, child or parent (“family member”) with a "serious

health condition;" and

d) because of an employee's own serious health condition which makes him or her unable

to perform the functions of his or her job.

With regard to the illness of an employee or family member, FMLA leave generally does not

apply to brief illnesses, such as absences of less than calendar days which do not involve

ongoing treatment by a physician or health care provider. Leave under this policy is permissible

only for a "serious health condition," which is intended to cover conditions which require

hospitalization or continuing treatment by a healthcare provider.

The availability of this unpaid leave does not affect the employee's eligibility, if any, for short or

long term disability for serious illnesses. However, if any employee takes short or long term

disability, the period of receiving such disability benefits shall be counted towards the

maximum 12 week period of unpaid leave available under ’s Family and Medical Leave

policy.

Length of the leave

Eligible employees may take up to weeks of unpaid leave within a month

period. However, if both parents (including domestic partners) work for CDC, they are

eligible for a combined leave of weeks in a month period for the birth, adoption

or foster care placement of a child. Each employee is eligible for weeks because of his

or her own serious health condition or to care for a family member with a serious health

condition.

In determining eligibility for leave, CDC shall use a "rolling" month period

measured backward from the start of the employee's leave period. Any time leave is

requested, CDC shall determine how much leave the employee has taken during the

immediately preceding months. The employee shall be entitled to the balance of the

weeks which has not been used. Total Parental Leave taken by the employee during the

yearly "rolling" month period is concurrently FMLA leave and shall be deducted from the

weeks of unpaid leave available under the Family and Medical Leave Plan.

Notice and Medical Certification

When the need for leave is foreseeable, an employee must provide thirty days advance notice

before leave is to begin. If leave is not foreseeable, an employee must provide as much notice

as is practicable. The failure to provide the required notice may result in the denial of the leave

until proper and timely notice is given.

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When an employee is taking leave because of his or her own serious health condition, the

employee must comply with the documentary requirements of CDC short term disability

plan. When an employee is taking leave because of a family member's serious health condition,

the employee shall be required to submit certification from a health care provider to

substantiate the request. The completed certification must be submitted within days of

the requested leave, except in unusual circumstances. Failure to provide the required medical

certification may result in the denial of all privileges and benefits under this policy. An

employee may also be required to provide subsequent recertification to support any continuing

FMLA medical leave.

Insurance Retirement

CDC provides a benefit package to all full-time employees which includes the

following:

a) Individual or Family Health Insurance

b) Short and Long Term Disability

c) 403b – retirement

d) Life Insurance

Group Insurance

CDC makes health insurance, life insurance and accidental death coverage (group

benefits) available to eligible employees and their eligible family members.

Short Term Disability

Short term disability benefits are designed to provide a pay check to employees during

periods of serious illness resulting in total disability by providing a continuation of income

during periods of serious illness resulting in total disability. Regular full time employees are

eligible for STD benefits and may consult with your immediate supervisor or HR office for

more detailed information on eligibility.

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ACCOUNTING, AUDIT AND FINANCIAL MANAGEMENT

POLICIES

Accounting Policies

It shall be the policy of CDC to create and maintain accounting, billing, and cash

control policies, procedures and records which are consistent with Generally Accepted

Accounting Principles (GAAP) and meet the requirements of 2 CFR 200.302.

CDC‘s fiscal year starts on 1 and ends on .

uses the accrual basis of accounting for all transactions consistent with GAAP.

CDC accounting, audit, and financial management policies are designed to do the

following:

a) Protect and secure the assets of CDC.

b) Ensure the maintenance of accurate, current and complete records of the financial

results of each award.

c) Identify the source and application of all federal award funds.

d) Ensure compliance with governmental and private funder reporting requirements.

e) Bank accounts are established as required by donors and funding requirements.

f) The Executive Committee must authorize all bank accounts and approves all check

signers. The approval of signers shall be reflected in the Board of Director’s meeting

minutes.

g) Bank transfers are scheduled and investigated to ascertain that both sides of the

transaction are recorded.

h) Compare expenditures with budget amounts for each Federal award to ensure that

costs do not exceed the budgeted amounts.

Cash Management

Consistent with 2 CFR 200.305, payment methods will minimize the time elapsing between

the transfer of funds from the United States Treasury or a pass-through entity and the

disbursement by CDC whether the payment is made by electronic funds transfer, or

issuance or redemption of checks, warrants, payment by other means. CDC will also

minimize idle cash balances.

Payments

Checks

All checks above $ written on CDC accounts require two authorized signatures.

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All persons approved to sign checks will formally be approved by the CDC’s Board of

Directors.

The payee and check signer cannot be the same person. Other authorized persons shall sign

reimbursement checks payable to a check signer.

Banks should promptly be notified of all changes of authorized check signers.

All checks are to be pre-numbered and accounted for by a check custodian (used, voided,

and not used).

Voided checks are to be properly defaced and maintained.

Bank reconciliations to the general ledger are to be done monthly and provided to the

Executive Director or Treasurer at regular Board meeting.

Payment of Bills

Two authorized persons should approve all bills. The Executive Director, and/or

authorized person must approve, in writing, all invoices for payment via e-mail, initials,

signature or stamp.

Vendor invoices must be recalculated on site to ensure accuracy. This recalculation must

occur prior to the preparation of a check to pay the invoice. After the recalculation is

complete, the employee who performed the recalculation must initial the vendor invoice,

indicating the amount is correct and the invoice can be paid.

Checks for payment are signed only when supported by approved invoices (checks will not

be processed and signed in advance of proper invoicing approval procedures).

Check signers should compare supporting data/documents against checks presented for

their signature.

The employee responsible for mailing checks will not be responsible for recording cash

disbursements. These two functions must be handled by different employees to ensure that

the appropriate checks and balances are in place.

All costs must be considered reasonable. A cost is reasonable if it does not exceed that which

would be incurred by a prudent person under the circumstances prevailing at the time the

decision was made to incur the costs.

Cash/Petty Cash

Petty cash should be used for such things as small and odd jobs, local travel and sundry

items. It is not intended for purchases that can be made with designated suppliers.

Activities or needs should be planned ahead so necessary funds will be available in the petty

cash account.

Receipts or itemized slips are required for every petty cash disbursement. The Executive

Director or his/her designee will be responsible for verification of receipts and cash.

Whenever petty cash is used, a pre-numbered “Receipt of Petty Cash” slip must be filled out.

A completed slip will include date, the amount taken and returned, the cash category and

the total spent. When a staff person receives cash, he/she will sign on the “Received By” line

of the petty cash log. Items purchased should also be listed on the log, unless the receipt

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that must always be clipped to the log lists items purchased. The Executive Director or

his/her designee will sign on the “Approved By” line of the petty cash log.

The Finance Officer will be responsible for the reconciliation and replenishment of the petty

cash account.

Cash Receipts

Someone other than the person making deposits is responsible for opening the daily mail,

making a log of cash receipts, restrictively endorsing the payment, making note of any

restrictions on the log entry, and account coding the receipt by receivable or revenue

account.

The Executive Director or an authorized person should prepare all bank deposit slips, listing

each item separately.

Receipts are deposited daily or kept in a safe. For all deposits the bank’s stamped duplicate

deposit slip should be attached to the remittance documentation.

The deposit log with the duplicate deposit slips should be forwarded to the Financial Officer

for verification and data entry.

All cash should be deposited in the appropriate bank account based on funding restrictions.

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SAMPLE SEGREGATION OF DUTIES

TWO PERSON DISTRIBUTION OF

DUTIES

THREE PERSON DISTRIBUTION OF

DUTIES

FOUR PERSON DISTRIBUTION OF

DUTIES

Individual A

Open and review bank statements

Open and review bank

statements

Open mail and prepare list of checks

received

Review accounts receivable aging

Void invoices and or create credit

memos

Sign checks

Void invoices and/or create credit

memos

Approve invoices

Review accounts payable aging

Approve invoices

Sign checks

Sign payroll checks

Sign checks

Review accounts payable aging

Perform interfund transfers

Review accounts payable aging

Void checks and/or create debit

memos

Reconcile petty cash

Void checks and/or create debit

memos

Approve employee timesheets

Individual B

Approve employee timesheets

Sign payroll checks

Physical access to petty cash or

undeposited funds

Sign payroll checks

Distribute payroll checks

Create invoices

Distribute payroll checks

Sign employee contracts

Enter records into general ledger

Sign employee contracts

Perform interfund transfers

Approve payroll

Perform interfund transfers

Reconcile petty cash

Sign employee contracts

Reconcile petty cash

Individual B

Individual C

Physical access to petty cash, and/or

undeposited funds

Physical access to petty cash and/or

undeposited funds

Open mail and prepare list of

checks received

Reconcile bank statements

Create invoices

Prepare bank deposit

Create invoices

Enter records into general ledger

Write/print checks

Enter records into general ledger

Approve payroll

Prepare bank deposit

Write/print checks

Individual C

Individual D

Approve payroll

Reconcile bank statement

Reconcile bank statements

Open mail and prepare list of checks

received

Void invoices and/or create

credit memos

Prepare bank deposits

Approve invoices

Write/print checks

Void checks and/or create debit

memos

Approve timesheets

Distribute payroll checks

Individual A = Executive Director or other top manager/board member

Individual B = Primary accounting assistant or office manager

Individual C = Second accounting assistant or another manager level employee

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Individual D = Another manager level employee

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Cash Disbursements

All cash disbursements should be made by check (with the exception of petty cash).

General Ledger Account Coding

All cash receipts and disbursements should be accounted for, coded, and reviewed by the

Executive Director, or authorized person.

Funding from multiple sources may be kept in a bank account with other funding; however,

it must be tracked independently. CDC will establish separate set of account for each

grant within its chart of accounts and general ledger.

Supporting documentation should be noted as paid and include the check number, date

paid, and general ledger account code.

Account coding for each payment is reviewed for accuracy.

CDC finance and accounting staff will ensure that all costs paid through the utilization

of external funding sources are recognized as ordinary, necessary, within the budget, are

arms-length transactions, and do not deviate from established practices of the organization.

Revenue

Revenue is earned using the accrual basis of accounting.

Cost reimbursement grants or contracts earn revenue when the expenses are incurred (not

committed).

Expense and Cost Allowability

When there are Federal funds involved, CDC will follow 2 CFR 200 Subpart E, the cost

principles. In these instances, programs and grants will not be charged for 2 CFR 200

unallowable items such as, but not limited to: entertainment, fundraising expenses,

lobbying, selling and marketing, bad debts, fines or penalties or interest on debt.

Before CDC seeks reimbursement from a funder, it will ensure that the costs are

considered allowable under the federal grant. Costs cannot be considered allowable unless

they:

a) are necessary, reasonable and allocable to that funder and within the grant period

b) are adequately documented,

c) have not been allocated to or included as a cost of used to meet cost sharing or

matching requirements of any other federal award in either the current or a prior

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period, except when allowed by federal law or regulation.

d) Expenses are charged to grants based upon a shared cost rationale when the direct

charge cannot be established. A cost will not be assigned to a federal award as a

direct cost if any other cost of the same purpose in like circumstances has been

allocated to the federal award as an indirect cost.

Expenditures for each grant, loan, or contract are to be recorded according to the budget

categories for that particular funding source. For each funding award, CDC will

maintain records that allow for a comparison of outlays with approved budget amounts.

Loan Loss Reserve (Only Applicable for CDCs that Make Loans)

Periodically, members of the Executive Committee, the Executive Director, and members of

the finance and accounting department should meet to review the adequacy of the

organization’s loan loss reserve Necessary adjustments should be determined and made at

least quarterly.

Collection of Delinquent Accounts.

CDC may utilize outside collection agencies if all past efforts to collect outstanding

debt are exhausted.

Upon approval from the Board of Directors, the Executive Director has discretionary

authority to submit delinquent debts (over 90 days) to an outside collection agency.

Write-off of Delinquent Debts/Charges

Before writing off any delinquent debts records must indicate that all efforts to obtain

payment have been exhausted.

The Executive Director of CDC has the discretion to approve debt write-offs of a

board-authorized amount. Any amount above the board-authorized amount should be re-

submitted to the board for approval.

If collection is made of a debt previously written-off as uncollectible, it will be recognized as

revenue in the current period.

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Financial Reporting Procedures

The Chief Financial Officer will be responsible for compiling monthly and year-to-date

reports by revenue source, expense code, and asset and liability account balances.

Financial reports are reconciled to the general ledger and accounting records prior to

submission to the funding source.

If an expenditure is different from an external funding source’s approved budget, prior

approval must be obtained from the funding source prior to the submission of the financial

report.

Monthly financial reports which analyze CDC’s financial position and the effectiveness

of its management and programs will be presented to the Executive Committee of the Board

of Directors and also reported within the board packets.

Periodic reports will be provided to all funders as requested or required by contract.

CDC’s finance and accounting staff will maintain records that identify the source and

application of funds for all activities. These records shall contain information pertaining to

awards, authorizations, obligations, assets, outlays, income and interest. Records will also

include copies of contracts, invoices, proof of payments and allocation tracking when costs

are distributed among several funding sources.

Investment/Banking Policies

The CDC Board of Directors will approve the placement of assets not needed for

immediate operations assuring compliance with all contractual requirements and using the

principles identified below.

Principles:

Minimize Risk: The Board will define a minimum risk strategy that will be reviewed annually

to ensure appropriate discharge of responsibilities to donors, lenders, and contractual

relationships.

Maximize Investment Return: Within the parameters defined in “minimum risk”, funds will

be invested at the highest interest rate/return available at the time of decision.

CDC will support local, women-owned and minority-owned banks and institutions, if

economically feasible: “local” is defined as having a physical presence within CDC’s

service area.

will maintain advances of federal funds in the best reasonably available interest

bearing account, unless 2 CFR 200.305(b)(8) apply.

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account would not be expected to earn interest in excess of $500 per year on Federal

cash balances.

CDC will keep all funds available not already invested in a federally insured bank.

Procedures:

Each quarter, the Executive Director or his/her designee will review with the Executive

Committee the projected cash needs of the corporation and the assets available for

investment.

Each quarter, the Executive Committee will provide the Executive Director or his/her

designee with guidance regarding investments and institutions.

The Executive Director or his/her designee will contact local institutions as needed to

determine the best rate of return for investments.

Each year, the Board of Directors will define a policy for minimizing risk and review it

annually.

Budget Principles/Procedures

The structure of the budgetary process should be made in accordance with the mission, by-

laws of the organization and align with the requirements of any funding partners.

Budget Principles

The budgetary process shall comply with the organization’s funding partners and in

accordance with applicable state and federal laws.

The budgetary process shall comply with the guidelines and principles set forth by the Board

of Directors.

Annually, each program area shall identify and develop a plan for its operation. Each budget

must be approved by the Board of Directors or Executive Director.

Procedures

The organization’s Executive Director will prepare and submit an operating budget to the

Board of Director’s 30-60 days prior to the beginning of the new fiscal year.

Differences in budget line items between the organization’s operating budget and a funders’

approved budgets will be resolved in negotiations between the Executive Director and the

funding agency.

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Adjustments in Budget/Spending Plans

Any adjustments or changes in spending policies/budget plans which vary by more than 10%

from the original approved budget must be initialed by the Executive Director and submitted

for approval to the Board of Directors.

These changes will be communicated in writing to funding sources or s required by

contractual agreements.

If proposed changes are unsatisfactory to the funder, the Executive Director will

communicate this response to the Board of Directors, who may authorize:

Changing the budget/plan to one which is satisfactory to the funder; or

Entering into negotiations to develop a compromise satisfactory to the funder and the Board

of Directors.

After all parties have approved the changes, the changes will be communicated in writing to

all affected management staff.

Audit Procedure

An independent audit should be performed by a Certified Public Accountant (CPA) at the

conclusion of each fiscal year.

The auditor(s) should complete the audit within months of the conclusion of the fiscal

year.

The auditor(s) should test accounting mechanisms in accordance with generally accepted

auditing standards for not-for-profit organizations and as contractually required by funding

sources.

The audit should conduct an A-133 audit, if the CDC expends over $500,000 in federal

funding. Audits of fiscal years beginning on or after January 1, 2015 will increase threshold to

$750,000.

A formal written report of the audit will be presented to CDC’s Board of Directors and

if necessary each principal funding source.

Whistleblower Policy

The CDC requires Board of Directors members, officers, other employees and

volunteers to observe high standards of business and personal ethics in the conduct of their

duties and responsibilities. Employees and representatives of the CDC must practice

honesty and integrity in fulfilling their responsibilities and comply will all applicable laws and

regulations.

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Each Board Member, volunteer, and employee of the charity has an obligation to report in

accordance with this Whistleblower Policy (a) questionable or improper accounting or

auditing matters, and (b) instances where one suspects that employees and representatives

of the did not practice honesty and integrity or comply with all applicable laws and

regulations.

Should a director, officer, employee, contractor, volunteer or agent of the have a

concern or complaint regarding the accounting, auditing or reporting of, or the internal

controls practices and procedures relating to the organization’s funds, the following

guidelines shall be followed:

Contact the Executive Director of the by telephone ( ), mail ( ) or in person to

submit the complaint. If the complaint involves the Executive Director contact the Board

Chair. Updated contact information for the individuals shall be posted on the website of

the . Submissions may be made anonymously.

Upon receipt of the complaint, the Executive Director (or the Board Chair) shall conduct an

initial screening of the complaint to assess its nature, legitimacy and significance. If in the

course of the initial screening or at any time thereafter, it is determined that the complaint

may implicate the Executive Director, he or she shall notify the Board Chair of that fact, and

the Board Chair shall determine whether the Executive Director may continue with the

investigation or appoint another person to assume the investigation instead.

Upon conclusion of the initial screening, the Executive Director (or the Board Chair or the

Executive Director’s appointee) shall decide whether to report the complaint in full to the

Board of Directors, proceed with further investigation or close the file. Any complaint

involving (i) the existence of material inaccuracies in the ’s financial reports or (ii) fraud

or other intentional misconduct with respect to its accounting, auditing, reporting or internal

controls, shall be reported promptly to the Board of Directors following the initial screening

thereof. All other matters shall be reported at a minimum in summary form to the Board of

Directors.

All submissions, inquiries and discussions will be documented by the Executive Director (or

the Board Chair) and will be kept confidential, specifically in a confidential file. Access to the

confidential file shall be restricted to the Board Chair, the Executive Director or the Executive

Director’s appointee, and their designated agents. This is important in order to avoid

damaging the reputations of persons suspected but subsequently found innocent of

wrongful conduct and to protect the from potential civil liability. All such confidential

files shall be maintained for at least seven years following the final disposition of the matter.

All other concerns and complaints not relating to the accounting, auditing or reporting of, or

the internal controls practices and procedures relating to the ’s funds shall be handled

pursuant to the current policies and procedures applicable to such matters.

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The shall take all appropriate steps to prevent retaliation by the , its directors,

officers, employees, volunteers or agents, against any person submitting a complaint on

account of that submission. This Whistleblower Policy is intended to encourage and enable

directors, officers, and employees to raise concerns within the organization for investigation

and appropriate action. With this goal in mind, no one who, in good faith, reports a concern

shall be subject to retaliation or, in the case of an employee, adverse employment

consequences.

Any employee or volunteer who is found to have engaged in retaliation contrary to this

policy will be subject to discipline, up to and including termination of employment (or

removal in the case of volunteers.)

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PROCUREMENT POLICIES

Introduction and Scope

The purpose of this policy is to ensure that achieves the best value for goods and

services procured, following a transparent and cost effective process. The policy aims to

safeguard an adequate level of competition in order to increase the integrity of the

procurement process, ensure good stewardship of funds and meet requirements of funding

agencies.

The following policies and procedures will be followed at all times when CDC is using

federal funds to procure goods and services from an external source.

CDC will follow accounting policies and procedures that comply with generally accepted

accounting principles (GAAP) and avoid purchasing unnecessary items. Any procurement of

goods and services shall be made by the procurement officer/authorized agent, in the best

interest of the CDC, upon considering the totality of the circumstances surrounding the

procurement, which may include but not limited to price, quality, availability, reputation and

prior dealings.

The Federal regulations pertaining to procurement standards are set forth in 2 CFR Part 200

(Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal

Awards). The standards included in 2 CFR 200.318 through 200.326 must be complied with

when any procurement of supplies and other expendable property, equipment, and services

made by involves the use of Federal funds, including funds directly awarded to

by a government agency or department, as well as pass-through federal funds awarded to

by local or state agencies (e.g. CDBG awards).

staff is expected to review and comply with the procurement requirements, if any,

under the applicable funding source agreement.

Code of Conduct

Requirements and Protocol

2 CFR Section 200.318 requires that , as a recipient of federal funds, maintain written

standards of conduct covering conflict of interests and governing the performance of its

employees engaged in the award and administration of contracts.

All employees who are engaged in the award and administration of government

contracts must adhere to a code of professional conduct. All employees, including those

employees who purchase goods or services, or otherwise administer contracts, must follow

CDC’s ’s Conflict of Interest Policies.

Conflicts of Interest. No employee, officer, or agent of shall participate in the

selection, award, or administration of a contract supported by federal funds if a real or

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apparent conflict of interest would be involved. Such a conflict of interest would arise when

the employee, officer, or agent of , any member of his or her immediate family, his or

her partner, or an organization that employs or is about to employ any of the parties

indicated herein, has a financial or other interest in or a tangible personal benefit from a firm

considered for a contract.

Prohibited Conduct. No employee, officer, or agent of must solicit nor accept

gratuities, favors, or anything of monetary value from contractors or parties to subcontracts.

Further, no employee, officer, or agent of shall accept gratuities, favors, or anything of

monetary value (other than an unsolicited gift of a nominal value) from contractors or

parties to subcontracts.

Organizational Conflicts of Interest. Organizational conflicts of interest means that because

of relationships with a parent company, affiliate or subsidiary organization, a person or

organization is unable or appears to be unable to be impartial in conducting a procurement

action involving a related organization. employees responsible for the procurement

shall identify and evaluate potential organizational conflicts of interest as early in the

procurement process as possible and avoid, neutralize, or mitigate significant potential

conflicts before contract award. If necessary, employees are directed to seek counsel

from in the evaluation of potential organizational conflicts of interest and in

developing any necessary solicitation provisions and contract clauses. If it is determined that

a conflict of interest exists and cannot be avoided or mitigated, before determining to

withhold an award based on conflict of interest considerations, the employee

responsible for the engagement shall contact the contractor regarding the existence of a

conflict of interest and provide the contractor with an opportunity to respond. If the

employee responsible for the engagement determines that it would be in the best interest of

to award the contract notwithstanding a conflict of interest, the employee shall

request a waiver and authorization to proceed from the .

Disciplinary Actions

Any employee who violates the requirements and protocol above, may be subject to

disciplinary action, based on the seriousness of the violation.

Acquisition Planning

Principles of Acquisition Planning

employees shall make purchase decisions based on necessity and shall avoid

purchasing unnecessary or duplicative items with funds. Consideration should be

given to consolidating or breaking out procurements to obtain a more economical purchase.

To foster greater economy and efficiency, and in accordance with efforts to promote cost-

effective use of shared services across the Federal government, may enter into inter-

entity agreements where appropriate for procurement or use of common shared goods or

services.

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Procedures and Documentation Requirements

Prior to purchasing goods or services, employees shall:

a) Conduct (where appropriate) an analysis of lease and purchase alternatives to

determine the most economical and practical procurement vehicle.

 Documentation may consist of notes made by the employee(s) making

the purchase decision, estimates/cost projections for lease and purchase

alternatives (obtained from contractors directly or through reputable Internet

resources), quotes from contractors, etc. Such employee(s) should

consider (without limitation) the duration of the need for such item, financing

terms, and the requirements of the applicable funding source.

b) Show a demonstrated need for all items purchased.

 Documentation may consist of notes made by the employee(s) making

the purchase decision, a copy of the applicable work plan or agreement which

the purchase/engagement fulfills, etc.

c) Review current inventories and goods on order to prevent duplicative purchases.

 Documentation may consist of the inventory record dated on or about the

date of the purchase decision.

 employees are encouraged to use Federal excess and surplus property

in lieu of purchasing new equipment and property whenever such use is

feasible and reduces project costs.

d) Assess whether the services can be performed more economically by direct

employment rather than contracting.

 Documentation may consist of notes made by the employee(s) making

the procurement decision (including cost projections for direct employment

and contracting). Such employee(s) should consider the duration of

the need for such services, whether similar services will be required over

time, the scope of work, and costs of engagement (as employee and

contractor, respectively), among other factors (as the situation might require)

in his or her assessment.

e) When appropriate and applicable, it is recommended that staff use value

engineering clauses in contracts for construction projects of sufficient size to offer

reasonable opportunities for cost reductions. Value engineering is a systematic and

creative analysis of each contract item or task to ensure that its essential function is

provided at the overall lower cost.

Retention of Documentation

staff shall maintain documentation in support of his/her observance of the

requirements of the section above, for as long as required pursuant to ’s record

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retention guidelines or as required by the funder pursuant to the applicable funding

agreement, whichever is later.

Solicitations for Goods and Services

Objective

All procurement transactions shall be conducted in a manner providing full and open

competition. Full and open competition in the contracting process should ensure cost

effectiveness and reduce the potential for favoritism and conflicts of interest (including

organizational conflicts of interest).

Principles

Basic Principles of Solicitations. Solicitations shall clearly set forth all requirements that the

bidder or offeror shall fulfill in order for the bid or offer to be evaluated.

Solicitations for goods and services must include the following:

a) A clear and accurate description of the technical requirements for the material,

product or service to be procured. The description should not be worded such that it

unduly restricts competition. Detailed product specifications should be avoided if at

all possible.

b) All requirements that the offeror must fulfill and all other factors to be used in

evaluating bids or proposals (including any specific criteria related to deliverables,

payment of expenses, payment schedules and timeliness, all of which make up the

decision criteria; provided, however, that such specific criteria shall not be unduly

restrictive of competition).

c) The submission deadline and the anticipated award date.

d) A description, whenever practicable, of technical requirements in terms of functions

to be performed and services required, including a range of acceptable characteristics

or minimum acceptable standards.

e) When is impractical or uneconomical to make a clear and accurate description of the

technical requirements, a “brand name or equivalent” description may be used as a

means to define the performance or other salient requirements of procurement/that

bidders are required to meet. The specific features of the named brand which must

be met by offers must be clearly stated

Small and Minority Firms, Businesses, Women’s Business Enterprises, and Labor Surplus Area

Firms. employees must take all necessary affirmative steps to assure small and

minority firms, women’s business enterprises, and labor surplus area firms are used

whenever possible. Affirmative steps employees must take, include the following:

a) Placing qualified small and minority businesses and women’s business enterprises on

solicitation lists;

b) Assuring that small and minority businesses, and women’s business enterprises are

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solicited whenever they are potential sources;

c) Dividing total requirements, when economically feasible, into smaller tasks or

quantities to permit maximum participation by small and minority businesses, and

women’s business enterprises;

d) Establishing delivery schedules, where the requirement permits, which encourage

participation by small and minority businesses, and women’s business enterprises;

e) Using the service and assistance, as appropriate, of such organizations as the Small

Business Administration and Minority Business Development Agency of the

Department of Commerce; and

f) Requiring any prime contractor, if subcontracts are to be let, to take the same

affirmative steps.

Unfair Competitive Advantage. In order to ensure objective contractor performance and

eliminate unfair competitive advantage, contractors that develop or draft specifications,

requirements, statements of work, invitation for bids and/or, requests for proposals shall be

excluded from competing for such procurements. Awards shall be made to the bidder or

offeror whose bid or offer is responsive to the solicitation and is most advantageous to

, price, quality and other factors considered. Some of the situations considered to be

restrictive of competition include but are not limited to:

a) Placing unreasonable requirements on firms in order for them to qualify to do

business;

b) Requiring unnecessary experience and excessive bonding;

c) Noncompetitive pricing practices between firms or between affiliated companies;

d) Noncompetitive contracts to contractors that are on retainer contracts;

e) Organizational conflicts of interest;

f) Specifying only a ‘‘brand name’’ product instead of allowing ‘‘an equal’’ product to be

offered and describing the performance or other relevant requirements of the

procurement; and

g) Any arbitrary action in the procurement process.

Monitoring Contractors’ Practices. shall be alert to organizational conflicts of interest

as well as noncompetitive practices among contractors that may restrict or eliminate

competition.

Prohibited Use of Geographical Preferences. staff shall conduct procurement in a

manner that prohibits the use of statutorily or administratively imposed state or local

geographical preferences in the evaluation of bids or proposals, except in those cases where

applicable Federal statutes expressly mandate or encourage geographic preference. Nothing

in this section preempts state licensing laws. When contracting for architectural and

engineering (A/E) services, geographic location may be a selection criterion provided its

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application leaves an appropriate number of qualified firms, given the nature and size of the

project, to compete for the contract.

Prequalified Lists of Persons, Firms or Products. shall ensure that all prequalified lists

of persons, firms, or products which are used in acquiring goods and services are current and

include enough qualified sources to ensure maximum open and free competition.

shall not preclude potential bidders from qualifying during applicable solicitation periods.

Procurement Methods (Types of Solicitations)

employees must use ONE of the following methods of procurement, for each instance

of procurement:

Procurement by Micro-Purchases. Contracts up to $3,000

Procurement by Small Purchase Procedures. Contracts from $3,001 to $[Not to exceed

$150,000 (2 CFR 200.88)].

Procurement by Competitive Proposals. Contracts in excess of $ .

Procurement by Sealed Bids - Construction.

Procurement by Noncompetitive Proposals.

Procurement by Micro-Purchases. Procurement by micro-purchase is the acquisition of

supplies or services, the aggregate dollar amount of which does not exceed $3,000 (or

$2,000 in the case of acquisitions for construction subject to the Davis-Bacon Act). To the

extent practicable, shall distribute micro-purchases equitably among qualified

suppliers. Micro-purchases may be awarded without soliciting competitive quotations if

considers the price to be reasonable.

Procurement by Small Purchase Procedures. Contracts from $3,001 to $[Not to exceed

$150,000 (2 CFR 200.88)].

Small purchase procedures are those relatively simple and informal procurement methods

for securing services, supplies, or other property that do not cost more than the Simplified

Acquisition Threshold ($ ). If small purchase procedures are used, price or rate

quotations must be obtained from an adequate number of qualified sources, not less than

three (3).

May be solicited verbally; however price and rate quotes obtained verbally must be

confirmed in writing, via email, facsimile, or other acceptable documentation. Moreover,

the staff responsible for the engagement and oversight of the contractor shall maintain

documentation of its solicitation and engagement process.

**Tip: Requests for Proposals might be recommended for certain procurement transactions,

particularly where a significant award is contemplated or where the services are of a complex

nature – in order to ensure that potential contractors are all being providing with the same

information.

a) Price or rate quotations must be obtained from an adequate number of qualified

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sources, not less than three (3).

b) employee(s) may contact persons and firms included on lists of prequalified

contractors.

c) “Qualified” means the supplier/contractor is able to meet required licensing or

certification requirements, is not prohibited from participating in the procurement

action, and can fulfill ’s requirements.

d) employee(s) responsible for the initiation of the solicitation and selection of

the contractor shall document its decision rationale in its file. The documentation

must include the performance requirements and the organizations/individuals that

were contacted. Specifically, the documentation should include, but not be limited

to:

 The name of the individual soliciting the information;

 The names of the companies/individuals solicited and the individuals

providing the price or rate quotation;

 The date the information was provided;

 The goods or services to be purchased, including the quantities upon

which the price or rate quote was provided;

 All pertinent terms or conditions imposed by either party;

 The duration of the price or rate quotation. A new solicitation must be

conducted for purchases that will be made after the current quotation

expires; and

 Responsiveness of the bid/quotations to the selection criteria

contained in the solicitation (including comparative analysis of the

bidding individuals/companies).



**Tip: Requests for Proposals might best accomplish this for certain procurement

transactions, particularly where a significant award is contemplated or where the services

are of a complex nature.

When a proposed contract modification changes the scope of a contract or increases the

contract amount by more than the amount of the simplified acquisition threshold, the

protocol on procurement by competitive proposal shall be followed.

Procurement by Competitive Proposals. Contracts in excess of the Simplified Acquisition

Threshold- $

The technique of competitive proposals is normally conducted with more than one source

submitting an offer, and either a fixed price or cost reimbursement type contract is awarded.

It is generally used when conditions are not appropriate for the use of sealed bids. If this

method is used, the following requirements apply:

a) Requests for proposals (“RFPs”) must be publicized and identify all evaluation factors

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and their relative importance. Any response to publicized requests for proposals

must be considered to the maximum extent practical;

b) Proposals must be solicited from an adequate number of qualified sources; written

responses must be obtained from an adequate number of qualified sources, not less

than two for any RFP. It is strongly recommended that at least three (3) price or rate

quotations be obtained for each RFP to strengthen the price analysis for the

procurement action;

c) “Qualified” means the supplier is able to meet required licensing or certification

requirements, is not prohibited from participating in the procurement action, and can

fulfill ’s requirements.

d) must have a written method for conducting technical evaluations of the

proposals received and for selecting recipients;

e) Contracts must be awarded to the responsible firm whose proposal is most

advantageous to the program, with price and other factors considered; and

If needed/applicable, may use competitive proposal procedures for qualifications-

based procurement of architectural/engineering (A/E) professional services whereby

competitors’ qualifications are evaluated and the most qualified competitor is selected,

subject to negotiation of fair and reasonable compensation. The method, where price is not

used as a selection factor, can only be used in procurement of A/E professional services. It

cannot be used to purchase other types of services though A/E firms are a potential source

to perform the proposed effort.

Contracts in Excess of the Simplified Acquisition Threshold:

Must be solicited utilizing written Request for Proposals (RFPs)

Minimum Components:

a) All of the requirements for solicitations under section above.

b) Any contract requirements mandated by the applicable funder.

c) Written Requests for Proposals may be posted on or printed in (as applicable):

d) website

 Local chamber of commerce

 Idealist.org

 Local or national (as feasible or necessary) newspapers

 Trade or industry newsletters, journals, or periodicals



**Tip: Objective is to elicit an adequate number of responses from qualified bidders. The

employee(s) should be able to defend that the selected medium/media fosters open

and free competition.

Tip: It may be a good practice to post or print Requests for Proposals on a public forum,

even if prequalified contractors have been identified through a Request for Qualifications

process, to further ensure maximum open and free competition.

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Responses to the Requests for Proposals must be in writing.

Program staff shall regularly monitor and evaluate the contractor’s performance against the

agreed-upon specifications, milestones, or scope of work and promptly address deficiencies.

Program staff shall maintain records of its monitoring and evaluation activities with respect

to the contractor in accordance with requisite record retention policies.

Procurement by Sealed Bids - Construction (Formal Advertising). Bids are publicly solicited

and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder

whose bid, conforming with all of the material terms and conditions of the invitation for

bids, is the lowest in price. The sealed bid method is the preferred method for procuring

construction, if the following conditions apply. In order for sealed bidding to be feasible, the

following conditions should be present:

a) A complete, adequate, and realistic specification or purchase description is available;

b) Two or more responsible bidders are willing and able to compete effectively for the

business; and

c) The procurement lends itself to a firm fixed price contract and the selection of the

successful bidder can be made principally on the basis of price.

If sealed bids are used, the following requirements apply:

a) The invitation for bids will be publicly advertised and bids must be solicited from an

adequate number of known suppliers, providing them sufficient response time prior

to the date set for opening the bids;

b) The invitation for bids, which will include any specifications and pertinent

attachments, must define the items or services in order for the bidder to properly

respond;

c) All bids will be publicly opened at the time and place prescribed in the invitation for

bids;

d) A firm fixed price contract award will be made in writing to the lowest responsive and

responsible bidder. Where specified in bidding documents factors such as discounts,

transportation cost, and life cycle costs must be considered in determining which bid

is lowest. Payment discounts will only be used to determine the low bid when prior

experience indicates that such discounts are usually taken advantage of; and

e) Any or all bids may be rejected if there is a sound documented reason.

Procurement by Noncompetitive Proposals. Procurement by noncompetitive proposals is

procurement through solicitation of a proposal from only one source and may be used only

when one or more of the following circumstances apply:

a) The item is available only from a single source;

b) The public exigency or emergency for the requirement will not permit a delay

resulting from competitive solicitation;

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c) The Federal awarding agency or pass-through entity expressly authorizes

noncompetitive proposals in response to a written request from the non-Federal

entity; or

d) After solicitation of a number of sources, competition is determined inadequate.

Procurement Instruments (Type of Contract)

Objective

The type of procuring instruments used shall be appropriate for the particular procurement

and for promoting the best interest of the program or project involved.

Procedures

will determine the type of procuring instruments in order to ensure that goods and

services are obtained in the most efficient, cost effective manner, without barriers to full and

open competition and free of any potential conflicts of interest

Government awarding agencies may impose limitations on contractor compensation.

staff procuring contractors with government funds should familiarize themselves with

specific contract requirements, including those imposing maximum hourly or daily rates of

compensation for contractors. In such cases, strongly prefers to enter into deliverable-

based or fix price contracts.

Procurement Instruments

Deliverables-Based or Fixed Price Contracts: Contractors will be engaged to perform specific

and discrete tasks and/or create specific deliverables and will be paid a flat fee upon

completion of each specific/discrete task and/or delivery of each satisfactory final

deliverable.

a) Responsive bids will include flat fee for the applicable task(s) and/or deliverable(s)

and projected expenses for which the contractor will seek reimbursement for from

(which shall be reimbursed at actual cost).

b) Fees do not fluctuate based on time spent by the contractor to complete the work.

**Tip: The fees quoted by the contractor should nevertheless be “reasonable”. The

reasonableness of the fee may be determined by a comparison of the responding contractors’

fees for the requested task(s) and/or deliverable(s), and an evaluation of the fees charged by

the contractor historically for similar tasks and/or deliverables.

Time-Based (Hourly/Daily Rate) Contracts: Contractors will be engaged to perform specific

tasks and will be paid based on time spent by the contractor to complete the work.

a) Time-Based Contracts should only be used after a determination has been made that

no other contract is suitable and if the contract includes a ceiling price that the

contractor exceeds at its own risk.

b) Responsive bids should also include projected expenses for which the contractor will

seek reimbursement for from (which shall be reimbursed at actual cost).

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c) The contract shall be subject to a ceiling price that the contractor exceeds at its own

risk.

d) Rates shall not fluctuate once a contract is awarded.

e) Projected time shall not fluctuate without significant extenuating circumstances.

employees awarding such time-based contracts must assert a high degree of oversight

in order to obtain reasonable assurance that the contractor is using efficient methods and

effective cost controls.

**Tip: Since time-based contracts can generate an open-ended contract price, which

provides no positive profit incentive to the contractor for cost control or labor efficiency, such

contracts must set a ceiling price that the contractor exceeds at its own risk.

Responsive bids will include a rate based on time (hourly/daily) and the projected number of

hours/days (depending on the rate increment charged by the contractor) to complete the

scope of work.

Other Procurement Instruments: If a different procurement instrument is contemplated for

use, staff should contact for guidance prior to issuance of solicitations.

a) Neither “cost-plus-a percentage-of-cost” nor “percentage of construction cost”

methods of contracting shall be used.

b) Time and material type contracts may only be used after a determination has been

made that no other contract is suitable and if the contract includes a ceiling price that

the contractor exceeds at its own risk. Time and material type contract means a

contract whose cost is the sum of (i) the actual cost of materials; (ii) direct labor

hours charged at fixed hourly rates that reflect wages, general and administrative

expenses, and profit. employees awarding such time-based contracts must

assert a high degree of oversight in order to obtain reasonable assurance that the

contractor is using efficient methods and effective cost controls.

Additional Considerations for Procurement of Office Supplies and Equipment

The procedures outlined below are in addition to ’s procurement procedures

established in Accounting and Finance Policy Manual and the Manual. staff

should also be guided by this document and 2 CFR Sections 200.453 and 200.439, as

applicable.

Please be aware that federal disposition requirements apply for equipment purchases in

excess of $5,000, with government funds. Equipment means tangible personal property

(including information technology systems) having a useful life of more than one year and a

per-unit acquisition cost which equals or exceeds $5,000.

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Office Supplies. Office supplies are small items used in the office to maintain daily

functionality (e.g. writing implements, paper products, office calculators, extensions cords,

staplers, etc.). Examples of large items not included in this definition are office equipment

and furniture.

Approved Vendor: is ’s only vendor for office supplies (effective ).

Payment for approved office supplies orders will be processed through .

Software, Hardware (including computers) and General Office Equipment are purchases and

leases of general office equipment and computer software, hardware and any computer-

related equipment that is to be used by CDC staff for CDC business purposes.

No software, hardware, or general office equipment should be purchased without first

receiving the appropriate approval from and it must be compatible with

systems and/or meet corporate standards. This will be determined by .

Purchased with Government Funds: Office supplies, software, hardware and general office

equipment to be used by staff for business purposes and charged to

government funding sources will be subject to the test of allowability, allocability and

reasonableness, in accordance with the principles established by 2 CFR Part 200. The

following parameters shall be used to make this determination:

a) Whether the cost is a type generally recognized as ordinary and necessary for the

organization or the performance of the award.

b) Whether the cost is incurred through an “arm’s length transaction,” and do not

deviate from established practices of the organization.

c) Whether the cost does not exceed, in nature or amount that which would be incurred

by a prudent person under the circumstances prevailing at the time the decision was

made to incur the costs.

d) Whether the cost is consistently charged to both government and non-governmental

(private) programs.

e) The cost is incurred specifically for the award.

f) The cost benefits both the award and other work and can be distributed in

reasonable proportion to the benefits received.

g) The cost is necessary to the overall operation of the organization, although a direct

relationship to any particular cost objective cannot be shown.

h) Any cost allocable to a particular award or other cost objective under these principles

may not be shifted to other awards to overcome funding deficiencies, or to avoid

restrictions imposed by law or by the terms of the award.

i) The cost is allowable according to 2 CFR Part 200 Subpart E.

j) Hardware (including computers) and software and general office equipment

purchases to be made by as part of a government contract and to be used by

another party for programmatic purposes require the participation and approval of

Department which will work with the program responsible for initiating the

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procurement process in order to identify hardware and software requirements,

develop technical specifications for vendors, request at least three (3) quotes from

vendors and participate in the negotiation process, as described above.

Contract Cost and Price and Other Selection Criteria

Requirement

shall perform a cost or price analysis (and document such analysis in the procurement

files) in connection with every procurement action in excess of the Simplified Acquisition

Threshold, including contract modifications.

Contracts shall be made only with responsible contractors who possess the potential ability

to perform successfully under the terms and conditions of the proposed procurement.

Consideration shall be given to such matters as contractor integrity, record of past

performance, financial and technical resources or accessibility to other necessary resources.

In certain circumstances, contracts with certain parties are restricted by agencies'

implementation of Executive Orders 12549 and 12689, “Debarment and Suspension.”

Procedures

Awards should be made to the bidder or offeror whose bid or offer is responsive to the

solicitation and is most advantageous to , price, quality and other factors considered.

reserves the right to reject any and all bid offers, if deemed to be in ’s best

interest.

shall enter into contracts only with responsible contractors who possess the potential

ability to perform successfully under the terms and conditions of the proposed procurement.

Consideration shall be given to such matters as contractor integrity; record of past

performance; financial and technical resources or accessibility to other necessary resources.

The method and degree of analysis is dependent on the facts surrounding the particular

procurement situation, but as a starting point, must make independent estimates

before receiving bids or proposals.

Offers and proposals received by shall be evaluated according to the following

parameters:

Contract Cost and Price. The employee responsible for the procurement action shall

perform a cost or price analysis with every procurement e made by in excess of the

Simplified Acquisition Threshold, including contract modifications. This analysis shall be

documented , and supplemented by other supporting documentation maintained by such

employee, for all government funded actions. Modifications that change the work

beyond the scope of the contract must be justified, and may require additional competitive

bidding.

Price Analysis: A comparison of price quotations submitted, market prices and similar

indicia, together with discounts. It is the evaluation of the proposed price (i.e. lump sum)

without analyzing any of the separate cost elements that comprise the proposed price.

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shall compare an offeror’s price to others, previous prices paid for similar services,

catalogue prices or other similar data.

**Tip: When to Use: Whenever you are comparing lump sum prices (not cost estimates).

Competition: Compare two or more responsible (not debarred or suspended, etc.),

competing independently. The greater the number of offers/bids, the greater the

competition and the better the pricing.

Cost Analysis: A review and evaluation of each element of cost to determine

reasonableness, allocability and allowability. Cost analysis is done when offers are broken

into various elements of cost (i.e.: training services broken by fees, travel, materials, etc).

shall analyze the costs associated with the offer and determine the reasonableness of

the amounts (by each component) included in the total cost and the necessity of each

element of cost.

**Tip. When to Use: Whenever you do not have price competition –

Non-Competitive (or Negotiated) Proposal: Acquiring professional, consulting,

architect/engineering services, where bidders are required to submit cost proposals that

show the elements (labor, materials, overhead, profit, etc.).

Sole Source: Not soliciting competitive bids or offers. Sole source selection must be

appropriate and justified. Used when award of a contract is infeasible under small purchase

procedures, sealed bids or competitive proposals and one of the following applies: (i) the

item/service is available only from a single source; (ii) the exigency/emergency for the

requirement will not permit a delay resulting from competitive solicitation; (iii) the awarding

agency authorizes noncompetitive proposals; or (iv) after solicitation of a number of sources,

competition is determined inadequate.

**Tip: Note: Sole source justification is available in limited circumstances and may require

consultation with the applicable government funder. If justification is available, all

documentation in support of such position must be maintained by the local or National office

responsible for the engagement.

Only One Bid Received and Bid Differs Substantially from Independent Estimate of the

Contract Price: If you determine that the bid is unreasonable and decide to not recomplete

(market survey tells you that you will not get competition), then you may formally cancel the

solicitation and negotiate a contract price with the single bidder. You must obtain a cost

breakdown of the contractor’s proposed cost – not a lump sum proposal – before

negotiating the change in contract price.

Modifications to a Contract: If modification changes the work authorized under the contract,

and changes the price or total estimated cost, either upwards or downwards, you must

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obtain a detailed breakdown of the contractor’s proposed cost – not a lump sum proposal –

before negotiating the change in contract price.

Cost Analysis and Fees: The non-Federal entity must negotiate profit as a separate element

of the price for each contract in which there is no price competition and in all cases where

cost analysis is performed. To establish a fair and reasonable profit, consideration must be

given to:

a) The complexity of the work to be performed (the more difficult the work, the more

profit a contractor may be entitled to);

b) The risk borne by the contractor (the higher the risk, the higher the profit/fee);

c) Contractor’s investment (labor, oversight, etc.) (the greater the investment of

resources, the higher the profit/fee);

d) Subcontracting (the more complex the contract, the higher the profit/fee);

e) Quality of the contractor’s past performance (profit/fee rewards contractor for

proven record of high quality performance); and

f) Industry profit rates in the surrounding geographical areas for similar work (“going

rate”) – Be careful to not pay going rates when the work required is not really

covered by those rates (you should not pay specialty rates for routine work).

g) Costs or prices based on estimated costs for contracts under the Federal award are

allowable only to the extent that costs incurred or cost estimates included in

negotiated prices would be allowable for the non-Federal entity under Subpart E—

Cost Principles of this Part. The non-Federal entity may reference its own cost

principles that comply with the Federal cost principles.

The cost plus a percentage of cost and percentage of construction cost methods of

contracting must not be used.

Federal Debarment Standard

When purchasing goods and services using federal funding, employees must ensure

that the contract awardee is not debarred or suspended from doing business with the

federal government nor delinquent in a debt to the United States. Before a contract is

awarded, the employee responsible for such procurement should check the System

for Award Management (“SAM”) and verify that the contractor is not so debarred or

suspended from doing business with the federal government and that the contractor does

not have any active exclusions in SAM.

Office of Foreign Assets Control (OFAC)

When purchasing goods and services using government funding, shall comply with

OFAC’s regulations against doing business with targeted terrorists and other criminals. Prior

to entering into an agreement, will use a web-based watch list screening tool to

ensure compliance with this requirement.

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Contractor Monitoring

Monitoring Performance.

Program staff shall regularly monitor and evaluate the contractor’s performance against

agreed-upon specifications, milestones, or scope of work and promptly address deficiencies.

Program staff shall maintain records of its monitoring and evaluation activities with respect

to the contractor in accordance with requisite record retention policies.

Procurement Records

Requirement

staff must maintain procurement records sufficient to detail the history of a

procurement action. These records shall include the following at a minimum:

a) Rationale for the method of procurement

b) Selection of contract type

c) Contactor selection or rejection; and

d) Basis for contract price.

Solicitation Documentation

must maintain procurement records in connection with every procurement action.

Solicitation Documentation: Staff shall maintain information used to solicit and select a

contractor, in addition to information documenting the actual purchases made from the

successful contractor. This information may include:

a) Copies of solicitation documents;

b) Names and dates of contractors contacted by phone;

c) Copies of letters, e-mails and faxes soliciting price or rate quotations;

d) Trip reports identifying contractors contacted in person;

e) Copies of price or rate quotations received, including telephone quote confirmations;

f) Notification to the successful contractor;

g) Purchase documents, such as invoices, bills of lading and canceled checks; and

h) Such other documentation as recommended elsewhere in this document.

Federal Agency Reviews.

On request, shall provide the Federal awarding agency or pass-through entity with

technical specifications on proposed procurements should the awarding agency or pass-

through entity believes such review is needed to ensure that the item or service specified is

the one being proposed for acquisition. This review generally will take place prior to the time

the specification is incorporated into a solicitation document. However, if desires to

have the review accomplished after a solicitation has been developed, the Federal awarding

agency or pass-through entity may still review the specifications, with such review usually

limited to the technical aspects of the proposed purchase. The Federal awarding agency or

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pass-through entity may also conduct a review of the technical aspects of the proposed

purchase after a solicitation has been developed by .

On request, must provide the Federal awarding agency with pre-procurement review

and procurement documents, such as requests for proposals or invitations for bids,

independent cost estimates, etc., when any of the following conditions apply:

’s procurement procedures or operation fails to comply with the procurement

standards set forth in 2 CFR Part 200.

a) The procurement is expected to exceed the current simplified acquisition

threshold and is to be awarded without competition or only one bid or offer is

received in response to the solicitation;

b) The procurement, which is expected to exceed the simplified acquisition threshold,

specifies a “brand name” product;

c) The proposed award over the simplified acquisition threshold is to be awarded to

other than the apparent low bidder under a sealed bid procurement; or

d) A proposed contract modification changes the scope of a contract or increases the

contract amount by more than the amount of the Simplified Acquisition Threshold.

Contract Provisions and Bonding Requirements Award and

Administration

Requirement

A system for contract administration shall be maintained to ensure contractor conformance

with the terms, conditions and specifications of the contract and to ensure adequate and

timely follow up of all purchases. employees responsible for each procurement action

shall evaluate contractor performance and document, as appropriate, whether contractors

have met the terms, conditions and specifications of the contract.

Other Award Administration Requirements

Contract Provisions. There are certain procurement provisions contained in 2 CFR Part 200

which must be included in all contracts that involve the use of Federal funds.

Bonding Requirements. For construction or facility improvement contracts or subcontracts

exceeding the Simplified Acquisition Threshold, minimum requirements set forth 2 C.F.R.

Section 200.325 must be applied.

Contract Administration. must maintain a system for contract administration to

ensure contractor conformance with the terms, conditions and specifications of the contract

and to ensure adequate and timely follow-up of all purchases. shall evaluate

contractor performance and document, as appropriate, whether contractors have met the

terms and conditions of their contracts.

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PROPERTY/EQUIPMENT STANDARDS

When purchasing property (both real property and equipment), the following procedures

will be followed:

a) Title to all property purchased with federal funds will vest with the CDC.

b) Property records will be kept showing the general name of the property,

identification number, original cost, and depreciated value. These records will be

reviewed and necessary revisions made on an annual basis at the end of CDC’s

fiscal year.

c) CDC will provide the equivalent insurance coverage for real property and

equipment regardless of how the property was acquired by the organization.

d) Equipment purchased, with a purchase price in excess of $5,000, with federal funds is

generally considered the property of the federal government and must be disposed,

if necessary, through a set procedure. When disposing equipment with an

acquisition cost in excess of $5,000, CDC will follow the respective funding

program’s disposal regulations.

e) A physical inventory of equipment purchased with government funds will be taken

and the result reconciled with the equipment records once every two years. Any

differences between quantities determined by the physical inspection and those

shown in the accounting records will be investigated to determine the causes of the

difference. will verify the existence, current utilization and continued need for

the equipment.

RECORDS MANAGEMENT POLICY

Records Management Policy

To ensure that all programs operated by CDC are properly managed and reported on,

CDC will establish and monitor a comprehensive records management policy.

a) To ensure that pertinent records are properly managed, CDC will implement

file maintenance and disposition plans for each project/funding source when that

project becomes inactive. When a project is closed a file maintenance and

disposition plan form will be filled out and filed for each project. The form includes,

but is not limited to, the date the project began, the date the project ended, amount

of contract, name and signature, a contact number for project’s manager, a

description of the files within the storage case and their filing arrangement, and

disposition instructions. Once the “File Maintenance and Disposition Plan” form has

been completed, it will be filed and the storage box will be sent to CDC’s off-

site storage facility.

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b) Financial records, supporting documents, statistical records, and all other records

pertinent to an award of funding from an external source shall be retained for a

period of three (3) years from the date of the submission of the final expenditure

report. If any litigation, claim, or audit is started before the expiration of the three-

year period, the records shall be retained until all litigation, claims, or audit findings

have been resolved and final action taken.

c) Records for real property and equipment acquired with federal funds must be

retained for three (3) years after final disposition, replacement, or transfer of said

property.

See table below:

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BUSINESS RECORD RETENTION SCHEDULE

ACCOUNTING AND FISCAL

TERM

CORPORATE

TERM

Accounts Payable Records

Certificate of Incorporation

Accounts Receivable Records

Charter

Audit Reports

Annual Reports

Audit Reports Internal

Contracts (After Expiration)

Bank Statements and Reconciliation

Copyrights

Canceled Checks

Correspondence (General)

Check Registers

Correspondence (Legal)

Cash Receipts Book

Insurance Policies (After

Expiration)

Expense Analysis & Distribution

Schedules

Inventories

Financial Statements

Leases (after expiration)

Fixed Assets Records

Legal Briefs

General Ledgers

Licenses

Invoices

Merger Acquisition Records

Journals/Cash Books

Board Minutes

Office Equipment Records (after

disposition)

PERSONNEL

Patents

Employment History

Profit and Loss Statements

Individual Employee Records

Property Records

Payroll Register

Trademark Records

Time Cards and Sheets

Unclaimed Wages(given to state

after 3 yrs)

TAXATION

Cancelled payroll checks

Annuity or Deferred Payment Plan

Retirement and Pension Plans

Payroll Tax Returns

Group Insurance Records

Withholding Tax Statements (W-2s)

Training Materials

Tax Bills and Statements

Employee Travel and Expense

Reports

Federal Tax Returns & Work Papers

Interim Payroll Registers

State Tax Returns & Work Papers

Sales and Misc. Tax Returns

Depreciation Schedules

This information is provided as guidance in determining your organization’s document

retention policy. Legal requirements may vary, please consult your accountant or lawyer for

specific needs.

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(Numerals indicate number of years records should be stored, P = Permanently)

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Drug-Free Work Place Policy

CDC is a drug-free work place and following is the organization’s drug-free work place

policy:

CDC does and will continue to provide a drug-free work place by:

a) Publicly posting a statement notifying employees that the unlawful manufacture,

distribution, dispensing, possession, or use of a controlled substance is prohibited in

the during normal working hours and on CDC properties.

b) Provide each employee engaged in the performance of a grant be given a copy of the

statement specified in paragraph A, above.

c) When an employee of CDC works on a government-funded project or activity

that has funding with a drug-free work place certification, CDC will notify

effected employees that they are required to abide by the terms of the statement;

and, notify the employer in writing of his/her conviction for a violation of a criminal

drug statute occurring in the work place no later than five calendar days after such

conviction.

d) Within 30 days of being informed by an employee that he/she had been arrested on

drug charges and convicted, CDC will:

e) Take appropriate personnel action against such employee, up to and including

termination, consistent with the Rehabilitation Act of 1973, as amended; or

f) Require the employee to participate and satisfactorily complete a drug abuse

assistance or rehabilitation program approved for such purposes by a federal, state,

or local health, law enforcement, or other appropriate agency.

g) CDC will strive to make a good faith effort to continue to maintain a drug-free

work place through implementation of paragraphs A through F, above.

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COMPUTER AND INTERNET SECURITY

The Internet and e-mail

Access to the internet is provided to employees for the benefit of CDC and its partners

and clients. Employees are able to connect to a variety of business information resources

around the world.

Internet use carries risks. To ensure that all employees are responsible and productive

Internet users and to protect CDC interests, the following guidelines have been

established for using the Internet and e-mail.

a) The email system is intended for official business. All communications are for

professional reasons and that they shall not interfere with the employees’

productivity.

b) Know and abide by all applicable policies dealing with security and

confidentiality of company records.

c) Employees must not use the Internet for purposes that are illegal, unethical, harmful

to the company, or nonproductive.

d) Email messages created, sent, or retrieved over the internet are the property of

and may be regarded as public information. reserves the right to access

the contents of any messages sent over its facilities if the company believes, in its

sole judgment, that it has a business need to do so. All communications, including

texts and images, can be disclosed to law enforcement or other third parties without

prior consent of the sender or the receiver.

e) Employees shall not transmit copyrighted materials without permission.

f) Employees shall avoid transmission of nonpublic information. If it is necessary

to do so, employees are required to take steps reasonably intended to ensure that

information is delivered to the proper person who is authorized to receive such

information for a legitimate use.

Computer viruses

Computer viruses are programs designed to make unauthorized changes to programs and

data. Therefore, viruses can cause destruction of corporate resources.

a) shall install and maintain appropriate antivirus software on all computers,

utilizing a multi-tiered anti-virus defense with workstation and server-based

components as well as a third-party email scanning services for inbound and

outbound email.

b) Employees shall not knowingly introduce a computer virus into company computers.

c) Employees shall not load flash drives, CDs or DVDs of unknown origin.

d) Incoming flash drives, CDs or DVDs shall be scanned for viruses before they are read.

e) Any employee who suspects that his/her workstation has been infected by a virus

shall IMMEDIATELY POWER OFF the workstation and call .

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Access and passwords

The confidentiality and integrity of data and Personally Identifiable Information (PII) stored

on company computer systems must be protected by access controls to ensure that only

authorized employees have access. This access shall be restricted to only those capabilities

that are appropriate to each employee’s job duties.

shall be responsible for the administration of access controls to all company computer

systems. will process adds, deletions, and changes upon receipt of a written request

from the end user’s supervisor.

a) Each employee shall be responsible for all computer transactions that are made with

his/her User ID and password.

b) Managers and supervisors should notify promptly whenever an employee

leaves the company or transfers to another department so that her/his access can be

revoked. Involuntary terminations must be reported concurrent with the termination.

Physical security

It is policy to protect computer hardware, software, data, personally identifiable

information, and documentation from misuse, theft, unauthorized access, and

environmental hazards.

Employee responsibilities

The directives below apply to all employees:

a) Flash drives, CDs and DVDs should be stored out of sight when not in use. If they

contain highly sensitive or confidential data, they must be locked up.

b) Flash drives, CDs and DVDs should be kept away from environmental hazards such as

heat, direct sunlight, and magnetic fields.

c) Critical computer equipment, e.g., file servers, must be protected by an

uninterruptible power supply (UPS). Other computer equipment should be protected

by a surge suppressor.

d) Environmental hazards to hardware such as food, smoke, liquids, high or low

humidity, and extreme heat or cold should be avoided.

e) Employees shall not take shared portable equipment such as laptop computers

without permission.

f) Employees should exercise care to safeguard the valuable electronic equipment

assigned to them. Employees who neglect this duty may be accountable for any loss

or damage that may result.

g) Employees shall protect any confidential, proprietary business information and

personally identifiable information such as home contact information, individual

demographic data or individually identifiable information collected from contracts

and/or partners.

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Copyrights and license agreements

a) It is policy to use licensed software only in accordance with the terms of its

license agreement. Violating a license agreement is not only unethical –it is also

illegal and can subject and the responsible employee to criminal prosecution

and substantial monetary penalties.

b) To help us adhere to this policy, employees may not do any of the following without

permission from the .

c) Make a copy of any software program, for any reason.

d) Install a software program on a home computer.

e) Install a personal software programs (that is, software owned by the employee) on

any computer.

f) Download any software program from the internet to a computer.

g) The may audit -owned computers at any time to ensure compliance with

this policy.

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ACKNOWLEDGEMENT FORM

I, ______________________, acknowledge that I have read the Policy Prohibiting Unlawful

Harassment, Including Sexual Harassment, which is contained in Section Two of this Sample

CDC Policies and Procedures Manual, and I agree to the terms and provisions contained in

such policy.

Name of Employee:_____________________

Title:____________________

Date:____________________

Witness:___________________

I, ______________________, acknowledge that I have read the Sample CDC Policies and

Procedures Manual, and I agree to comply with the terms and provisions contained in this

manual.

Name of Employee:_____________________

Title:____________________

Date:____________________

Witness:___________________