COM 0918.001 2022-2024 - Laserfiche WebLink

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Phase 2 Awarding The role of Hawaii County Council in awarding funds is not described as currently written. In our evaluation of Article 25, we identified procedural gaps. Specifically, the activities of the Council as they relate to its review and appropriation of funds to nonprofits are not addressed in the code. Not defining the Council's responsibilities introduces actual and perceptual risks, including: Actual Risks Several risks need consideration. Firstly, the lack of clearly defined responsibilities within the Council's decision-making process concerning fund allocations to non-profit organizations may undermine accountability. Secondly, the absence of established procedures could result in inconsistent and subjective decisions in fund allocation. Thirdly, unclear responsibilities may inadvertently violate applicable laws and regulations. Lastly, the absence of explicit procedures heightens the risk of conflicts of interest influencing funding decisions. Perceptual Risks Additionally, perceptual risks encompass other concerns. Firstly, there is the risk of erosion of public trust, driven by a perceived lack of transparency and fairness in the Council's actions. Secondly, the perception that decisions may be influenced by personal or political biases rather than objective criteria exposes a susceptibility to bias. Thirdly, nonprofit organizations might perceive the funding process as unpredictable or biased, potentially reducing their confidence in receiving fair treatment. Lastly, the perception of favoritism toward certain nonprofits over others within the community can lead to questions about equitable treatment. Timeline for Awarding • Section 2-139 states, "Agencies shall be notified by the director of their funding or lack thereof by August 31." It is assumed that all activities occur between February, when the director forwards qualifying applications, and August when organizations are notified. However, the Council's activities are not explicitly associated with time frames in the procedure. Observation 3 Opportunity to Clarify Council Responsibilities. We suggest the Hawai'i County Council clarify Chapter 2, Article 25 to explicitly include activities and timelines for reviewing and appropriating non-profit funding. This should include clear guidelines on the evaluation criteria, decision-making processes, and oversight mechanisms. Additional elements to consider: 1. Plan and Design Each Year's Program - eCFR Federal Guidlines Title 2 Subtitle A Chapter II Part 200 Subpart C§ 200.202 requires that the Federal awarding agency must design a program and create an Assistance Listing before announcing the Notice of 7