Sourceamerica

“The 990 is provided to the full sourceamerica board generally 30 days in advance for review and approval before it is executed by the organization's chief financial officer.”

“All members of the board of directors must file an annual disclosure statement revealing all conflicts of interest. The sourceamerica board of directors adopted a code of conduct policy that all board members must abide by. All sourceamerica employees must abide by the conflict of interest policy and must file a conflict of interest disclosure statement form on a bi-annual basis or as conflicts arise. All new sourceamerica employees certify that they have no conflict of interest upon hire.”

“The sourceamerica executive compensation committee and the board sets and approves the compensation of the ceo. The ceo approves the compensation for all other disqualified persons as defined by irs code section 4958 f(1). The sourceamerica executive compensation committee obtains compensation comparability data for the ceo and other disqualified positions. The comparability data is generally provided by an expert in compensation and is based on industry surveys, documented compensation of persons holding similar positions in similar organizations, expert's own compensation studies and other comparable data. The executive compensation committee reviews all compensation of disqualified individuals to ensure no excess benefit has occurred. The committee's deliberations and final vote excludes any person(s) whose compensation is being approved or any other board member with a conflict of interest. The executive compensation committee documents the basis for its determination with concurrent approval from the full board of directors. The organization's documentation contains the following: 1. The terms of the approved transaction and the date approved, 2.the members of the executive compensation committee who were present during the debate on the transaction that was approved and those that voted on it, 3.the comparability data that was relied on by the executive compensation committee and how the data was obtained and 4. Any actions by a member of the executive compensation committee having a conflict of interest. All documentation must be prepared before the later of the next meeting of the executive compensation committee or 60 days after the final actions of the organization's board of directors. In addition, the executive compensation committee must approve the documentation by the next board meeting.”

“Documents are available to the public upon request.”

“The process has not changed from the prior year.”

“The single audit act requirements under subpart f of 2 c.f.r. 200 do not apply to sourceamerica because the abilityone program fee is not appropriated federal award funds within the meaning of the single audit act (2 c.f.r. 200.500). While the term "federal award" is defined to include cooperative agreements, (2 c.f.r. 200.38), the cooperative agreements contemplated therein refer to "a legal instrument of financial assistance between a federal awarding agency or pass-through entity and a non-federal entity." 2 c.f.r. 200.24; 200.74. Sourceamerica receives no such financial assistance from a federal awarding agency (2 c.f.r. 200.37) or a pass-through entity, by way of subcontract. Without waiving this qualification, sourceamerica voluntarily engaged an external auditor to perform a single audit. Expenses associated with the abilityone program, as defined under the cooperative agreement, were reported in the schedule of expenditures of federal awards (sefa) for 2017 and 2018, recognizing those program expenses were not federal awards.”