Compliance Policies

Empowering Latina Leadership and Action (ELLA)

Financial Policies for Compliance with Federal Grants 

At ELLA, our mission extends beyond delivering impactful programs to the community; it is also about ensuring responsible and transparent financial practices. To uphold these values, we have established comprehensive financial policies designed to guide our budgeting, resource allocation, and fiscal management. These policies provide a foundation for maintaining financial integrity and compliance with both organizational and federal standards, ensuring that ELLA remains aligned with federal agency grant expectations and the broader goal of transparent, responsible program funding.

Code of Financial Regulations (CFR) Cited:

1. Financial Management 2 CFR § 200.302(b)
2. Internal Controls 2 CFR § 200.303
3. Reporting 2 CFR § 200.328
4. Audit Requirements 2 CFR § 200.501
5. Financial Management and Compliance

• ELLA commits to maintaining a robust financial management system that complies with 2 CFR § 200.302(b) to ensure proper oversight and management of all federal and non-federal funds. This includes maintaining accurate records of all financial activities and adhering to policies designed to prevent fraud, waste, and abuse.

1. II. Record Retention and Access

• In compliance with 2 CFR § 200.334, ELLA will maintain financial and programmatic records for a minimum of three years from the date of submission of the final expenditure report. This includes all financial documents, records related to grant compliance, and other relevant information that demonstrates adherence to federal funding requirements.

III. Transfer of Financial Records

• ELLA acknowledges that, under 2 CFR § 200.335, federal agencies may request the transfer of records that possess long-term retention value. In such cases, ELLA will cooperate with the federal agency's request by promptly transferring the relevant records to federal custody. Alternatively, if agreed upon with the federal agency, ELLA will retain the records that have long-term retention value so long as they are continuously available to the Federal Government. 

1. Methods for Collection, Transmission, and Storage of Financial Information

• In line with 2 CFR § 200.336, ELLA will strive to collect, transmit, and store Federal award information in open and machine-readable formats whenever feasible. These formats will be standard computer-readable formats that can be automatically processed by computer systems to enhance accessibility and efficiency.

1. Access to Financial Records

• In compliance with 2 CFR § 200.337, ELLA will ensure that authorized representatives of Federal agencies, pass-through entities, Inspectors General, and the Comptroller General of the United States have the right of access to any records related to Federal awards. This access will be provided in a timely and reasonable manner, including access to personnel for interviews and discussions pertaining to such records or Federal awards in general.

1. Internal Controls and Risk Management

• Adopting internal controls as described in 2 CFR § 200.303, ELLA will implement checks and processes to safeguard assets, prevent financial mismanagement, and ensure operational efficiency. These measures conducting financial audits quarterly and annually as required, transparent procurement procedures, and whistleblower protection mechanisms.
  • For any concerns related to financial conduct or to report potential mismanagement, we encourage community members and partners to reach out to the appropriate oversight agencies.
    • Washington State Office of the Attorney General: To report fraud or file a complaint, visit https://www.atg.wa.gov/file-complaint.
    • IRS Exempt Organizations Division: For concerns related to nonprofit financial mismanagement, you can refer to https://www.irs.gov/charities-non-profits/irs-complaint-process-tax-exempt-organizations.
    • Office of Inspector General: To Report Fraud, Waste, & Abuse: https://www.epaoig.gov/fraud-waste-and-abuse-indicators-and-examples

VII. Periodic Financial and Administrative Reporting

• ELLA will comply with 2 CFR § 200.328, providing periodic financial and program performance reports. These reports will be submitted quarterly and annually as required, ensuring full transparency and accountability in how federal funds are utilized.

VIII. Federal Audit Compliance

• The organization will adhere to financial regulations outlined by the granting federal agency, including audit requirements under 2 CFR § 200.501(a) and compliance plans as mandated by the federal granting agency for grant recipients.
• ELLA will undergo a single audit if expending $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of 2 CFR § 200.501(a).
• The audit will be conducted by an independent auditor who meets the requirements of generally accepted government auditing standards. ELLA will ensure that the auditor is selected through a competitive procurement process to maintain the integrity of the audit.
• If any findings or deficiencies are identified in the audit, ELLA will develop and implement a corrective action plan to address them promptly. This plan will be shared with the relevant federal agency or pass-through entity as part of our commitment to continuous improvement and compliance.

1. Budget Sustainability, Fiscal Reserves, and Emergency Planning

• To mitigate potential budget shortfalls, ELLA will maintain fiscal reserves according to best practices, ensuring continued service delivery without disruption during unexpected financial conditions.
• Funds received will be allocated according to a detailed budget plan that is compliant with federal agency guidelines and reflects a realistic approach to achieving project outcomes. The allocation will support project feasibility over the grant contract period while planning for long-term sustainability through diversified funding sources. 

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Empowering Latina Leadership and Action (ELLA)

Equitable and Inclusive Job Policies

At ELLA, we believe that an equitable and inclusive workplace is essential to fulfilling our mission of community empowerment and advocacy. Our equitable and inclusive job policies are designed to create a work environment where every employee feels valued, supported, and empowered to thrive. These policies reflect our commitment to fairness, transparency, and respect for diverse perspectives and backgrounds.

1. ELLA Non-Discrimination Policy
   • ELLA is committed to creating an inclusive and welcoming environment for all. We do not discriminate on the basis of race, color, national origin, language, disability, age, gender, sexual orientation, religion, marital status, veteran status, or any other characteristic protected by federal, state, or local law. This commitment applies to all our activities, including employment, education, outreach, partnerships, and all programs and services offered by ELLA.

2. Grievance Procedures
   • ELLA is committed to fostering a safe, inclusive, and equitable work environment. To uphold this commitment, we have established a transparent grievance procedure to address any complaints related to discrimination, harassment, or retaliation based on race, color, national origin, disability, age, gender, sexual orientation, or any other protected characteristic.
   • Filing a Complaint
     • Any individual who believes they have experienced discrimination, or harassment may file a complaint.
     • Complaints may be filed verbally or in writing with the Non-Discrimination

Coordinator, either in person, by mail, phone, or email.

• Contact information for the Non-Discrimination Coordinator:

Name: Vicky Frausto

Address: 521 South 6^th Street, Sunnyside, Washington 98944

Phone Number: (509) 391-9864

Email: vicky@WeAreElla.org

3. Confidentiality and Anti-Retaliation Protections
   • ELLA is committed to ensuring that all complaints are handled with the utmost confidentiality.
   • Retaliation against anyone who files a complaint, participates in an investigation, or opposes discriminatory practices is strictly prohibited. Any retaliation should be immediately reported to the Non-Discrimination Coordinator.
4. Complaint Review and Investigation
   • Upon receiving a complaint, the Non-Discrimination Coordinator will initiate a prompt and thorough investigation, applying a preponderance of the evidence standard. The investigation process may involve:
     • Speaking with the complainant and relevant witnesses.
     • Reviewing documentation or other evidence related to the complaint.
     • Both formal and informal resolution options are available to the complainant, and the coordinator will discuss these options and any preferred approach.

5. Resolution and Notification
   • The investigation will be completed promptly, with every effort to ensure a fair and timely resolution.
   • Following the investigation, the coordinator will notify the complainant in writing of the outcome, including:
     • Whether discrimination was found.
     • Steps taken to address and resolve the complaint if discrimination was found.
     • Additional measures may be implemented to prevent future occurrences of discrimination or harassment.

6. Follow-Up and Appeal
   • If the complainant is unsatisfied with the outcome, they may request a review or appeal by the Executive Director, Board of Directors, or Mediator as needed in the process.
   • ELLA will conduct follow-up checks with the complainant to ensure that any implemented remedies are effective, and that no retaliation has occurred.

7. Inclusive Recruitment and Anti- Bias Hiring Practices
   • ELLA implements standard practices for equitable screening, with mandatory training on bias-free recruitment and inclusive language in job descriptions.
   • The hiring process will be free from discrimination and will focus on relevant, skills-based requirements.
   • Educational and credential requirements that are not directly related to job performance will be minimized to expand opportunities.

8. ADA and Disability Policy
   • In compliance with the Americans with Disabilities Act (ADA) and other relevant laws, we provide reasonable accommodations to qualified individuals with disabilities to ensure equal access to employment opportunities, programs, and resources.
   • We prohibit discrimination or harassment based on disability status and strive to foster a respectful, supportive workplace where everyone can thrive.
   • We will work with employees to identify and provide reasonable accommodations that enable them to perform their essential job functions.
   • We ensure that our facilities, programs, and resources are accessible to all employees, including those with mobility, sensory, or other disabilities. 

9. Fair and Equitable Pay and Benefits
   • All employees will be compensated with a stable, predictable living wage that is fair and transparent.
   • Pay scales will be equitable and designed to grow as employees gain skills and experience.
   • We will regularly conduct market analyses to ensure our compensation aligns with industry standards and remains competitive.
   • Job Specifications and compensation will be routinely assessed to ensure fairness across all roles.
   • All Employees will be offered benefits that ensure economic security, such as health insurance, retirement plans, and work-family support. 

10. Skills Development and Career Advancement
    • ELLA will offer equitable opportunities for career advancement, providing transparent pathways for promotions and growth.
    • Employees will have access to high-quality training and education to help them progress within or beyond the organization.

11. DEI Training and Education
    • ELLA will provide consistent DEIA training for all staff, including leadership.
    • Allocate budget for DEIA workshops and development opportunities, establishing these as annual requirement.
    • Leaders will undergo DEIA training specific to their roles, fostering an understanding of diversity’s value in their work and leading by example.

12. Psychological Safety
    • At ELLA, we are committed to fostering a workplace culture that prioritizes psychological safety for all employees.
    • We define psychological safety as an environment where everyone feels comfortable expressing ideas, asking questions, and sharing concerns without fear of judgment or retaliation.

13. Employee Experience and Retention
    • Conduct a robust and positive onboarding process for new hires, ensuring they are introduced to DEIA initiatives, support groups, and other staff resources to foster engagement and improve retention.
    • Develop and conduct yearly or biannual pulse surveys to monitor workplace culture and address concerns.
    • Develop measurable indicators to collect longitudinal data that tracks workplace progress and identifies ongoing barriers to work culture improvement, employee development, and retention.
    • Conduct yearly performance reviews to assess progress, provide constructive feedback, set goals for the upcoming year, and support each team member’s professional growth and development within the organization
    • Conduct exit interviews to improve retention strategies, ensuring all feedback is acted upon to create a more inclusive environment.