HomeMy WebLinkAbout2026-10-06 Resolution 2026-369Page 1 of 6
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Adopted this Order on October 6, 2026 by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
RESOLUTION NO. 2026/369
RESOLUTION OF THE BOARD OF SUPERVISORS ESTABLISHING THE
INTERNAL CONTROLS THAT APPLY TO CONTRA COSTA COUNTY HEAD
START PROGRAM FUNDS, ASSETS, AND EQUIPMENT
The Contra Costa County Board of Supervisors resolves as follows:
I.GENERAL
This policy of the Board of Supervisors establishes and describes the internal controls
that apply to Contra Costa County Head Start program funds, assets, and equipment.
These internal controls conform to the internal control guidelines applicable to local
agencies as established by the Controller of the State of California in accordance with
California Government Code section 12422.5, and are in compliance with the Head Start
Act's Post Federal Award Requirements regarding internal controls, as set forth in 2 Code
of Federal Regulations (CFR) section 200 (Internal Controls).These policies and
procedures also document how Contra Costa County complies with the Committee on
Sponsoring Organizations (COSO) framework.
II.INTERNAL CONTROLS THAT APPLY TO CONTRA COSTA COUNTY
HEAD START PROGRAM FUNDS, ASSETS, AND EQUIPMENT
A. The Contra Costa County Head Start program (Program) will maintain fiscal
integrity through implementation of internal controls. This involves a financial
system that ensures budget management, maintains control over current
operations, and provides a complete and accurate record of fiscal management.
The Program is governed by the Contra Costa County Board of Supervisors and
operates within the financial information system of the County of Contra Costa.
The Program operates under the County of Contra Costa's fiscal accountability
rules, policies, and procedures, including the following:
1.Contra Costa County Administrative Bulletin 200 - Capital Asset
Accounting and Budgeting Policy.
2.Contra Costa County Administrative Bulletin 205 - Cash-Receiving,
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Diane Burgis, Ken Carlson, Candace Andersen, Shanelle Scales-Preston, John Gioia5
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Safeguarding and Depositing.
3. Contra Costa County Administrative Bulletin 212 - Internal Audit of
County Departments and Offices.
4. Contra Costa County Administrative Bulletin 215 - Petty Cash
Funds.
5. Contra Costa County Administrative Bulletin 600 - Purchasing
Policies and Procedures. In accordance with 2 CFR 200.318, these
procurement procedures reflect applicable State and local laws and
regulations, conform to applicable Federal law and the standards
identified in 2 CFR Part 200, require the County to maintain
oversight to ensure that contractors perform in accordance with the
terms, conditions, and specifications of their contracts or purchase
orders, and include written standards of conduct covering conflicts
of interest and governing the actions of its employees engaged in the
selection, award and administration of contracts. Specifically, ethical
standards mandated for County procurement activities include the
following:
• Avoiding activities which would compromise or give the
perception of compromising the best interests of the County;
• Actively promoting the concept of competition through bid
solicitation consistent with this policy; and
• Refraining from engagement in any procurement activity in which
an employee may have a personal or indirect financial interest in
accordance with Government Code sections 87100 and 81703.
In addition, the following procurement standards apply to the Program
pursuant to 2 CFR 200.318:
a) No employee, officer, or agent may participate in the selection,
award, or administration of a contract supported by a Federal
award if he or she has a real or apparent conflict of interest. Such
a conflict of interest would arise when the employee, officer, or
agent, any member of his or her immediate family, his or her
partner, or an organization which 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. The officers, employees, and agents of the County may
neither solicit nor accept gratuities, favors, or anything of
monetary value from contractors or parties to subcontracts.
Appropriate disciplinary actions will be applied for violations of
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such standards by officers, employees, or agents of the County.
b) The County will avoid acquisition of unnecessary or duplicative
items. Consideration will be given to consolidating or breaking
out procurements to obtain a more economical purchase. Where
appropriate, an analysis will be made of lease versus purchase
alternatives, and any other appropriate analysis to determine the
most economical approach.
c) To foster greater economy and efficiency, and in accordance with
efforts to promote cost-effective use of shared services across the
Federal Government, the County is encouraged to enter into state
and local intergovernmental agreements or inter-entity agreements
where appropriate for procurement or use of common or shared
goods and services.
d) The County is 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.
e) The County is encouraged to 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.
f) The County will award contracts only to responsible contractors
possessing the ability to perform successfully under the terms and
conditions of a proposed procurement. Consideration will be given
to such matters as contractor integrity, compliance with public
policy, record of past performance, and financial and technical
resources. See also 2 CFR 200.214.
g) The County will maintain records sufficiently to detail the history
of' procurement. These records will include, but are not necessarily
limited to, the following: rationale for the method of procurement,
selection of contract type, contractor selection or rejection, and the
basis for the contract price.
h) The following provision will be included in all contracts entered
into by the County on behalf of the Program: "Contractor shall
establish safeguards to prohibit employees or officers from using
their positions for a purpose which could result in private gain, or
gives the appearance of being motivated for private gain for
themselves or others, particularly those with whom they have
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family, business or other ties. Contractor should maintain a code or
standard of conduct that governs the performance of its officers,
employees or agents in the award and administration of contracts
and provides for appropriate disciplinary actions for noncompliance.
The standards shall include, but not be limited to, prohibition
against soliciting or accepting gratuities, favors or anything of
monetary value from subcontractors or potential subcontractors. Per
2 CFR 200.113, Contractor shall disclose, in a timely manner, in
writing to County all violations of Federal criminal law involving
fraud, bribery, or gratuity violations potentially affecting the
Contract. Contractors may be required to report certain civil,
criminal, or administrative proceedings to the System for Award
Management SAM. Failure to make required disclosures can result
in any of the remedies described in 2 CFR 200.339, including
suspension or debarment."
6. Accounting Standards and Procedures for Counties Manual - 2025 Edition
7. California State Controller's Office - 2015 Internal Control Guidelines for
California Local Agencies.
B. The Program also operates under the following policies:
1. Contra Costa County, EHSD, Community Services Bureau -Fixed Assets,
Information Technology, Low-Value Inventory and Clouds Data System
Policies and Procedures (Attachment F), and the Equipment Inventory
form attached thereto (see 2 CFR section 200.313(d)(l)).
2. Contra Costa County, EHSD, Departmental Fiscal Policy-Fiscal
Monitoring of Subrecipient (Attachment G) (see 2 CFR 200.303(c)).
3. Contra Costa County, EHSD, Community Services Bureau- Cost
Allocation Plan (Attachment H).
C. Monitoring. In addition to the monitoring provisions contained in the above
policies, the Program will be monitored as follows:
1. Monthly Reports to Governing Board. The Head Start Executive Director
and the Head Start Director will present a fiscal report to the Board as part
of the monthly report required by Section III.A.2 of the Contra Costa
County Head Start Program Formal Governance Policy adopted by the
Board of Supervisors. At a minimum, the fiscal report will contain the
following:
o Summaries of Program financial statements, including total
expenditures and revenue received to date;
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o Results of Sub-Recipient monitoring activities, including information
related corrective actions plans entered with delegate agencies, if any;
and
o Results of self-monitoring activities, including information related to
corrective action plans implemented within the County's Head Start
program, if any.
2. Reports to the Head Start Oversight Committee. The Head Start
Executive Director and the Head Start Director will present a fiscal report
to the Head Start Oversight Committee six (6) times per calendar year. At
a minimum, the fiscal report will contain the following:
o Detailed Program financial statements, including expenditure
information by recipient and sub-recipient at the object level (i.e.,
Salaries & Benefits, Services and Supplies, Other Charges, Fixed
Assets, and Expenditure Transfers) and revenue by major federal and
state grant type;
o Details about Sub-Recipient monitoring activities, including schedules
for planned monitoring activities, updates of ongoing monitoring
activities, results of monitoring activities and status of monitoring of
corrective action plans entered with sub-recipients; and
o Details about self-monitoring activities, including schedules for
planned monitoring activities, updates of ongoing monitoring
activities, results of monitoring activities and status of internal
monitoring of corrective action plans.
3. Self-monitoring. The self-monitoring required by 2 CFR 200.303(c) is set
forth in Appendix 15 of Contra Costa County, EHSD, Departmental Fiscal
Policy - Fiscal Monitoring of Subrecipient. Initial self-monitoring (in 2023)
will take place quarterly and will take place semi-annually thereafter.
Compliance assessments will be conducted to ensure:
o Compliance with statutory requirements.
o Review of internal checks/controls.
o Review of financial documents.
o Review of business practices, processes and policies.
D. Training. In addition to the training provisions contained in the above policies,
the Head Start Executive Director and the Head Start Director will cause
employees to be provided with fiscal training on a regular basis to employees on
the above policies and ensure the following:
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1.Agendas. Training agendas will explicitly identify each of the fiscal
policies applicable to the County Head Start Program.
2.Materials. Copies of the policies and internal procedures to ensure
compliance with the policies will be distributed in the training materials.
3.Attendance. Employee training attendance records will be maintained in a
dedicated training file.
4.Head Start Committee Oversight. At the next regular meeting of the Head
Start Standing Committee following a training event, the Head Start
Executive Director and the Head Start Director will provide an update on
training to the Committee, including:
o All the materials in Section II(D)(l-2) above will be included as
attachments to the staff report; and
o A listing of how many employees have not yet received training with a
plan for when those employees are to receive training.
5. Governing Board Oversight. In the next regular, monthly Head Start
Program report to the Board of Supervisors following a training event, the
Head Start Executive Director and the Head Start Director will provide an
update on training to the Board, including:
o Date of the most recent fiscal training provided;
o Summary of the fiscal training agenda;
o Number of employees receiving fiscal training
o Number of employees who still need fiscal training; and
o Date of next fiscal training event.
October 6, 2026ctober 6, 2026