Commissioner Russell,
I can tell you have spent a lot of time on these amendments. It looks much better. Thank you for all the time you have spent editing your original submission.
I have some continued reservations on the requirement for an external audit. May I make a suggestion on verbiage? Most of the defined services receive grants of $10,000. An audit will cost generally at least near this amount. Why should a small nonprofit even accept the funds if it costs as much in compliance costs as the grant itself?
May I suggest having a dollar theshold of the grant that triggers requiring an audit? Perhaps $50,000 or $100,000? Even if this doesn’t pertain to any nonprofits today, it would provide guardrails for many years if grants / contracts increase over time. I could potentially agree with this amendment. However, I feel the audit requirement for all funding, regardless of dollar amount, would be overreach for smaller nonprofits.
Respectfully submitted,
Shane
