Corrective Action Plans

Action Plan: Upon learning of this finding during the FY2022 audit, we worked with our external consultant, our Council auditors and our external auditor to reperform and review the base year and subsequent year calculations of revenue, using financial information in our final audit reports. These corrected calculations of lost revenue have been clearly documented and will be reported going forward. We will continue to work to ensure that all controls for grants be documented with written procedures. The procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, reperformable manner including the name of each responsible individual, the specific control they performed over compliance for the grant and the date(s) the controls were performed. Contact Names responsible for the plan – Marcia Saulo Anticipated completion date of the plan – September 30, 2024

U.S. Department of Health and Human Services National Indigenous Women's Resource Center respectfully submits the following corrective action plan for the year ended September 30, 2023: Audit Period: October 1, 2022 to September 30, 2023 The finding from the Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING-MAJOR FEDERAL PROGRAMS SIGNIFICANT DEFICIENCY 2023-001 Suspension & Debarment Recommendation: We recommend the Organization increase training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed on all covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We have informed all individuals involved in procurement and contract approval of the requirement to perform suspension and debarment checks on hotel venues. Additionally, we will provide additional training to provide a better understanding of the procurement and contracting requirements. Name of the contact person responsible for corrective action: Lora Helman Planned completion date for corrective action plan: September 30, 2024 If the U.S. Department of Health and Human Services has questions regarding this plan, please contact Lora Helman at lhelman@niwrc.org.

Condition: During testing we noted the Organization did not retain support showing they had searched if an entity was debarred, suspended or otherwise excluded. Planned corrective action: KYD Network and the American Rescue Plan Act (ARPA) Compliance Contractor will conduct a search to ensure all ARPA funded organizations have not been debarred, suspended, or otherwise excluded from receiving federal funds prior to receiving ARPA summer program funds. The results of the search will be included in the ARPA spreadsheet. Responsible Person: Viridiana Carvajal, Co-Executive Director, and American Rescue Plan Act (ARPA) Compliance Contractor Anticipated completion date: May 10, 2024. This action already has been implemented for the 2024 ARPA summer program.

Finding Number: 2023-005 Condition: Two of forty contracts was entered into with a contractor without verification that the entity was not debarred, suspended, or otherwise excluded. As well as two of forty contracts that were tested did not have documentation to support that either the small purchase procedures were followed or the rationale for a noncompetitive solicitation was documented. Planned Corrective Action: Management will ensure that all contracts include verification that an entity is not debarred, suspended, or otherwise excluded and maintain documentation of this review in the contract file. While our current internal controls already support this practice, we acknowledge that there were instances in which this was unintentionally missed. We are re-educating procurement staff regarding the necessity of these verifications. Additionally of note, is that the contracts in question related to emergency professional services in support of MTA's response to the global pandemic. Due to the emergent situation, the ideal processes were not followed. We acknowledge that internal controls must be followed for all contracts, regardless of urgency. Furthermore, the contract should have been reevaluated when the Public Health Emergency ended, and the processes used should have been fully documented. We will endeavor to have full documentation in the future. Contact person responsible for corrective action: Colette Champine, CFO/Corwin Matthews, COO Procurement & Capital Projects Anticipated Completion Date: Already completed

Action taken in response to finding: • LMC staff will retain documentation for sam.gov verification

Planned Corrective Action: This item was included in the 6/30/22 Report on Compliance for Major Federal Programs which was finalized in February 2023. The G/L Vendor List was found to contain many inactive vendors and was modified. Beginning in October 2023, management began sending the Vendor List to EPStaffCheck on a monthly basis. Each vendor is run through OIG {Office of Inspector General for Excluded Individuals/Entities); OIG_Most_Wanted (Fugitives); SAM (System for Award Management for excluded parties); SON.Office of Foreign Assets Control (Specially Designated Nationals) and NY_Medicaid (Exclusion List).

2023-002 Suspension and Debarment Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A signed debarment letter is now a required document for vendors greater than $25,000. This letter is verified by our University procurement office before the item is purchased.   Name(s) of the contact person(s) responsible for corrective action: Dawn Durham Planned completion date for corrective action plan: 10/6/2023

Condition: We noted during testing that the City had omitted a subrecipient from its search to ensure that the subrecipient was not suspended, debarred, or otherwise excluded pursuant to 2 CFR section 180.300. Planned Corrective Action: Procedures have already been put into place to ensure that each new contractor is not on the Federal list of suspended and/or debarred contractors. Furthermore, all vendors previously paid have been searched for in the Federal list and none were suspended and/or debarred. Contact person responsible for corrective action: Lee Ward, Director of Finance. Anticipated Completion Date: 12/15/2023

Finding Number: 2022-006 Condition: Policies and procedures in place over procurement, suspension, and debarment are not in conformance with Uniform Guidance. Additionally, the Organization did not procure in accordance with the regulations, including maintaining records sufficient to detail the history of each procurement transaction nor did they comply with suspension and debarment rules. Planned Corrective Action: Management will implement written policies and procedures over procurement, suspension, and disabarment that conform with Uniform Guidance Contact person responsible for corrective action: Chief Financial Officer Anticipated Completion Date: 06/30/2025

FINDING 2022-005Contact Person Responsible for Corrective Action: Kristin CharlesContact Phone Number: 765-866-0203Views of the Responsible Official: The School Corporation is in agreement with the Finding.Description of Corrective Action Plan: We will provide additional training to our Food Service team about the processes with suspension and debarment. We had assumed we had done enough due diligence since we passed our IDOE Child Nutrition audit; on the same token that audit may not have encompassed the sample that was randomly selected by CLA. We will also add suspension and debarment language into any other contract we anyone that we enter where there is a chance that Federal Dollars could be used for the purchase.Anticipated Completion Date: ASAP

Finding Number: 2022-011 Federal Program, Assistance Listing Number and Name: ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 Condition: Original Finding Description: During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost-price analysis. Contact Person Responsible for Corrective Action: Sandra Yu Stahl Anticipated completion date: June 2023 Planned Corrective Action: The city will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.

Finding 2022-001 ? Suspension and Debarment Recommendations: The Board of Directors, the Director and key positions of management should re-assess the current board policy and potentially add encompassing compensating controls. The Board should then periodically check that all procedures agreed upon are operational and effective, and adjust procedures as needed. Action Taken: We agree with the recommendation and are set to re-address the board policy with board members, Business Director, Federal Funds Director, and Superintendent. Our targeted implementation date is March 2023.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over Procurement, Suspension and Debarment. After this review, we will implement a system to ensure that all procurement methods are followed properly and that suspension and debarment checks are completed prior to awarding of contracts. Some measures have already been implemented, such as a procurement pack is being prepared for each procurement that is completed using federal funds. This process started in July 2022. Anticipated Completion Date: We expect this Corrective Action to be implement by the end of April 2023 to allow for a full review of all internal control processes and procedures.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Shane Hacker, CFO; Tracy Boss, Deputy Treasurer; Jordan Ryan, Coordinator for Nutrition Services Contact Phone Number: 317-852-5726 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Moving forward, the Nutrition Services Coordinator will ensure that a certification of suspension and debarment is completed prior to approving contracts over the $150,000 threshold, per the district?s Child Nutrition Procurement Plan. Anticipated Completion Date: July 1, 2023

Suspension and Debarment ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend that Legacy retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. The organization can keep screenshots that Sam.gov was checked or a PDF print out of the web page. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ? LMC staff will review the OIG exclusions list prior to onboarding or signing contracts with vendors. ? LMC staff will print and retain proof of each review for reporting purposes. Name(s) of the contact person(s) responsible for corrective action: Melissa D?Onorio, CEO, and Emily Faricy, CFO. Planned completion date for corrective action plan: January 15, 2023

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has updated verbiage in our general Terms & conditions to include compliance with the suspension and debarment regulation. Additionally, a Suspension and Debarment Self Certification statement will be included with all the college solicitations. Name of the contact person responsible for corrective action: Karina Jackson, Director for Finance Planned completion date for corrective action plan: April 30, 2022

Finding Number: 2022-001 Condition: The College did not have a policy in place to ensure it was complying with "Never Contract with the Enemy" and verifying that a contractor is not debarred, suspended, or otherwise excluded from doing business with federal assistance programs or activities. In addition, the College's policy does not include all provisions in 2 CFR Section 200.318-327. Planned Corrective Action: An Albion College ?Never Contract with the Enemy? policy will be put into place and have the following conditions within the policy: The ?Grants and Foundation Relations Grants Manual? will be updated to include policy information about this federal regulation and how to determine whether a subcontractor/vendor is prohibited under this policy from being paid with federal grant funds. The Grants and Foundation Relations team (?GFRT?) will include the federal regulation in every ?Grants Kickoff Meeting? checklist and will discuss with the Principal Investigators (?PI?s) during grant development so that issues can be addressed at the beginning of federal grant application process. PI?s of the federal grants will be responsible for checking the SAM excluded vendor list as they are finalizing their budget and/or planned expenditures to confirm all subcontractors/vendors are allowed and in good standing, before any contract over $50,000 is executed or any invoice greater than $20,000 is paid. The Business Office will verify that the vendors or subcontractors for federal grants have been checked against the SAM excluded vendor list during the expenditure approval process. In addition, the College with develop a procurement policy that conforms to provisions in 2 CFR Section 200.318-327 and all federal grant recipients should review and adhere to that policy for all purchases and expenditures made with federal grant funds. Consult with GFR or the Business Office if there are questions about these standards and how they may impact federal grant expenditures. Contact person responsible for corrective action: Amy Routhier-Chief Advancement Officer for Grants and Foundation Relations & Albert Hammond-Staff Accountant-Gifts and Grants Anticipated Completion Date: The GFRT has added a ?Never Contracts with the Enemy Policy? to the Grant Manual, which is presented at all ?Grant Kickoff? meetings. The team also discusses with each (?PI?) in grant development what the policy expectations are.

2022-002 Higher Education Emergency Relief Funds Recommendation: We recommend the College document suspension and debarment procedures going forward for any vendors with federal expenditures over $25,000. We also recommend a procurement policy be implemented that meets the requirements of Uniform Guidance as well as the conflict of interest policy is updated to conform with Uniform Guidance. Lastly, we recommend documentation be retained as it relates to the methodology chosen for procurement in accordance with the procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A procurement policy will be developed to include appropriate procedures to meet Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Michele Peterson Planned completion date for corrective action plan: 06/30/23

U.S. Department of Housing & Urban Development 2022-002 Continuum of Care ? Assistance Listing No. 14.267 Recommendation: We recommend that polices and procedures are implemented and that appropriate documentation is maintained when entering into transactions with covered entities as defined by 2 CFR section 180.220.Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Agency?s procurement policy will be updated to reflect the current federal guidelines under 2 CFR section 180.220 and 48 CFR 52.209-6 and procedures will be implmented to ensure that all covered transactions over $25,000 do not include venders that have been debarred, suspended, or proposed for debarment. Name(s) of the contact person(s) responsible for corrective action: Chris Willis, CFO Planned completion date for corrective action plan: 12/12/2022

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

Compliance requirement ? Procurement, and suspension and debarment Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor findings on the deficiencies in a), b) and c), about requesting quotation because, In accordance with the procedures under 2 CFR ? 200.320, and the definitions under 2 CFR 200.1 and 48 CFR Part 2, subpart 2.101 to support response to an emergency; the seven (7) referenced procurement transactions were under the Micro-purchase threshold for a national emergency response and the purchase could be awarded without soliciting competition or quotations. 2. The institution concurs with the auditor finding. The institution will incorporate the verification of suspension and debarment under the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution. Actions Taken or Planned: The institution will incorporate the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution.

2022-003 Finding: Procurement, Suspension and Debarment Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Out of five loans selected for testing, two of the loan agreements did not include a representation that the borrower is not currently debarred, suspended, excluded, or disqualified by any Federal department or agency, and no other procedures were performed by the Organization to determine if these two borrowers were debarred, suspended, excluded, or disqualified. A subsequent review of the borrowers determined that neither was debarred, suspended, excluded, or disqualified. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding. MCCD currently has a section in its loan documents for borrowers to certify that they, any coborrowers or principals, are not presently debarred, suspended, or proposed for debarment from transactions by any Federal department or agency. The two loans referenced in the finding are loans where MCCD was a participating lender; we used the lead lender?s loan documents. The lead lender?s loan documents did not have a section for the borrower to certify they are not debarred, suspended or are being proposed for debarment from transactions by Federal departments or agencies. MCCD will create and implement a policy to verify that borrowers are not debarred, suspended or are being proposed for debarment from transactions by Federal departments or agencies when making a participation loan. MCCD?s Loan Program staff will (1) check the suspension and debarment list through the federal government?s website, and (2) save a copy of the of the results to the borrower?s loan file. Responsible Official: Trish DeAnda, Chief Financial Officer Completion Date: April 21, 2023

Planned Corrective Action: Management will revise its procurement policy to include a semi-annual review of the vendors charged to federal programs eligibility to participate in federal award programs.

Contact Person ? Maureen Storstad ? Finance Director Corrective Action Plan ? The City is in the process of updating its procurement policy to include verbiage related to the suspension and debarment requirement. Completion Date - Immediately

2022-005 - Finding Condition We noted during testing procurement, suspension, and debarment that the County doesn't have a procurement policy that follows Uniform Guidance. We also noted during testing for suspension and debarment that 3 of our 4 vendors tested were not reviewed to ensure they were not suspended or disbarred from federal funds. Corrective Action Plan per Debbie Nelson, Auditor We agree. A procurement policy is being drafted for approval by the Grand Forks County Commission. Anticipated Completion Date Fiscal Year 2023