Corrective Action Plans

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

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action; Brian Tomamichel, Chief Financial Officer Contact Phone Number: 317-867-8013 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Westfield Washington Schools will be hiring a Director of Food Service to oversee our current food service management company. With this hire the district will ensure that this individual is routinely trained on procurement, contract approval, and any other necessary items to ensure that all Federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contract. Anticipated Completion Date: June 2023

2022-009 – SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM CLUSTER – SUSPENSION AND DEBARMENT U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Passed Through Minnesota Department of Human Services Pass Through Number: H55210010 Award Period: 2022 Recommendation: We recommend that the County ensure it is either checking sam.gov and documenting that check or has a contract in place with the required self-certification language for each vendor paid over $25,000 for a type of service or item that was paid for in whole or in part by federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: This is now a standard practice in the contracting process that is managed by the Community Services Contracts Department. Any contract that EEA may need to enter in to must flow through the contracts team and as such, it will follow this recommendation. Name of the contact person responsible for corrective action: Daren Nyquist, Administration Manager Planned completion date for corrective action plan: December 31, 2023

Vendors will be reviewed and documented that they are not debarred, suspended, or otherwise excluded from participation in federal award programs by use of the System for Award Management (SAM), the Official U.S. Government system. [New procedure implemented]

2021-006 - Compliance with Uniform Guidance - Procurement; During the 23-24 fiscal year, the Controller (Jarri Melton) audited the vendors more than the $25,000 threshold to determine if they are debarred, suspended, or otherwise excluded from participation in federal award programs. None were noted to be ineligible for participation. The Agency developed and implemented a purchasing policy which encompasses the requirements of the Uniform Guidance, including the requirement to review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs. During the 21/22 fiscal year the Payables Accountant (Jarri Melton) completed a review of the Agency’s vendor list to ensure that the Agency followed 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. A hard copy of this review was signed by the Controller (Jarri Melton), then filed. The Payables Accountant (TBD) and the Controller (Jarri Melton) will perform this review going forward for any new vendors. Additionally, the Agency’s purchasing policy was updated in fiscal year 21-22, with purchase orders, a purchase order numbering system and tracking. here are monthly closings / reconciling of outstanding purchase orders from the prior month done by the Payables Accountant (TBD). The Revenue Accountant (Deena Iaccarino) and Purchasing Clerk (Marissa Anderson) assign purchase order numbers to the purchase orders and the originals are kept in a folder for the Payables Accountant (TBD) to retrieve when closing out the month. The Controller (Jarri Melton) will ensure this occurs by conducting monthly reviews. The CEO (Marianne Gribbon) will monitor the process, quarterly.