Corrective Action Plans

Finding ref number: 2023-002 Finding caption: The County’s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of County contact person: Leo Kim, Chief Financial Officer 411 N 5th Street Shelton, WA 98584 (360)427-9670 Corrective action the auditee plans to take in response to the finding: The County is committed to ensuring internal controls are adequate for compliance with federal suspension and debarment requirements. Management understands the seriousness of potentially awarding federal funds to ineligible parties and has taken steps to confirm that compliance is followed in future purchases using federal funds. An updated purchasing and contracting policy and procedures was adopted by the Board of County Commissioners in December of 2023. The document includes an updated section on suspension and debarment regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180, per §200.213. County offices and departments will ensure and document that no agreement for goods or services is entered into with any entity or person who has been disqualified from participation in Federal programs or activities. Program staff will do this by checking the federal System for Award Management (SAM.gov) prior to the contract execution date. If the contractor is not listed in SAM.gov, the County created a “Certification of no debarment or suspension form” that the contractor can attest and/or the attestation may be added to the contract. Both the SAM.gov check and/or the “Certification of no debarment form” must be completed at or before contract execution and documentation will be maintained in each contract file. The County is committed to providing training on federal grants at least annually to all county staff that work with them and anticipates full compliance with the suspension and debarment requirements moving forward. Anticipated date to complete the corrective action: 8/7/2024

Views of Responsible Officials: The Organizations concur with the auditor's assessment and are in the process of implementing a formal procedure that documents their Suspension and Debarment screening practices.

Views of Responsible Officials: New audit procedures were established for the FY 2023 audit related to federal procurement testing that generated these findings. Management is aligned with the findings from the audit firm. We have the following takeaways. Vendor Screenings: Vendor screening procedures are part of our current procedures, but we will make process improvements:  In accordance with the Suspension and Debarment compliance requirements (section M-12 & M-14) of the USAID Cooperative Agreement, JGI-USA and JGI-Tanzania will process and retain vendor screenings before payment to vendors.  The following sources will be used for screenings:  SAM.gov  OFAC sanctions list  UN List  We will retain the evidence of the screenings, including the dates of the screenings, within our files and these will be available for subsequent audit procedures.  Our Procurement Policy in Tanzania and the USA will be updated to include these required procedures. Procurement Documentation: JGI-USA and JGI-Tanzania have procurement procedures and policies in place, but our procedures need to be updated to include some specific considerations:  When a partner or vendor is included in a proposal by name, we must prepare documentation that supports sole source procurement or a bid analysis to justify the selection of this partner. Alternatively, we may work with the donor to obtain written approval to proceed with the vendor used in proposal.  We will update our procurement manuals to include templates for sole source justifications and bid analysis to justify vendor selection and fully comply with §200.320.  Our Procurement Policies will be updated to fully comply with §200.320 and §200.213

American Diabetes Association (ADA) is committed to ensuring the appropriate documentation is in place to adhere to federal regulations regarding procurement, suspension, and debarment. In response to the audit finding, ADA is taking the following corrective actions to address the audit recommendations: 1) Financial Services will communicate annual reminders of the existing policy relating to procurement policies including the requirement to evaluate a firms status relating to federal suspension and debarment. 2) Federal grant program management will develop and utilize a checklist to ensure that all procurement steps are completed prior to forming a relationship with a potential vendor.

2023-006 - Internal Control Over Compliance and Compliance – Procurement, Suspension and Debarment Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: July 2024 Management’s Corrective Action Plan NGA has always mandated that all vendors paid using federal funds be checked on SAM.gov for debarment or other issues. NGA believes this finding reflects a single isolated incident in which this check was completed, but records were not saved as a PDF within our vendor records. NGA has reiterated and retrained staff on the importance of documentation retention and ensuring that accounting staff consistently retrain these records. NGA expects this issue to have been fully addressed as of July 2024.

Finding 2023-002 Issue: For the procurement samples tested, Management did not provide adequate supporting documentation for the procurement including ensuring proper suspension and debarment checks were performed. Recommendation: We recommend that the Organization establish written procurement policies and procedures to ensure that Organization is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Action Taken: Current MGHPCC policy states that criteria for approval of Purchase Orders above $25,000 include a check to ensure that the vendors are not suspended disbarred, or otherwise excluded from participating in a covered transaction as defined in 2CFR 180.220 and 2CFR 180.300. Policy has been updated to require that the check be documented by capturing a copy of the entity information database entry at www.sam.gov as part of the Purchase Order approval process for vendors who exceed the threshold defined in 2CFR 180.220 and 2CFR 180.300. The entity information database report includes a time stamp, which serves as an indication of when the database entry was checked. Completion date: The MGHPCC Controls for Federal program document was updated on March 15, 2024, and documentation has been retained for all relevant Purchase Orders subsequent to that date. If the National Science Foundation has questions regarding this plan, please contact John Goodhue by telephone at 413-552-4900 or by email at jtgoodhue@mghpcc.org.

Sanford Corrective Action Plan December 31, 2023 Finding 2023-001 – Suspension and Debarment/Procurement Information on the federal program: Federal Agency: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing: 93.155 Award Year: 2021 Planned corrective actions: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third-party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford’s compliance department to ensure that there are no findings that would be of concern to Sanford’s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 23,754 vendors in 2023. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford’s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to the vendors that are suspended or debarred. Sanford believes the risk of any material disbursement to suspended and debarred vendor is effectively mitigated through existing preventive and detective internal controls. In August 2023, Sanford began documenting a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford enhanced its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results generated through the vendor setup process. Responsible official: Tracy Sattler, Director of Compliance and Melanie Paape, Vice President of Supply Chain Operations As it relates to the procurement of goods and services, Sanford’s preventive and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being utilized for procurement. Sanford believes the risk of any material disbursement subject to procurement is effectively mitigated through existing preventive and detective internal controls. To provide context on the scale of procurement under the program $2,298,733 in expenditures exceeded the micro purchase threshold and $307,249 were found to have inadequate documents for sole source. Sanford will provide education to applicable departments related to the compliance requirements subject to procurement. Sanford will document the procurement process from the initial approval to potential sale/disposition items. Responsible official: Kristi Crawford, Director of Office of Grants Anticipated completion date: June 30, 2024

Views of Responsible Officials: Management will ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number: SLFRP1026 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Prior Year Finding: No Criteria: Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work to individuals and firms or economic considerations. Control: Per 2 CFR Section 200.303(a), a non‐Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Spotsylvania County Public Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Questioned Costs: None Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program Cause: Spotsylvania County Public Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Recommendation: Spotsylvania County Public Schools should ensure that employees are following the requirements they have outlined in their procurement policy. Views of Responsible Officials and Planned Corrective Action: Our procurement office will complete a check list to ensure compliance. Current procedures already require for suspension and debarment verification prior to entering into contracts/agreements with vendors. In this case, the procedure was followed appropriately, but documentation was not retained. Failure to retain a screenshot of the debarment search is easily corrected and staff will ensure such screenshots are saved when the search is completed. Action taken in response to finding: Spotsylvania County Public Schools will ensure the procurement checklist is followed and all supporting documentation is retained on file. Name of contact person (s) responsible for the corrective action plan: Phil Trayer and Jamie Pitts

Views of Responsible Officials: The Foundation will conduct screenings on all vendors, suppliers and consultants. The Foundation will also ensure that the screening date is documented prior to payment or signing of the contract.

Views of Responsible Officials: Management acknowledges the comment and has subsequently established policies and procedures to ensure suspension and debarment checks of vendors, supplies, contractors, and sub-contractors/grantees are done in accordance with the recommended threshold.

Auditor’s Recommendations: We recommend the District establish a policy and implement procedures regarding large purchases related to Federal grants to insure that no vendors who are suspended, debarred, or otherwise excluded from participating in transactions funded through Federal grants are used. As identified above, there are several methods in which the District can verify vendors who are not suspended or debarred. The District may have the vendor provide an annual certification that is s not currently suspended, debarred, or otherwise prevented from receiving Federal dollars. In other occasions in which a single purchase is going to be made, the purchasing procedures should include looking up the vendor on the GSA website, printing a copy of the verification, and placing it in the file with the purchase order. The District has options, and it should establish what method is the least intrusive, but also effective, in complying with the requirements of the Uniform Grant Guidance. Responsible Official’s Plan: • Specific corrective action plan for funding: The procurement Officer of SJSWCD has updated the procurement process on 12/7/23 that all contractors who will be receiving Federal monies must provide an annual certification that they are not suspended, debarred, inactive, or otherwise excluded from participating in transaction funded through Federal grants. The policy change will be approved at the next board meeting. • Timeline for completion of corrective action plan: December 7, 2023 • Employee position(s) responsible for meeting the timeline: Oralia Bridge, District Manager

Suggested Actions: 2.1 Perform a review of Supplier Master Records for completeness. The validation of completeness will include but will not be limited to the initial suspension and debarment validation report on Supplier Master Record file, in accordance with CRS Supplier Master Record Management policies and procedures. Responsible Officials: Director of Global Procurement, DRD Operations, SCM RTAs, Head of Operations, Supply Chain Managers Completion Date: September 30th, 2024

Specific corrective action plan for finding: Christi Walter, Coordinator Purchasing Department along with the Dom Atcitty, Grants Specialist, will review vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached. At the initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document from SAM.GOV verifying eligibility of vendor will be attached to the vendor file. Timeline for completion of corrective action plan: July 1, 2023 Employee position(s) responsible for meeting the timeline: Dom Atcitty, Grants Specialists; Christi Walter, CPO; Lisa Smith, Purchasing Specialist; Bellamie DeHerrera-Presley, Federal Grants Coordinator and Erica Benally, Federal Grants Specialist

To mitigate this issue in the future, County Counsel reminded departments of the importance of understanding the requirements tied to the source being used to procure goods and services and to notify Counsel when federal monies are being used. Furthermore, County Counsel will include the suspension and debarment clause in the County’s standard contract templates, and the County Purchasing Policy (4-03) will be updated to reflect the importance of complying with requirements tied to a specific funding source. Lastly, County Counsel and Internal Audit will develop and provide training to departments. Antipcated Completion Date: 04/01/2024. Responsible Contact Person: Peter Philbrick

The County does check Sam.gov for suspension and debarment transactions. Documentation was retained but was lost due to a network intrusion. We will remain diligent in documenting our reviews.

Views of the Responsible Officials and Planned Corrective Actions: The Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money.

The District will monitor vendors to ensure they are able to accept federal monies. By Ashley Simmons, Accounts Payable clerk by 6/30/2024.

U.S. Agency for International Development 2023-001 Collaboration for African Biodiversity (ABCG III) – Assistance Listing no. 98.001 Recommendation: Management should ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: AWF management agrees with the finding and recommendation set forth and has developed a corrective action plan. The procurement and contracts manager is now ensuring that AWF captures the date when taking a screenshot from the OFCCP Debarred Companies list when conducting background checks on vendors so as to document that the search has been performed prior to entering into a contract with the vendor.

For the Special Aid and Food Service Funds, the System for Award Management will be checked in the fall and spring for the debarment of any vendors that we expect to pay over $25,000 for the fiscal year. Summary spreadsheets will be provided to the Auditors.

Action taken: The district entered into a shared services agreement with Capital Region BOCES in March of 2022 for management of the School Nutrition program. It was assumed that this was a procedure they followed; however, documentation was not provided and the external auditors inciuded it as a finding. The School Nutrition Director resigned and was replaced by a new School Nutrition Director with BOCES (Greg Nalewjka) and he was unaware that this was necessary. He is working with his supervisors to provide documentation to the district that due diligence has been done to meet this requirement. Anticipated completion date: 11/10/2023

CORRECTIVE ACTION PLAN October 2023 Section III: Federal Award Findings and Questioned Costs Findings and questioned costs related to Federal awards which are required to be reported in accordance with the Uniform Guidance 2 CFR 200.516(a): Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1. Select “Search” from the header menu from any page on SAM.gov 2. In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3. Use the filters or keyword box to enter the search criteria and view the results 4. Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.

Material Weakness in Internal Control Over Compliance (Federal Award Program) The City will develop and implement formal written procedures for the management of Federal award expenditures and procurement activities. All fund transfers will require documented approval by authorized personnel. Procurement processes will include verification of vendor eligibility, compliance with bid law, and retention of supporting documentation. Staff will be trained on federal compliance requirements. Responsible Party: Robert Nielson, Temporary Fiscal Administrator Timeline: December 31, 2025

2022 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance) Material Weakness – 93.U01 Title V Condition: The Organization was unable to provide sufficient documentation to support compliance with federal procurement and suspension and debarment requirements for purchases made under the Title V program. The general ledger did not allow for sufficient identification of transactions related to the Title V program as all expenditures were recorded through journal entries without supporting transaction-level detail. Due to this limitation, we were unable to select procurement transactions for testing or verify whether vendors had been screened for suspension and debarment before contracts were awarded. Corrective Action Plan: As of October 1, 2024, the start of FY25 QuickBooks has been the only software uused,and Revenue and Disbursements are being classed by Fund. General ledgers are reconciled monthly. The following are updated procedures that are now in place. All purchases must come with a purchase order request and be signed by the supervisor prior to purchase. All purchases over $1000 must be CEO approved too. All purchases over $5000 must have 3 bids and be Board approved. All purchase orders must be completed completely in all fields to know what grant/funding source is covering the cost for draw downs. Anyone who uses the SDUIH credit cards must sign a credit card statement

Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town does not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action The Town will review the district’s suspension and debarment policy and make sure that it is following the criteria as set out in the 2 CFR sections 200.213. The policy will then be updated and communicated to all personnel involved in the procurement process. Name of Contact Person Robert J. Civetti, CPA, Finance Director Projected Completion Date June 30, 2025