Corrective Action Plans

Suggested Action (s)- Send out communication to reinforce understanding and responsibilities of the verification process as required by CRS policy. Responsible Official- Global Controller Senior Director Finance Systems & Operations Regional Finance Officers Country Program SMT. Completion Date- September 30th, 2023.

ARPA Business Support Program ? Assistance Listing No. 21.027 Recommendation: We recommend the Chamber adopt a procurement and suspension and department policy that is in accordance with requirements established by the Uniform Guidance. Furthermore, we recommend these policies are approved by the board of directors. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Chamber is not expecting to receive federal funds exceeding the $750,000 single audit threshold in the future. However, the Chamber will review 2 CFR ? 200.318 and 200.213 while preparing the procurement and suspension and debarment policies to ensure Uniform Guidance standards are followed. Name of the contact person responsible for corrective action: Colin Hastings, Executive Director Planned completion date for corrective action plan: May 2023

Finding 2022-001 ? Suspension and Debarment Information on the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 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 27,000 vendors in 2022. 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 preventative 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 preventative and detective internal controls. Sanford will document 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 will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process. Responsible official: Tracy Sattler, Director of Compliance and Melanie Paape, Executive Director of Supply Chain Anticipated completion date: August 31, 2023

2022-001 Suspension and Debarment ? ICS updated its Fiscal Policies and Procedures to include procedures specifically related to Suspension and Debarment during the year ended June 30, 2020. Beginning on July1, 2022, documentation of management's determination of whether a vendor was debarred or suspended was maintained. The Controller will review monthly the listing of all covered vendors to ensure documentation was maintained and that no transactions occurred with vendors suspended or debarred.

The District will monitor vendors to ensure they are able to accept federal monies. Samantha Schweizer, Business Administrator by 6/30/2023.

2022-004 INTERNAL CONTROL OVER COMPLIANCE AND COMPLIANCE WITH PROCUREMENT, SUSPENSION AND DEBARMENT The National Trust has a Procurement SOP that is fully responsive to CFR ?200.318, and the sampled expense complied with that policy when procured in April 2022. Federal funds were awarded in July 2022 permitting reimbursement of costs incurred as early as March 2021. At the direction of pass-through entity Westchester County, these one-time coronavirus relief funds were applied to reimburse the National Trust for expenses selected by that entity even though the vendors were contracted prior to the award of relief funds. To remedy any gaps in our process, the National Trust will modify the Procurement SOP to clarify that multiple contracts with a single vendor must be treated as a single contract for purposes of the small purchase threshold and will ensure that all expenses are subject to the more stringent requirements under CFR ?200.318. Additionally, the National Trust will modify the procurement procedures to ensure that suspension and debarment screening occurs prior to entering contracts. Individual(s) Responsible for Corrective Action Plan: Thompson Mayes Chief Legal Officer and General Counsel 202-588-6182 Anticipated Completion Date: June 30, 2023

Recommendation: We recommend the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. 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 included it as a finding. Todd Barker is the new School Nutrition Director with BOCES and he will provide documentation to the district that due diligence has been done to meet this requirement. Anticipated completion date: 11/1/2022

Emergency Connectivity Fund Program - Procurement, Suspension and Debarment Information on Federal Program: Federal Communications Commission Emergency Connectivity Fund Program Assistance Listing No. 32.009. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in this specific Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.213 for this major program. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Cost: None. Ernergency Connectivity Fund Program - Procurement, Suspension and Debarment Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District's vendors charged to the major program that were selected for testing, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No __Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in all Federal assistance pr9grams or activities is performed prior to disbursing federal funds to the vendor. Views of responsible officials and planned corrective actions: Effective immediately, the District is implementing the following: The Procurement Specialist in the Technology Department (Maura O'Brien)) will check the SAMS Debarment and Suspension website quarterly.? The data obtained from the quarterly check will be logged into a Google Sheet that is shared with Erin Sheevers, the Chief Technology Officer. ? Any ineligible vendor information will be shared with the Accountant (Steven Terry) in the Business Office.Implementation Date: October 14, 2022

2022-006 Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursement funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District has created a sams.gov account to verify any company that is paid with Federal money. Implementation Plan: The Interim Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money. Implementation Date: November 2022. Person Responsible for Implementation: Interim Business Administrator - Brenda Leitt.

2022 002 Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency U.S. Department of Interior, U.S. Department of Education Title Indian School Equalization Program Federal Assistance Listing Number 15.042, 84.027 Questioned Costs None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non federal entities are subject to the non procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict 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. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team

Information on Federal Programs: U.S. Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 0.553 and 10.555) passed through the New York State Education Department. 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): Criteria: CFR Section 200.318 stipulates that a non -Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: No Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs and activities. Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. 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): Kristin Chotkowski, Purchasing Agent Deadline for Completion: On or before 4/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 1/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 2/1/23.

The Grants Finance Department, Purchasing Department along with the Federal Grants Department 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.

Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. Name and Title of Responsible Official: Michael Stock, Board Chairman Planned Completion Date: Immediately.

Views of Responsible Officials and Planned Corrective Actions: USTTI management will develop and implement a formal policy on suspension and debarment. The policy will include a threshold for when vendors, suppliers, contractors and employees should be screened and no contract will be signed or payment issued until all screenings have been conducted. All USTTI employees will be notified of this policy.

Views of Responsible Officials: SAM checks are on file for all vendors paid for using Federal Funds in 2022 and 2023. SAMU will continue to provide training to staff regarding the importance of continuing to conduct SAM checks prior to making purchases. SAMU has included conducting SAM checks in the procurement policy and process.

2021-003 Child Nutrition Cluster - CFDA No.’s 10.555, 10.559 Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Framingham Public Schools (FPS) contract procurement is handled by the Purchasing Department in the City of Framingham. FPS Executive Director of Finance and Operations, Lincoln Lynch IV, notified the Chief Procurement Officer, Jennifer Pratt, and City Framingham legal counsel, Christopher L. Brown of Petrini & Associates, P.C, of this finding and requested that 1) debarment and suspension procedures be included in the City of Framingham Procurement manual by no later than 01/03/2022 and 2) City of Framingham Supplemental Conditions be included in any City of Framingham contract where there is partial or whole federal funding (there is no dollar threshold). Name(s) of the contact person(s) responsible for corrective action: Jennifer Pratt - Chief Procurement Officer City of Framingham and Lincoln Lynch, IV - Executive Director of Finance and Operations Framingham Public Schools Planned completion date for corrective action plan: In progress with a start date of 1/03/2022.

2021-001 Special Education Cluster - CFDA No. 84.027 and 84.173 Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Framingham Public Schools (FPS) contract procurement is handled by the Purchasing Department in the City of Framingham. FPS Executive Director of Finance and Operations, Lincoln Lynch IV, notified the Chief Procurement Officer, Jennifer Pratt, and City Framingham legal counsel, Christopher L. Brown of Petrini & Associates, P.C, of this finding and requested that 1) debarment and suspension procedures be included in the City of Framingham Procurement manual by no later than 01/03/2022 and 2) City of Framingham Supplemental Conditions be included in any City of Framingham contract where there is partial or whole federal funding (there is no dollar threshold). Name(s) of the contact person(s) responsible for corrective action: Jennifer Pratt - Chief Procurement Officer City of Framingham and Lincoln Lynch, IV - Executive Director of Finance and Operations Framingham Public Schools Planned completion date for corrective action plan: In progress with a start date of 1/03/2022.

Findings: Procurement, Suspension and Department - Procurement policy not maintained by client and contracts was made to vendors without checking suspension and debarment status on www.sam.gov. Status: Resolved Correction Action: DSAL has updated the organization's policies and procedures to ensure with Tittle 2, Code of Federal Regulations (CFR), Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards and include review of the System of Award Management www.sam.gov (SAM) to determine whether vendors were debarred or suspended.