Corrective Action Plans

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FINDINGS 2025-002 Contact person responsible for Corrective Action: Christi McElhaney, City Clerk Treasurer Contact phone number: 260-356-1400 x2016 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The City continues to develop and implement controls ...
FINDINGS 2025-002 Contact person responsible for Corrective Action: Christi McElhaney, City Clerk Treasurer Contact phone number: 260-356-1400 x2016 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The City continues to develop and implement controls that will ensure that all vendors used for Federal Grants will be checked for suspended and debarment within the SAM.gov website and/or include in the contract with the vendor. Anticipated completion date: July 31, 2026
Subject: 2025-002 Material Weakness and Noncompliance – Procurement and Suspension and Debarment (Repeat Finding 2024-002) Federal Agency: Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procureme...
Subject: 2025-002 Material Weakness and Noncompliance – Procurement and Suspension and Debarment (Repeat Finding 2024-002) Federal Agency: Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness and Noncompliance – Procurement and Suspension and Debarment Recommendation: We recommend the City ensure suspension and debarment checks are performed on all CSLFRF transactions prior to payment to new vendors and documented appropriately. Planned Corrective Action: The City agreed with the recommendation and plans to implement corrective action plan by December 31, 2026. City staff are in the process of updating internal policies to ensure that suspension and debarment checks are performed on all CSLFRF transactions prior to payment to vendors and documented appropriately.
The Platte County has implemented procedures to ensure when an entity is selected by Board Resolution/Motion, to be paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or disbarred and such procedure will be documented. The procedure to have the entity verif...
The Platte County has implemented procedures to ensure when an entity is selected by Board Resolution/Motion, to be paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or disbarred and such procedure will be documented. The procedure to have the entity verified is included in the Board minutes.
Corrective Action Plan Contact Person: Belinda Harris Clegg, Wolcott Town Clerk & Treasurer Corrective Action: The Selectboard will update their Purchasing Policy to include checking Sam.gov to confirm if a contractor has not been debarred or suspended from receiving federal funds and to request a S...
Corrective Action Plan Contact Person: Belinda Harris Clegg, Wolcott Town Clerk & Treasurer Corrective Action: The Selectboard will update their Purchasing Policy to include checking Sam.gov to confirm if a contractor has not been debarred or suspended from receiving federal funds and to request a Suspension and Debarment certification from the contractor. Anticipated Completion Date: April 30, 2026
Finding #2025-015 14.850 Public Housing Operating Fund Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action AMP 1 Response: For Items #2 and #4, management concurs with the finding. Management acknowledges that required documentation verifying that co...
Finding #2025-015 14.850 Public Housing Operating Fund Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action AMP 1 Response: For Items #2 and #4, management concurs with the finding. Management acknowledges that required documentation verifying that contractors were not suspended, debarred, or excluded was not maintained in the files. Management will conduct a review of contracts to ensure required documentation is obtained and properly filed and will update internal policies to include a checklist to ensure compliance prior to contract execution. • Documentation Review: We will conduct a thorough review of our contracts and ensure that all necessary debarment, suspension, or exclusion from receiving or participation in federal awards are obtained and properly filed. • Policy Improvement: We will update our internal policies to include a checklist for all new contracts, which will ensure that documentation related to debarment, suspension, or exclusion is acquired before proceeding. For Items #2, #4, and #5, management concurs with the finding related to Independent Cost Estimate documentation. Management acknowledges that documentation supporting cost estimates was not maintained prior to solicitation. Management will implement a standardized process for documenting Independent Cost Estimates and will conduct periodic reviews to ensure compliance. We acknowledge the lack of documentation on the Independent Cost Estimate (ICE) procedures prior to solicitation. GHURA is committed to maintaining a procurement system that is transparent, compliant, and fully aligned with federal and local requirements. Moving forward, we will implement measures to ensure that appropriate documentation is created and maintained for all cost estimates. This includes developing a standardized process for documenting ICE procedures and conducting regular reviews to ensure compliance. For Item #15, management does not concur with the finding. Management states that documentation supporting the Independent Cost Estimate was included in Purchase Order No. PO251039. Management refers to the Small Procurement Abstract/Price Analysis Form, which documents prior pricing information used to support cost reasonableness. Small Procurement Abstract/Price Analysis Form that shows ICE information detailing the last price paid for Consumable Inventory. AMP 2 Response: We acknowledge the need to strengthen monitoring controls to ensure full compliance with applicable procurement, suspension, and debarment requirements. We recognize that verification of contractor eligibility and proper documentation of procurement actions are essential components of an effective internal control system. We acknowledge that documentation of the required suspension and debarment verification was not included in the procurement file at the time of purchase. Although this verification was completed after the fact, we have now confirmed through SAM.gov that the vendors involved were not suspended, debarred, or otherwise excluded from receiving federal funds. To prevent this issue going forward, we have implemented a strengthened control requiring staff to perform and document SAM.gov verification prior to every procurement action, including micro purchases. Verification results will be printed or saved as PDF and filed with each procurement record to ensure full compliance with 2 CFR 200.214 and HUD procurement requirements. These corrective measures will ensure that all future procurements include timely and complete documentation of suspension and debarment checks. Corrective Actions Implemented 1. Suspension & Debarment Verification Controls Strengthened Effective immediately, we have implemented enhanced procedures requiring Housing Administrative Officer personnel to verify all prospective contractors and vendors against the SAM.gov Exclusions Database prior to award. 2. Enforcement of Minimum Solicitation Requirements AMP 2 has reinforced compliance with 5 GCA Chapter 5 and internal procurement SOPs requiring minimum solicitation thresholds: • Three written quotes for small purchases above the micro purchase threshold. • Written justification for any noncompetitive procurement, including emergency, sole source, or inadequate competition. • Staff have been retrained on documentation standards, including price reasonableness, vendor selection rationale, and procurement history requirements. 3. Strengthened Management Oversight and File Review To prevent recurrence, AMP 2 will review all required documentation—including SAM verification, solicitation records, and justifications—is complete. GHURA is committed to maintaining a procurement system that is transparent, compliant, and fully aligned with federal and local requirements. These corrective actions strengthen internal controls, ensure proper oversight, and prevent recurrence of the deficiencies identified. AMP 3 Response: For Items #6 (PO251249) and #10 (PO250104), management does not concur with the finding. Management explains that the purchase orders were structured similarly to indefinite delivery/indefinite quantity arrangements to support recurring and variable requirements throughout the fiscal year. Management states that Housing Administrative Officers solicited pricing from multiple qualified vendors at the beginning of the fiscal year to establish competitively awarded pricing schedules. By securing pricing in advance, management was able to address anticipated needs efficiently without preparing separate Independent Cost Estimates for each task, while maintaining fair and reasonable pricing through competition. For Item #22 (BPA250203), management concurs with the finding. Management noted that the blanket purchase agreement was established to support anticipated advertisement services related to the opening and closing of the AMP3 waitlist. At the time, management determined that only one vendor provided hard-copy print publication services locally and was uncertain whether electronic-only media outlets met program needs. Based on this determination, the agreement was executed. However, management acknowledges that the procurement file should have included documentation of market research performed. Management will ensure that future procurement files include adequate documentation of solicitations, market research, and any sole-source or limited-source justifications, as applicable. AMP 4 Response: AMP4 consistently adheres to all procurement policies and requirements prior to executing contracts, agreements, or purchases. Staff will continually ensure documentation is complete and concise with all procurement procedures. AMP4 Response to items: Item #8. We disagree with this finding. Documentation was completed to continue procurement services. See attached documentation labeled as “#8”. Item #s 17, 19, and 20. We disagree with this finding. Documentation on file to support procurement transactions being conducted in a manner that provided for full and open competition. See attached documentation labeled as “#17, #19, #20”. Item # 23. We disagree with this finding. Documentation on file to show evidence services were awarded equally among multiple vendors. See attached documentation labeled as “#23”. Responsible Party: Asset Management Property Site Managers – Jeanna Blas, AMP 1 Acting, Gina Cura, AMP 2, Patrick Bamba, AMP 3, and Bernadette Tyquiengco, AMP 4 Anticipated Date of Completion: September 30, 2027
Finding #2025-012 14.267 Continuum of Care GU0018L9C002209, GU0026L9C002305, GU0028L9C002204, GU0037L9C002201, GU0031L9C002203 Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action Management’s Position: Management concurs with the finding. Management ...
Finding #2025-012 14.267 Continuum of Care GU0018L9C002209, GU0026L9C002305, GU0028L9C002204, GU0037L9C002201, GU0031L9C002203 Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action Management’s Position: Management concurs with the finding. Management would like to clarify that verification of suspension and debarment status was performed through SAM.gov prior to the execution of subrecipient agreements. Historically, the process involved reviewing the entity’s suspension and debarment status directly through SAM.gov, and maintaining an electronic copy of the verification was not established as a standard documentation practice because the information was available for verification through SAM.gov. As changes have occurred to the availability and accessibility of historical SAM.gov records, management recognizes the importance of maintaining independent documentation of the verification performed. While the required verification was conducted, documentation evidencing the verification results was not consistently retained within the applicable procurement or subrecipient files. As a result, management was unable to provide sufficient supporting documentation during the audit to demonstrate completion of the required verification. Corrective Actions: Management will require retention of supporting documentation from SAM.gov verification, including the date of review and evidence of the verification results, within the applicable procurement or subrecipient file. The responsible program personnel will ensure that suspension and debarment verification is completed and documented prior to execution of applicable subrecipient agreements. The applicable procurement and subrecipient files will include SAM.gov verification documentation to support compliance with federal suspension and debarment requirements. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: The updated procedures and documentation requirements have been implemented.
The Town has been duly aware of it responsibilities pertaining to this program and will comply with the program requirements for suspension and debarment including evaluation and documentation for program expenditures.
The Town has been duly aware of it responsibilities pertaining to this program and will comply with the program requirements for suspension and debarment including evaluation and documentation for program expenditures.
SCORE acknowledges the auditors’ recommendation and confirms that procedures are already in place to verify new vendors against the SAM.gov suspension and debarment database prior to engagement. Management agrees that this procedure should be extended to include periodic verification for contract re...
SCORE acknowledges the auditors’ recommendation and confirms that procedures are already in place to verify new vendors against the SAM.gov suspension and debarment database prior to engagement. Management agrees that this procedure should be extended to include periodic verification for contract renewals and multi-year vendor relationships. SCORE will also update its vendor compliance procedures to require documented SAM.gov verification at the time of vendor onboarding and periodically thereafter for continuing vendors and will implement a centralized tracking mechanism to document verification dates.
2025-003 Suspension & Debarment Cluster: Other major program referenced below Sponsoring Agency: Department of Health and Human Services Award Names: Doorway for Substance Use-Related Supports and Services Award Numbers: Cheshire Medical Center 05-95-920510-7040000 Assistance Listing Title: Opioid S...
2025-003 Suspension & Debarment Cluster: Other major program referenced below Sponsoring Agency: Department of Health and Human Services Award Names: Doorway for Substance Use-Related Supports and Services Award Numbers: Cheshire Medical Center 05-95-920510-7040000 Assistance Listing Title: Opioid STR Assistance Listing Number: 93.788 Award Year: 2024-2025 Pass-through entity: New Hampshire Department of Health and Human Services Management agrees with the finding related to Suspension & Debarment. Dartmouth Health experienced significant leadership turnover and changeover in the contracting and procurement function in fiscal year 2025. This was the primary cause of suspension and debarment checks not being completed before entering into agreements with new vendors. The Office of Research Finance will provide training to procurement and contracting staff to further emphasize the importance of performing vendor checks before entering into agreements. Individual Responsible: John Muhlen, System Vice President of Corporate Finance Anticipated Completion Date: September 30, 2026
Finding 2025-003 Congressionally Mandated Projects / Suspension and Debarment Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed...
Finding 2025-003 Congressionally Mandated Projects / Suspension and Debarment Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the RFP and contract process. Any project that meets additional standards requirements, the checklist will be required and will be maintained for the duration of the project with monthly review at the Executive level to ensure compliance is being met. Responsible Official: Andrew Ferris Chief Financial Officer Kansas City Board of Public Utilities
• Management Response - SERCAP will improve lease accounting controls by: Creating and maintaining accurate model spreadsheet of centralized lease inventory for all operating and financing leases. Establishing written procedures requiring all lease agreements, amendments, renewals, and extensions to...
• Management Response - SERCAP will improve lease accounting controls by: Creating and maintaining accurate model spreadsheet of centralized lease inventory for all operating and financing leases. Establishing written procedures requiring all lease agreements, amendments, renewals, and extensions to be communicated to the Finance Department immediately upon execution. Performing an annual review of all lease agreements to determine whether modifications require remeasurement under ASC 842. Preparing documented lease calculations and reconciliations for supervisory review. Updating accounting policies and procedures related to lease accounting and providing additional staff training regarding ASC 842 requirements. In addition, setup a policy and procedure for the review and documentation review of all contracts for a potential embedded lease transaction. SERCAP has hired new staff for capacity and support. • Contact Person: • Contact Phone Number: • Expected Completion Date: Charles Denny, Jr. - Finance & Operations 540-345-1184 ext. 128 September 30, 2026
Community Mental Health Services of Livingston County Single Audit Report: Corrective Action Plan Year ended September 30, 2025 Finding 2025-001- Suspension and Debarment Requirement: As required by 2 CFR 200.214, Non-Federal entities are subject to the non-procurement debarment and suspension regul...
Community Mental Health Services of Livingston County Single Audit Report: Corrective Action Plan Year ended September 30, 2025 Finding 2025-001- Suspension and Debarment Requirement: As required by 2 CFR 200.214, Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. Condition: The vendor used for this grant was not checked for suspension and debarment prior to execution of the contract. Also, the contract did not include certification that vendor was not suspended or debarred. Questioned Cost: None. Recommendation: We recommend that the CMHSP update contract language to include certification that vendor is not suspended or debarred. Corrective Action Plan LCCMHA will address the concern raised by RPC and agrees with the above recommendation. The Accounting Manager and Associate Director of Finance and Contracts will work with the Contract Manager to modify existing contract language to include certification that vendors are not suspended or debarred. This change will be implemented for fiscal year 2027 commencing 10/01/26. Responsible Party: Jim Kubus, Accounting Manager Anticipated completion date: September 30, 2026
Federal Agency Name: Department of Treasury Pass-through Agency: State of Indiana Office of Community and Rural Affairs Assistance Listing Number: 21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified: • The Entity’s formally documented pro...
Federal Agency Name: Department of Treasury Pass-through Agency: State of Indiana Office of Community and Rural Affairs Assistance Listing Number: 21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified: • The Entity’s formally documented procurement policy was missing the required elements detailed under Uniform Guidance. • Four instances where the Entity did not follow the procurement process and did not have any formal documentation in place with vendors. • Four instances where the Entity entered into a contract with a vendor over $25,000 and there was no review performed to ensure the vendor was not suspended or debarred. Responsible Individuals: Sara Morris, Chief Financial Officer and Jay Watkins, Sr. Vice President of Broadband Services Corrective Action Plan: Management will update their procurement policy to ensure it includes all required elements in accordance with Uniform Guidance. In addition, management will implement procedures and control processes related to the review of procurement to ensure the procurement methods are being followed and documentation isretained to support compliance. Management will also ensure vendors are not suspended or debarred from doing business with the federal government prior to entering into a procurement transaction. Anticipated Completion Date: October 2026
Finding 2025-001- Material Weakness related to Procurement and Suspension and Debarment Information on the federal program: Federal Agency: Department of Health and Human Services, Department of Homeland Security, Department of Defense, Department of Justice, National Science Foundation, Department ...
Finding 2025-001- Material Weakness related to Procurement and Suspension and Debarment Information on the federal program: Federal Agency: Department of Health and Human Services, Department of Homeland Security, Department of Defense, Department of Justice, National Science Foundation, Department of Agriculture, US Agency for International Development Program Name: Research and Development Cluster Assistance Listing Number: Various Planned corrective action: The Medical Center has updated the reporting logic of the vendor report submitted to the third-party service provider for suspension and debarment evaluation. The Medical Center has also implemented an internal control where a member of Research Finance management will review the vendor report for accuracy and completeness and sign-off prior to submitting to the third-party service provider for suspension and debarment evaluation. Name of responsible official: Michael Brennan Director, Research Finance Michael.Brennan@childrens.harvard.edu Anticipated completion date: May 11, 2026
Finding: 2025-002 Condition Found: The Organization did not have adequately designed internal controls to ensure compliance with Federal suspension and debarment requirements. Specifically, the Organization did not perform SAM.gov exclusion screenings for all contractors. SAM.gov checks were perform...
Finding: 2025-002 Condition Found: The Organization did not have adequately designed internal controls to ensure compliance with Federal suspension and debarment requirements. Specifically, the Organization did not perform SAM.gov exclusion screenings for all contractors. SAM.gov checks were performed only for employees, rather than being performed for all applicable vendors whose yearly expenditures charged to the grant met or exceeded $25,000. As a result, the Organization’s exclusion screening process was not consistently applied to all vendors who met the expenditure threshold. Individual(s) Responsible for Corrective Action: Andrew Barter, CEO Planned Corrective Action: On May 7, 2026, Little Rivers Health Care completed a comprehensive review of all vendors to identify those meeting the federal suspension and debarment screening threshold, with no results. This review identified no excluded or debarred vendors and included all vendors associated with business conducted during 2025. In addition, searches conducted for periods prior to 2025, which included vendors utilized during 2025, did not identify any excluded parties. While the Organization inadvertently failed to perform the required vendor screenings during 2025, the retrospective review, together with the 2026 screening process, demonstrated that none of the applicable vendors were suspended, debarred, or otherwise excluded from participation in federal programs during the period under review. Recognizing the oversight in 2025 and to ensure ongoing compliance, the Organization established a formal vendor exclusion monitoring process consisting of a four-member review team. While the review process itself is relatively straightforward, the team was intentionally designed with redundancy to ensure continuity during periods of staff absence, turnover, or organizational transition. This approach provides multiple levels of oversight and helps ensure that the control remains effective over time. The review team will conduct SAM.gov exclusion screenings and validation reviews twice annually, during May and November of each year, for all vendors meeting applicable federal requirements. Meetings have been scheduled indefinitely with no planned end date. The next scheduled review dates are November 10, 2026, May 11, 2027, and November 9, 2027. Documentation of completed reviews and any required follow-up actions will be maintained as part of the Organization's compliance records. Anticipated Completion Date: May 7, 2026 (Corrective action completed). Ongoing semiannual SAM.gov exclusion screening reviews will continue indefinitely each May and November.
Condition Found: The Organization did not have adequately designed internal controls to ensure compliance with Federal suspension and debarment requirements. Specifically, the Organization did not perform SAM.gov exclusion screenings for all employees and contractors. SAM.gov checks were performed o...
Condition Found: The Organization did not have adequately designed internal controls to ensure compliance with Federal suspension and debarment requirements. Specifically, the Organization did not perform SAM.gov exclusion screenings for all employees and contractors. SAM.gov checks were performed only for certain clinical providers and were aligned with the Organization’s credentialing cycle (approximately every two years), rather than being performed for all applicable individuals upon hire and/or on a recurring basis. As a result, the Organization’s exclusion screening process was not consistently applied to all individuals whose compensation is charged, in whole or in part, to Federal awards. Individual(s) Responsible for Corrective Action: Heidi Melbostad, Chief Executive Officer and Compliance Officer (process design and oversight). Nancy Kusner, Human Resources Director (screening execution and documentation). Planned Corrective Action: This finding has been remediated. The Organization has implemented exclusion screening covering all employees, contractors, and Board members whose compensation may be charged, in whole or in part, to Federal awards. Screening is performed against both the SAM.gov Exclusions List and the Office of Inspector General List of Excluded Individuals and Entities (LEIE) at the time of hire or engagement and on a recurring monthly basis. The Organization built this control in phases, conducting screening runs on 2026-04-22 and 2026-05-09 as it expanded coverage and refined the process, and completing its first comprehensive entity-wide screening, covering all current staff and Board members and including review of known names and aliases against the current roster, on 2026-06-01, with all individuals returning clear results. The Organization retains documented evidence of each screening, including the roster comparison and alias check, to support compliance with 2 CFR 200.214. Management is finalizing a written protocol documenting these steps to ensure the control is sustained. Anticipated Completion Date: Control built in phases over April and May 2026 (screening runs 2026-04-22 and 2026-05-09); first comprehensive entity-wide screening completed 2026-06-01, all results clear. SAM.gov and LEIE screening of all staff, contractors, and Board members continues on a recurring monthly basis. Written protocol documenting the control to be finalized by 2026-06-30.
Federal Single Audit Finding: 2025-001 Procurement, Suspension and Debarment – Significant Deficiency in Internal Control over Compliance Name and Contact Person: Janelle Friday, Tribal Administrator Corrective Action: Klawock Cooperative Association will create additional forms for both suspension ...
Federal Single Audit Finding: 2025-001 Procurement, Suspension and Debarment – Significant Deficiency in Internal Control over Compliance Name and Contact Person: Janelle Friday, Tribal Administrator Corrective Action: Klawock Cooperative Association will create additional forms for both suspension and debarment checks and sole source transactions to ensure proper approval prior to purchasing from vendors whose expenditures would exceed the micro-purchase threshold. Proposed Completion Date: June 30, 2026
2025-002 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – 21.027 Recommendation: We recommend the Town enhance procedures and controls to ensure that the verification of vendors’ suspension and debarment status is obtained prior to executing transactions. Explanation of disagreement with ...
2025-002 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – 21.027 Recommendation: We recommend the Town enhance procedures and controls to ensure that the verification of vendors’ suspension and debarment status is obtained prior to executing transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Following the finding that the town did not perform a suspension/debarment status check when awarding vehicle contract to Gervais Ford, internal procedures were strengthened to require this check for procurements involving federal funds. Name(s) of the contact person(s) responsible for corrective action: Al Rego, Town of Bedford Finance Director and Dave Manugian Director of Public Works. Planned completion date for corrective action plan: Corrective action was implemented immediately.
FINDING 2025-003 Mr. Tim Johnson - President Elected 1/2/2025-12/31/2028 Mrs. Becky Comoglio - V. President Elected 1/2/2025-12/31/2028 Mr. Ryan Zeck - Secretary Elected 1/2/2023-12/31/2026 Mrs. Kristi Hull - Member Elected 1/2/2023-12/31/2026 Mr. Rick Lee - Member Elected l/2/2025-12/31/2028 Findin...
FINDING 2025-003 Mr. Tim Johnson - President Elected 1/2/2025-12/31/2028 Mrs. Becky Comoglio - V. President Elected 1/2/2025-12/31/2028 Mr. Ryan Zeck - Secretary Elected 1/2/2023-12/31/2026 Mrs. Kristi Hull - Member Elected 1/2/2023-12/31/2026 Mr. Rick Lee - Member Elected l/2/2025-12/31/2028 Finding Subject: Special Education Cluster - Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Jackquan Gray, Business Manager Contact Phone Number and Email Address: 574-626-2525 grayj@lewiscass.net Views of Responsible Officials: We Concur with the Finding. Description of Corrective Action Plan: o Create a clear procedure for all small purchases as it relates to procurement. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. o Implement a policy requiring verification of all vendors/contractors for "covered transactions" prior to entering into the contract or issuing payment. A "covered transaction" includes contracts for goods and services expected to equal or exceed $25,000. o The standard procedure should be to check the System for Award Management (SAM} exclusions (www.sam.gov) for all vendors involved in covered transactions funded with federal awards. o Establish proper segregation of duties within the procurement and payment processes to ensure no single person controls an entire transaction. Implement a review process to check for compliance with the new procedures before a purchase order is issued or a payment is made. Anticipated Completion Date: This new policy will take place immediately and the process will be followed when there is a need to check vendors in such circumstances.
Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of...
Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of federal funds. Since then, the School Board has since reviewed both policies and has revised threshold amounts and other language per the advice of legal counsel and MSMA. Now adopted, the policies have been shared with administration to ensure that purchasing procedures are followed and will be reviewed regularly. If there is any chance of federal funds being used for a purchase, the Department will follow the federal procurement requirements. Municipal staff attempted to follow Treasury guidance to administer the State and Local Fiscal Recover Fund (SLFRF) grant and interpreted the “Revenue Replacement” category of expenditure to be exempt from nearly all of the usual federal grant requirements, including the Suspension and Debarment verification step. More recently, the interpretation of the rule changed, but not before certain projects had been initiated, in which the verification step had been missed. Going forward, this will not be an issue as all SLFRF monies have been expended.
2025-001 – Procurement/Suspension & Debarment Federal Program Information: Department of Education – Child Nutrition Cluster: CFDA – 10.553/10.555/10.556/10.559/10.579/10.582 Criteria: The following CFR(s) apply to this finding: 2 CFR 200.318 General procurement Standards and 2 CFR 200.214 Suspe...
2025-001 – Procurement/Suspension & Debarment Federal Program Information: Department of Education – Child Nutrition Cluster: CFDA – 10.553/10.555/10.556/10.559/10.579/10.582 Criteria: The following CFR(s) apply to this finding: 2 CFR 200.318 General procurement Standards and 2 CFR 200.214 Suspension and Debarment Condition: During audit procedures, it was identified that the Supervisory Union did not have internal controls in place to ensure that all appropriate procurement standards and procedures were followed. Cause: Unknown Effect: The Supervisory Union may not be consistently following all appropriate procurement standards and procedures. There were instances where the suspension and debarment verification were not performed. Identification of Questioned Costs: None identified. Context: Of the 8 procurement purchases tested, 6 were not verified for suspension or debarment in SAM.gov. Repeat Finding: This is a repeat finding. Recommendation: It is recommended that the Supervisory Union implements controls to ensure that it follows all appropriate procurement standards and procedures. We also recommend that the Supervisory Union review its procurement policy to ensure that it is updated and complete. Management Response: Management agrees with the recommendation and will implement controls to ensure we follow all appropriate procurement standards and procedures. In addition we also will review our procurement policy and ensure it is updated and complete. Anticipated completion date 7/1/2026
Management’s Response/Corrective Action Plan: The Town was unaware of the suspension and debarment requirements under Uniform Guidance §200.214. Upon notification of this finding, the Town has implemented corrective measures to ensure compliance. Effective immediately, the Town will verify all vendo...
Management’s Response/Corrective Action Plan: The Town was unaware of the suspension and debarment requirements under Uniform Guidance §200.214. Upon notification of this finding, the Town has implemented corrective measures to ensure compliance. Effective immediately, the Town will verify all vendors before contract execution by searching SAM.gov to confirm they are not suspended or debarred. Additionally, the Town will require vendors to provide written certification of their suspension and debarment status. Documentation of both the SAM.gov verification and vendor certification will remain with the applicable grant records. These procedures will be incorporated into the Town’s standard procurement practices and will apply to all federally funded projects, including a $1.1 million Congressionally Directed Spending (CDS) award for which the Town awaits receipt.
2025-001: Lack of Documentation of Suspension/Debarment Testing at Time of Procurement Federal Department: Department of Housing and Urban Development Assistance Listing #: 14.251 Internal Controls Significant Deficiency & Noncompliance Category of Finding – Procurement, Suspension, and Debarment Na...
2025-001: Lack of Documentation of Suspension/Debarment Testing at Time of Procurement Federal Department: Department of Housing and Urban Development Assistance Listing #: 14.251 Internal Controls Significant Deficiency & Noncompliance Category of Finding – Procurement, Suspension, and Debarment Name of contact person: Zach Petroski, Director of Finance Corrective Action: Clare Housing will complete the following corrective action steps, which are consistent with the organization’s financial policies: • Clare Housing will continue to conduct verifications to ensure the organization is not entering into transactions with parties that are temporarily suspended or permanently debarred from doing business with the federal government. Clare Housing will do so by validating the potential vendors’ status in the System for Award Management (www.SAM.gov) portal and document the verification with a screenshot of the validation before any payment to a vendor is completed. These verifications will be completed by appropriate procurement/finance personnel and supervised by the Director of Finance. • Clare Housing will establish a centralized electronic filing system that houses the documentation for suspension/debarment verification. • Clare Housing will track and report any findings to management, including corrective actions for any recurring deficiencies. Completion Date: January 1, 2026
The Town of Lynnfield, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024 – June 30, 2025 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the...
The Town of Lynnfield, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024 – June 30, 2025 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—FEDERAL AWARD PROGRAMS AUDIT 2025-001 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – 21.027 Recommendation: We recommend procedures be implemented to ensure that the verification of vendors’ suspension and debarment status is documented prior to executing transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town has implemented procedures requiring documentation of vendor suspension and debarment verification prior to the execution of transactions involving federal funds. Staff responsible for procurement and accounts payable have been instructed to verify vendor eligibility through the System for Award Management (SAM.gov) and retain documentation of the verification in the applicable procurement or payment file. Name(s) of the contact person(s) responsible for corrective action: David Castellarin Planned completion date for corrective action plan: June 30, 2026
Reference Number: 2025-001 Description: Procurement Corrective Action Plan: Guest House has modified its staffing structure, training, and procurement protocols to ensure that all contractors, including local landlords receiving payments under federal grant programs, are verified against the federal...
Reference Number: 2025-001 Description: Procurement Corrective Action Plan: Guest House has modified its staffing structure, training, and procurement protocols to ensure that all contractors, including local landlords receiving payments under federal grant programs, are verified against the federal System for Award Management (SAM.gov) prior to contract execution. Anticipated Corrective Action Plan Completion Date: April 1, 2026 Contact Information: For additional information regarding these corrective actions, contact Stephen Bauer, CEO at 414.345.3240. Stephen Bauer CEO Guest House of Milwaukee
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