Corrective Action Plans

2023-002 Material Weakness in Internal Controls – Procurement, Suspension and Debarment Funding Agency: Department of Education Program: Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Direct Spending for Elementary and Secondary Education Community Projects Assistance Listing Number: 84.215K Condition: None of the five samples selected for testing had appropriate suspension and debarment checks prior to entering into the subawards. Criteria or Specific Requirement: Criteria or specific requirement: 2 CFR 200.318(i) states that "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. Effect: The Organization was unaware of the requirement to perform suspension and debarment checks on subrecipients. Without proper controls the Organization could enter award subrecipients with entities that are suspended or debarred. Cause: The Organization was unaware of the requirement to perform suspension and debarment checks on subrecipients. Without proper controls the Organization could enter award subrecipients with entities that are suspended or debarred. Recommendation: The Organization should implement policies and procedures for performing suspension and debarment checks for all covered transactions, including subrecipients. Questioned Costs: None View of Responsible Official and Corrective Action Management accepts the finding and is taking the following corrective action to prevent recurrence: • Procurement training planned throughout the agency to ensure that personnel authorized to initiate procurement transactions are aware of organizational policies and have the guidance necessary to comply with procurement rules. Anticipated Completion Date: Corrective action is currently being implemented.

Finding 2023-003 Condition: Documentation of the solicitation of quotes for one purchase totaling $16,700 could not be found in Department files. Also, a written determination related to a sole source procurement totaling $15,460 was not in the Department files. Corrective Action Plan: The School District has implemented new policies and procedures surrounding the documentation of procurement to better ensure compliance with federal procurement requirements. Anticipated Completion Date: 5/31/2024 Contact Information: Keith Buday, Assistant Superintendent – Finance & Operations

Finding 2023-002 Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Corrective Action Plan: The School Lunch Department has implemented new policies and procedures surrounding documentation of procurement, including the adoption of new standardized procurement forms based on templates provided by the state, to ensure compliance with federal procurement requirements. Anticipated Completion Date: 5/31/2024 Contact Information: Keith Buday, Assistant Superintendent – Finance & Operations

The Town of Swansea immediately took corrective action by establishing a Town wide policy which requires the procurement of certain documents. The implementation has already taken place on all projects concerning ARPA funds.

Hood River County has developed procedures to ensure the suspended and debarred listing is checked prior to awarding contracts to outside parties. In addition, the County is maintaining documentation of a second check being performed before the vendor can be entered into the payment system. We expect this to be running without exception by 12/31/2024.

Views of Responsible Officials: IW will initiate a thorough review and revision of our procurement policy to ensure full compliance with the Uniform Guidance. This revision process includes adding documentation of the procurement process. In addition, it will address how we incorporate specific procedures for conducting and documenting checks against the System for Award Management (SAM) to verify the status of vendors prior to engaging in covered transactions. We will implement a standardized documentation process to maintain evidence of SAM checks within our vendor files. This includes a detailed log of each check performed, the date, the name of the entity checked, and the outcome. These records will be retained as part of our procurement files for audit and review purposes.

NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30 2023 Name of contact person: Kristen Galbraith, GPC Corrective Action: The Grants Department will develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Proposed Completion Date: Immediately

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; GRANT No. Direct and AM-23-0287 Name of contact person: Kelly Strecker Corrective Action: The City commits to ensuring that a procurement policy be put in place that will allow it to comply with procurement standards outlined in the Uniform Guidance. Proposed Completion Date: December 1, 2024

CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, PROCUREMENT AND SUSPENSION AND DEBARMENT Name of contact person: County Commissioners Corrective Action: Roosevelt County will follow the procedure of verifying contractors through SAM or GSA Websites when using SLFRF funds. Proposed Completion Date: Immediately.

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Corrective Action Planned: The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented. Anticipated Completion Date: Ongoing Responsible Party: Phil Hardenburger, Saline County Board of Commissioners, Chairperson

2023-003 Child Nutrition Cluster – Assistance Listing No. 10.553 and 10.555 Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of potential contractors to determine they are not suspended or debarred is retained for all applicable vendor relationships. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will review vendor suspension and debarment evaluation policies and purchasing policies and implement polices and controls to ensure that District policies and controls comply with Uniform Guidance requirements. Name(s) of the contact person(s) responsible for corrective action: Brenda Arnett Planned completion date for corrective action plan: June 30, 2024

Finding 2023-001-Procurement, Suspension and Debarment Finding: The Foundation does not have a formal procurement policy under requirements of 2 CFR 200.317 through 200.327. The Foundation established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. We noted as part of our testing that there was no documentation that these policies and procedures were being followed. Corrective Actions Taken or Planned: The Foundation is in the process of developing a formal procurement policy to conform to 2 CFR 200.317 through 200.327. Further, the National Association of Social Workers, the supported affiliate of the Foundation has posted a position to hire a senior grants accountant who will be assisting in the development and implementation of policies and procedures around grants. The position will be reporting to the Accounting Manager and ultimately the Chief Financial Officer. Sekou Murphy, Chief Financial Officer, will be responsible for the corrective action plan that is anticipated to be completed by October 2024.

COVID 19 - Demonstration Programs to Improve Community Mental Health Services 93.829 Recommendation: We recommend internal controls over suspension and debarment be implemented. This could include following checklist which includes procedures for verification of whether a vendor is suspended or debarred and having that checklist be required to be reviewed by the program manager prior to entry into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A process of more comprehensive review of program requirements will be put in place. Name of the contact person responsible for corrective action: Lisa Katz, Chief Program Officer Planned completion date for corrective action plan: Currently underway and planned to be completed by June 30, 2024.

Finding No. 2023‐007 – Suspension and Debarment (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.634 Program Title: State Wildlife Grants (R&D Cluster) Condition The auditing firm tested a non‐statistical sample of two subawards and found no evidence indicating that program personnel verified whether any of the contractors were federally suspended or debarred. Current Status of Corrective Action Plan Concur. DLNR DOFAW has implemented procedures to ensure that a SAM.gov verification is performed for all subrecipients, and that documentation is printed out from SAM.gov and retained with the subrecipient file folder. Person Responsible Cynthia C. Gomez, Fiscal Management Officer David Smith, DOFAW Administrator Anticipated Date of Completion Completed.

Finding No. 2023‐005 – Suspension and Debarment (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.615 Program Title: Cooperative Endangered Species Conservation Fund Condition The auditing firm tested a non‐statistical sample of two subawards and found no evidence indicating that program personnel verified whether any of the contractors were federally suspended or debarred. Current Status of Corrective Action Plan Concur. DLNR Division of Forestry and Wildlife (DLNR DOFAW) has implemented procedures to ensure that a SAM.gov verification is performed for all subrecipients, and that documentation is printed out from SAM.gov and retained with the subrecipient file folder. Person Responsible Cynthia C. Gomez, Fiscal Management Officer David Smith, DOFAW Administrator Anticipated Date of Completion Completed.

DEPARTMENT OF TREASURY 2023-003 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend management ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to issuance of the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will ensure all new vendors will sign a suspension and debarment agreement prior to any payments being made. Name(s) of the contact person(s) responsible for corrective action: Kelly Baldwin, Director of Finance Planned completion date for corrective action plan: March 31, 2024 If the Cognizant or Oversight Agency has questions regarding this plan, please call Kelly Baldwin, Director of Finance at 410-239-3200.

Reference Number: 2023-001 Prior year Finding: No Federal Agency: U.S. Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency in Internal control, Noncompliance Recommendation: The Town should review and enhance controls and procedures to ensure that it follows the applicable procurement policy and Federal suspension and debarment regulations for all goods and services charged to the program. Explanation: There is no disagreement with the audit finding. Action taken in response to finding: The Town of Camden, Delaware will review the State’s procurement process to satisfy the compliance requirements for the program. The Town of Camden, Delaware will also put procedures in place to check and review each bidder as part of the Federal suspension and debarment policies. Name(s) of the contact person(s) responsible for corrective action: Harold Scott Jr., Town Manager Malori Lewis, Account Specialist Planned completion date for corrective action plan: Procurement training and monitoring, ongoing Suspension and debarment training and monitoring, ongoing

2023-001 Special Education Cluster – Assistance Listing Numbers 84.027, 84.173 Recommendation: We recommend procedures be strengthened 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 and agrees that the vendors were not suspended or disbarred. Action taken in response to finding: The School Department has implemented procedures to document the verifications with either contract certifications and/or screenshots of SAM.gov searches. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: Completed.

Views of Responsible Officials: AHCMC acknowledges that it does not have a formal and open procurement policy that requires full and open competition for purchases of goods and services. AHCMC will implement a procurement policy that conforms to the Uniform Guidance. AHCMC will also maintain documentation to support that the procurement policy is adhered to. AHCMC will also develop internal controls to maintain documentation that required suspension and disbarment searches were performed on the SAM website.

Views of Responsible Officials and Planned Corrective Action: ASBO has made the registration at Sam.gov part of the application process that will be handled through the subgrant portal being developed with our new grants monitoring contractor. This will now be an electronic field that will be entered by the subgrantee. The 3rd party administrator will be responsible for verifying the subgrant applicant Sam.gov registration is valid and active. Anticipated Completion Date: System anticipated go live Date: April 26, 2024 Contact Person: Name: Glen Howie Title: Director Agency: Department of Commerce, Arkansas State Broadband Office Address: 1 Commerce Way, Suite 601 City, State, Zip: Little Rock, AR 72202 Phone Number: 501-682-1123 Email Address: Glen.howie@arkansasEDC.com

Views of Responsible Officials and Planned Corrective Action: Department of Human Services Response DHS concurs with the finding. The SNP database has been updated to reflect that a National Disqualified List (NDL) search was run on the 15 providers that were reviewed. The Health and Nutrition Unit for the Office of Early Childhood conducted a staff training on the written application procedure with an emphasis on performing and documenting NDL searches prior to approval of the application. (Note: Effective August 1, 2023, DHS DCCECE has transitioned to Arkansas Department of Education.) Arkansas Department of Education Response Arkansas Department of Education’s Office of Early Childhood, Health and Nutrition unit conducted training December 2023 and continues to maintain staff training on the written application procedure to ensure providers are reviewed against the National Disqualified List (NDL) database and prior to approval. Anticipated Completion Date: Department of Human Services Response Complete Arkansas Department of Education Response Continuous Contact Person: Name: Pamela Burton Title: Director, Health and Nutrition Unit, Division of Elementary and Secondary Education Agency: Arkansas Department of Education Address: 700 Main Street, Room 1216 City, State, Zip: Little Rock, AR, 72203 Phone Number: 501-320-8978 Email Address: Pamela.Burton@ade.arkansas.gov

DEPARTMENT OF AGRICULTURE 2023-001 Child Nutrition Cluster – Assistance Listing Numbers 10.553, 10.555 Recommendation: We recommend procedures be strengthened to timely 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: Program management has begun the process of strengthening procedures to timelier document the verifications with either contract certifications and/or screenshots of SAM.gov searches. Name(s) of the contact person(s) responsible for corrective action: Program management. Planned completion date for corrective action plan: As soon as possible.

Corrective Action Planned: The County will implement procedures to ensure when a contractor is paid with federal funds, sam.gov will be utilized to verify the entity has not been suspended or debarred and such procedure will be adequately documented. Anticipated Completion Date: Ongoing Responsible Party: Mike Hall, Bryan Mellage, Michael Weiss, Nemaha County Board

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CAPITALIZATION GRANTS FOR DRINKING WATER STATE REVOLVING FUNDS, ASSISTANCE LISTING No. 66.468, GRANT No.’s WRF-23530 AND WRF-23531, YEAR ENDED JUNE 30, 2023

Program: AL 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Corrective Action Planned: The County has implemented a process to ensure when a contractor is paid with federal funds that the vendor will be looked up on sam.gov to verify the entity has not been suspended or debarred, upon which time a printout will be printed and put with the claim that is being paid as well as attaching the verification to the ARPA binder that has a copy of all claims paid with the ARPA funds. Anticipated Completion Date: Completed 3/13/2024. Responsible Party: Butler County Board of Supervisors: Anthony Whitmore, Scott Steager, Tony Krafka, Scot Bauer, Robert Coufal, Jan Sypal, and Ryan Svoboda.