Corrective Action Plans

Procurement, Suspension, and Debarment Auditor Description of Condition and Effect: During our audit procedures over the City’s debarment and suspension procedures, we noted that the City relies on their engineers to verify contractors are not debarred, suspended, or otherwise excluded from Federal assistance programs or activities. The City does not have a process in place to verify the engineers are in fact monitoring the contractors on the project. The City did not follow requirements to check whether a vendor is suspended or debarred. Auditor Recommendation: We recommend that the City verify that any vendors or contractors selected are verified as neither suspended or debarred per the SAM.gov website prior to awarding the bid, and, that the City retain documentation of their verification in the bid file. Corrective Action:We agree with the finding and will develop and implement written procedures required for federal awards.

NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; GRANT No AM-23-0262, YEAR ENDED JUNE 30, 2023 Name of contact person: Fallon County Commission/Clerk and Recorder Corrective Action: Procedures will be developed 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, ASSISTANCE LISTING No. 21.027 AND DISASTER GRANTS-PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS), ASSISTANCE LISTING No. 97.036 Name of Contact Person: Loni Hanson Corrective Action: The City appreciates the clarification regarding the required compliance certifications for all contractors receiving federal funds. The City has worked with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2024

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027 AND DISASTER GRANTS-PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS), ASSISTANCE LISTING No. 97.036 Name of Contact Person: Loni Hanson Corrective Action: The City appreciates the clarification regarding the required compliance certifications for all contractors receiving federal funds. The City has worked with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2024

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2023 ____________________________________________________________________________________________________________________________________ FINDING 2023-005: U.S. DEPARTMENT OF THE TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (ALN 21.027) PASS-THROUGH P.R. FISCAL AGENCY AND FINANCIAL ADVISORY AUTHORITY PROCUREMENT SUSPENSION & DEBARMENT (I) SIGNIFICANT DEFICIENCY AND NONCOMPLIANCE Corrective Action We implemented policies and procedures in accordance with Uniform Guidance 2 CFR 200.214. Statement of Concurrence and Responsible Persons We concur with the auditors' finding. Kristian Rivera Santiago Finance Director Implementation Date Fiscal year 2023-2024.

Criteria: Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing executive orders and 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. Corrective Actions: During the year ended June 30, 2022, documentation of management's determination of whether a vendor was debarred or suspended was maintained for most vendors; however, this documentation was not maintained for all vendors. 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. Corrective Actions FY '24: Beginning July 1, 2023, the Chief Financial Officer will verify if any new vendor has been suspended or debarred prior to the approval of any purchase order requesting their goods and/ or services. No purchase order will be approved if the vendor has been debarred. This review will be done semi-annually to ensure that the status of any vendor has not changed during the year.

2023-019. Suspension and Debarment Not Verified Before Awarding Contracts State Agency: Governor’s Office of Planning and Budget Federal Agency: Department of the Treasury GOPB will review its June 2023 training on requirements for SLFRF agreements and retrain all state entities receiving ARPA funds during April 2024. Part of this training will focus on the requirement to perform timely suspension and debarment checks. GOPB will also reissue the guidance documents requiring suspension and debarment clauses in contract agreements. GOPB will include the reference guide to agencies that contains the standardized language about suspension and debarment checks to use in new agreements. GOPB will collaborate with the Division of Finance to examine FAQ 13.15 and summarize which requirements do and do not apply to revenue replacement projects in order to guide agency compliance activities. GOPB will review processes in place to perform suspension and debarment checks, when required, as part of the ongoing monitoring activities and sample contract agreements to verify inclusion of the appropriate contractual provisions. Contact Person: Darcy Jaimez, Fiscal Grant Manager, 385-377-3373 Anticipated Correction Date: April 30, 2024

2023-002 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. 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. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non- Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: During our testing of the Orange County Public Works (OCPW), Orange County Community Resources (OCCR) and the Social Services Agency’s (SSA) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW, OCCR or SSA departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy: • Four (4) of four (4) contracts through the OCPW department selected for testing. • Three (3) of eight (8) contracts through the OCCR department selected for testing. • One (1) of one (1) contract through the SSA department selected for testing. The following information was not provided at the time of the contract award for four (4) of four (4) contracts selected for testing within the OCPW department, one (1) of one (1) contract selected within SSA, and five (5) of eight (8) contracts selected for testing within the OCCR department: • Byrd Anti-Lobbying Amendment • Clean Air Act and Federal Pollution Control Act provision The following information was not provided at the time of the contract award for two (2) of four (4) contracts selected for testing within the OCPW department and one (1) of one (1) contract selected for testing within SSA: • Contract Work Hours and Safety Standards Act provision The following information was not provided at the time of the contract award for one (1) of one contract selected for testing within SSA: • Davis-Bacon Act provision • Equal Employment Opportunity provision Cause: The OCPW, OCCR and SSA departments did not follow their policy to verify the information described in the condition prior to entering the transactions and did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The County’s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. EB reviewed the vendor’s status on SAM.gov and verified the vendors selected for testing were not suspended and debarred at the date of the audit. Additionally, the OCPW, SSA and OCCR departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of four (4) out of twelve (12) procurement contracts were sampled from OCPW and eight (8) out of nineteen (19) procurement contracts were sampled from OCCR for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The entire population of 1 (contract) was tested from SSA for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. Repeat Finding from Prior Years: Yes, Finding 2022-003 and 2022-009. Recommendation: We recommend that the OCPW, OCCR and SSA departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Additionally, we recommend the OCPW, SSA and OCCR departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Management Response and Corrective Action: Orange County Community Resources: 1. Person Responsible: Isela Martinez, OCCR Procurement Manager 2. Corrective Action Plan: The contracts in question were originally funded by the County General Fund. OCCR Procurement team was not aware that the funding source changed to Coronavirus funds during the contract period. OCCR will update internal procedures to ensure procurement is notified when the contract funding source changes to federal funding, triggering the additional federal provisions mentioned above. 3. Anticipated Implementation Date: September 30, 2024 Orange County Public Works: 1. Person Responsible: Joseph Sly, OCPW Procurement Manager 2. Corrective Action Plan: The contracts in question were originally funded by the County. OCPW Procurement was not aware that the funding source changed during the contract period. OCPW will update internal procedures to ensure funding agency provisions are met. 3. Anticipated Implementation Date: September 30, 2024 Social Services Agency: 1. Person Responsible: Alin Buna, SSA Procurement Manager 2. Corrective Action Plan: SSA Procurement did not execute the specified contracts. When executing the specified contracts, OCPW, on behalf of SSA, was not aware of federal funding being included. SSA will ensure that agencies executing contracts on behalf of SSA will be notified if federal funding is included for specific projects to ensure proper procedures have been followed when the contracts have been executed. 3. Anticipated Implementation Date: September 30, 2024

Personnel to Effect Change: Finance Director (Steve Baugher), Capital Projects & Grant Accountant (Linda Wertman), Grants Manager (Catherine Rigby), and City Engineer (Interim Chris Beatty) City Response and Corrective Action Plan: Fiscal year 2022-23 was a challenging year for the City of Newport due to staff turnover and vacancies for key positions in Engineering, Public Works and Finance. Processes were in place to ensure that vendors were not on the suspended or debarred list prior to awarding contracts. However, due to key staff turnover, the documentation was not available to verify that the process was followed, The Finance Department, Engineering, and Grant Manager will work on a checklist to make sure all required written documentation is obtained. The written documentation will be centrally kept by the Capital Projects and Grant Accountant with the awarded contract before executing the contract. The checklist will include that the suspended and debarred list is checked to make sure the awardee is not on the list and retain documentation of the list being checked. Anticipated Completion Date(s): March 31, 2024

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update, as necessary, its current procurement policies and procedures to ensure compliance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements. In specific, this procedure will ensure that the terms and conditions required by Subpart D are included as part of all future contracts involving the use of federal assistance. This procedure will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

MANAGEMENT’S CORRECTIVE ACTION PLAN: Effective immediately, management will implement the practice of properly vetting future third-party contractors for debarment and suspension in federal assistance programs by utilizing the SAM.gov website, to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance and Executive Orders 12549 and 12689, 2 CFR part 180.

Views of responsible officials: Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MWCOG will ensure that all vendors’ suspension and debarment status be documented in the procurement files at the time of contract with the vendors. Name(s) of the contact person(s) responsible for corrective action: Rick Konrad, Facilities and Purchasing Manager Planned completion date for corrective action plan: December 1, 2023

The County Attorney is writing up a policy.

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Corrective Action Planned: A procedure implemented to print the page of Sam.gov website. Anticipated Completion Date: Immediate Responsible Party: Jim Mejstrik, Colfax County Board Chairman

The Chief Financial Officer or Senior Accountant staff of Our World Neighborhood Charter Schools (OWNCS) will adhere and comply with 2 CFR 200 Appendix XI, Part 3-I-2. Effective October 31, 2023, OWNCS will retain all supporting documentation that verifies that an entity defined in 2 CFR Section 180.995, is not suspended, debarred, or otherwise excluded from participating in the transactions after the research is performed.

Annually

2023-001 Procurement Corrective action: Competitive quotes should be obtained and retained as specified in the procurement policy. Non-competitive procurement should be documented and approved prior to incurring expenses. Vendor debarment checks should be performed and documented prior to entering into covered transactions. Management Response: The audit uncovered a non-compliance with required competitive quotes for a procurement of meeting services which did not comply with CASIS policy. The predecessor management team had previously advised the responsible purchaser that these services did not require competitive quotes. This matter is also complicated by the fact that the procurements are not just for meeting space, logistics and meals, but also includes lodging, which is not subject to the three quote rule. Management acknowledges that this was a process escapement and provides for the following corrective action. Typically lodging expenses are included in the procurement because it results in discounts that are unavailable if not included. CASIS implemented a policy of requiring competitive quotes for purchases over $1,000 in the most recent revision of the procurement policy. This change was made to assure compliance with Federal Regulations. While the amount noted is within the limits established by Federal Micro-purchase regulations, it did not comply with internal policies as noted. Meeting space is a commonly used service that is highly competitive in pricing and most facilities charge competitive rates, but most of the time those quotes are not useable given the time of year, and more importantly the occupancy rate of the facility. Starting in 2024, we are requesting quotes from three facilities in the local area that will be valid for a period of one year. These rates will be updated manually and a single additional quote will be obtained to assure the “reasonableness” of the price. This process will represent an annual price survey that will satisfy the three quote rule of our procurement policy. For rental of facilities outside of the local area, we will obtain a minimum of three quotes as required by our procurement policy. Management also acknowledges the process escapement for SAM checks on new vendors. Our normal process is that annually, Finance performs a SAM check for all approved vendors. The agreement for Trust Factory came in late during the year resulting in this deficiency. When a new vendor is setup in our system, it will automatically trigger a SAM check. Responsible Party: Jonathan Bobbitt, CPA, Finance Manager Date Expected to be Corrected: September 30, 2024

The County plans to check the SAM (System for Award Management formerly Excluded Parties Listing System (EPLS), which is maintained by the General Services Administration before any funds are disbursed to vendors/entities.

Recommendation: We recommend the District include contract language which ensures vendors are not suspended or debarred as well as utilize sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Procedures will be updated to include verification that a vendor has not been suspended or debarred. A record of this verification will be retained.

The County has put adopted new procedures within the Accounts Payable County Procedures Manual to actively verify vendors for eligibility utilizing the SAM exclusion database system. Procedure will include a printed copy of the search that will be signed and dated by the employee conducting the search. Document will be attached to the vendor file and the transaction that initiated the search.

U.S. Department of Education 2023-002 IDEA Procurement, Suspension and Debarment Assistance Listing Nos. 84.027 and 84.173 Recommendation: CLA recommends that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure the proper procurement method was followed and procurement history is documented. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented and communicated a process where all contracts and orders that exceed $25,000 require a Purchas Order to be created. The creation of the Purchase Order then alerts the Director of Procurement to perform the suspension and debarment checks. This will be done for all agreements exceeding $25,000, including repeat contracts. Name(s) of the contact person(s) responsible for corrective action: Jake Alverson, Director of Procurement Planned completion date for corrective action plan: 12/15/2023 If the U.S. Department of Education and Wisconsin Department of Public Instruction has questions regarding this plan, please call Sara Noah at (920)448-2200.

Child Nutrition Cluster - Assistance Listing nos. 10.553 and 10.555 Recommendation: CLA recommends the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transaction have vendors reviewed for suspension and debarment status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All food service vendors will be checked for suspension and debarment on the Sam.gov website. Name(s) of the contact person(s) responsible for corrective action: Morgan Mueller, Bookkeeper Planned completion date for corrective action plan: July 1st 2023

Procedures will be updated to include verification that a vendor has not been suspended or debarred. A record of this verification will be retained.

Finding 2023-002 Finding Summary: Suspension and Debarment Verification Procedures were not performed prior to entering into covered transactions. Responsible Individual: Robert Bryce Shields, District Attorney Corrective Action Plan: Pershing County District Attorney’s Office will enhance Internal Controls to ensure all contracts under Federal Awards contain the applicable provisions related to Suspension and Debarment or other procedures are performed to verify that the party is not suspended or debarred. Anticipated Date of Correction Action Plan: Corrected November 14, 2023

Finding Number: 2023-001 Condition: The City had no control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Planned Corrective Action: City Manager office staff has searched the State Procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future as part of Federal Grant Funding implementation staff will check vendors to make sure they are not debarred or suspended from federal funding awards. Contact person responsible for corrective action: Melissa Marsh, City Manager Anticipated Completion Date: 10/10/2023