Corrective Action Plans

FINDING 2022-005 Finding Subject: Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) – Suspension and Debarment Summary of Finding: The County stated procedures were not in place to ensure vendors were not suspended or debarred prior to entering into covered transactions. One covered transaction for funds passed through to a subrecipient was identified during the audit period. The amount passed through to the subrecipient was $914,863. The identified transaction was examined to determine if the County verified the suspension and debarment status of the subrecipient prior to payment. Upon review we determined that the County entered into a Memorandum of Understanding (MOU) with the subrecipient on June 22, 2020. However, the County had not performed procedures to ensure the subrecipient was not suspended or debarred, or otherwise excluded or disqualified from participation in federal assistance programs or activities at the time of the initial MOU or at any time during the audit period. Recommendation We recommended that management of the County establish a proper system of internal controls and develop policies and procedures to ensure contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. We also recommended that supporting documentation be retained in order to be presented for audit. Contact Person Responsible for Corrective Action: Concetta Sanfilippo Contact Phone Number and Email Address: 574.523.2101 csanfilippo@elkhartcounty.com Views of Responsible Officials: We concur that suspension and debarment was not run within the audit period. However, it was not done under the direction of CLA Auditing team 2021 who instructed it was not necessary, rather the most current audit report should be run which Elkhart County did do and had on file for their subrecipient Oaklawn Psychiatric. Description of Corrective Action Plan: The Elkhart County Health Department and Auditor’s Office Grants Administrator are working collaboratively to administer this grant award with strong internal controls. The Grant’s Administrator has taken the role to routinely run Suspension and Debarment verification on this subrecipient. The date it is run is recorded and a pdf is retained for records. Anticipated Completion Date: This procedure is in place as of 2023 and correction is completed.

View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing procurement policies and procedures found in Section III Policy #301 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff and which requires these vendors to be reviewed on the SAM website to ensure they have not been suspended or debarred. While after the fact, each of the five vendors noted in this finding have since been reviewed on the SAM website and none of them returned any notices of having been suspended or debarred. Management is in the process of going back and reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement as well as for those it is anticipated will meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.

FINDING 2022-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: Material Weakness, Modified Opinion. Three contracts out of seven did not include the suspension and debarment requirements. The County has already executed addendums with the contractors to correct this issue. Contact Person Responsible for Corrective Action: Adam Gadberry Contact Phone Number and Email Address: 317.346.4392 agadberry@co.johnson.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The County has already added the suspension and debarment language to the County’s standard contracts for SLRF projects. County has also added checking for suspension and debarment to the County’s contract checklist. Anticipated Completion Date: December 31, 2023

Finding 2022-006: Procurement, Suspension, and Debarment – Material Weakness. The buying policy ordering process has been updated to include blocking GSA (Government Services Administration) & HHS (Health & Human Services) disbarred sellers in accordance with SAM (System of Award Management) system. The overall Procurement policy, contracts and forms will be updated to include suspension and debarment language.

Audit Finding Reference: 2022-003 Management's View: The town agrees that we had not properly prepared formal policies to ensure that the suspension and debarment testing would be carried out and documented prior to entering into a covered transaction with an entity. Planned Corrective Action: The Town will develop and implement policies and procedures to formally verify and document the suspension and debarment process for all entities that we enter into transactions with when using Federal funds. Name of Contact Person and Completion Date: Danielle Basora Assistant Town Administrator/Finance Director/Treasurer 603-497-8990 ext. 104 Danielle.Basora@GoffstownNH.gov Derek Horne Town Administrator/Deputy Treasurer 603-497-8990 ext. 101 Derek.Horne@GoffstownNH.gov Anticipated Completion Date: April 30, 2024

Finding 2022-01 Federal Program Title: Education Stabilization Fund ?Higher Education Emergency Relief Fund Compliance Requirement: Procurement, Suspension and Debarment Name of Contact Person: Lynn Feeken, Financial Controller Corrective Action: The College developed and implemented a procurement policy which addressed Uniform Guidance Procurement, Suspension and Debarment requirements. Date of Completion: January 5, 2023

The Town of Mashpee, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 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 AUDITS DEPARTMENT OF AGRICULTURE 2022-001 Child Nutrition Cluster ? Assistance Listing Numbers 10.553 and 10.555 Recommendation: We recommend to annually (at a minimum) 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: Mashpee Public Schools will document the verification that all the vendors are not suspended or debarred from participation in the Federal assistance programs or activities. At a minimum the verification will happen once per fiscal year by the Director of Food Service or their representative. Name(s) of the contact person(s) responsible for corrective action: Catherine Kingsbury - Food Service Director (start date 9/21/23) and/or Kristen Hurlburt - Assistant Food Service Director (start date 9/21/23) and/or Ashley Lopes ? Director of Finance Planned completion date for corrective action plan: December 31, 2023

Virgina Department of Education City of Alexandria, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: Fiscal Year 22, (July 1, 2021-June 30, 2022) The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS 2022-001 Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, 10.559, 10.582 Recommendation: We recommend that ACPS consistently follow their procurement procedures and enhance procedures to ensure that all required procurement documentation is maintained in the vendor?s procurement file. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement has developed operating procedures on the steps to run debarment reports within electronic Virginia (eVA) https://eva.virginia.gov/ The operating procedures have been made available to the procurement team. This report will be included in the file of each awarded offeror. For contracts that contain Federal Funding, Procurement tried to run a report from SAM https://sam.gov however the report did not contain information on the debarment status. All Offerors or Bidders are required to complete the Certification Regarding Debarment or Suspension form as part of their response to posted solicitations. If Offerors or Bidders do not submit a completed form they are deemed nonresponsive. See attached form Name(s) of the contact person(s) responsible for corrective action: Dyanna McMullen and Kimberly Young Planned completion date for corrective action plan: March 28, 2023 If the Virginia Department of Education has questions regarding this plan, please call Dyanna McMullen at 703-472-4034 or Kimberly Young at 703-244-0419

The Town of Chelmsford, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 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 PROGRAM AUDIT DEPARTMENT OF AGRICULTURE 2022-001 Child Nutrition Cluster ? Assistance Listing Numbers 10.553 and 10.555 Recommendation: We recommend to annually (at a minimum) 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 Chelmsford Public Schools is one of the twelve districts that is part of the Metro North Collaborative (MNC). The MNC executes the competitive bid process for several of the school nutrition products. A certificate of good standing was required in the bid process and the MNC has added the recommended language that the participant certify to the best of its knowledge and belief that it and its principals are not presently debarred, suspended, proposed for disbarment, declared ineligible, or voluntarily excluded from the covered transactions by any Federal department or agency. Chelmsford Public Schools will also assist the MNC with documenting the suspension/debarment verifications at the time of the bid process and bid award with screen shots from the SAM.gov website resource. In addition, the Chelmsford Public Schools has verified that list of vendors is not suspended or disbarred, using the SAM.gov website resource. Name(s) of the contact person(s) responsible for corrective action: The Director of School Nutrition of the Chelmsford Public Schools. Planned completion date for corrective action plan: The spring of 2023 (April ? May timeframe) is when the MNC invites interested vendors to submit bids for the school nutrition products and the bid documents will reflect the recommended language. In January and February of 2023, the Chelmsford Public Schools verified the list of vendors is not suspended or disbarred, using the SAM.gov website resource.

2022-003 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 debarement 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: Mel Nettesheim Planned completion date for corrective action plan: June 30, 2023

Finding 2022-001 Grantor: Department of Health and Human Services Federal Program: Various Assistance Listing #: Various Pass-through Grantor Pass-Through Award Number Pass-through Award Period None None None Award Year: Fiscal year 2022 1/1/2022 ? 12/31/2022 Award Number: None Management agrees with the recommendation. Management will implement the following changes to Time and Effort practices. Corrective Action Plan and Anticipate Completion Date Management agrees with the recommendation. ? Review suspension and debarment? Management will review the monthly third-party vendor screening results. Management will retain documentation of the review and supporting documents used in the review. ? Reconciliation ? Management will implement a process to reconcile the number of vendor files sent to the third-party screening vendor with the number screened. Management will memorialize this reconciliation. ? Accuracy ? Management will implement a process to verify the accuracy of the results produced by the third-party vendor. Management will memorialize this review. Responsible Person: Kathleen Dunn, JD ? VP and Chief Compliance Officer Effective Date: October 1, 2023 Management?s corrective action plan includes: ? Initial screening ? Management will implement a process to ensure that supporting documentation of the initial screening process is maintained. Responsible Person: Mary Beth Colatruglio, CPA ? Director of Accounting Effective Date: October 1, 2023

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 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. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) 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 or CEO 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 ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Management Response and Corrective Action: County Executive Office: 1. Person Responsible: Selina Chan-Wychgel, Fiscal Services Manager 2. Corrective Action Plan: The County Executive Office will adhere to the Contract Policy Manual (CPM) and internal policy and procedure of ensuring the suspension or debarment verification of a contractor is performed and documented prior to awarding a contract. The County Procurement Office will continue to provide trainings and reminders to County-wide procurement staff of this guideline to ensure compliance with Federal Award protocol. 3. Anticipated Implementation date: June 30, 2023 OC Public Works: 1. Person Responsible: Joseph Sly 2. Corrective Action Plan: On October 21, 2022, OCPW Procurement updated the Department?s policy and procedure to include an additional requirement for the submission of the Alternative Funding Procurement Acknowledgement Form when utilizing non-County funding sources. The contracts selected in this audit were awarded prior to October 21, 2022. 3. Anticipated Implementation date: October 21, 2022

Management response: Management agrees with the finding. This process will be included in the internal control matrix and finance manual. New vendors will be reviewed before entering in any commercial relationship. An annual review will be established for all large, significant contracts and for small vendors based on a sampling basis. Expected to be documented and in practice by June 30, 2023. Corrective action plan: 1. Verification of vendor in the System for Award Management (SAM) portal will be established and included in our control matrix. 2. Procurement area should verify all new vendors before entering in any commercial relationship. 3. Management will define a metric to select a sample from all vendors to verify in an annual basis. Contact person: Manuel Joglar Team: Head Start Finance Manager, Purchasing Officer Anticipated completion date: Not later than June 30, 2023

The Town of Carlisle, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 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. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF AGRICULTURE 2022-001 Child Nutrition Cluster ? Assistance Listing Numbers 10.555 Recommendation: We recommend procedures be implemented to annually (at a minimum) 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: Starting school year 2023/2024, we will make sure that the vendor certification will be done annually. We will also do an online research to make sure they are not suspended or debarred from federal funds. Name(s) of the contact person(s) responsible for corrective action: Susan Robichaud Planned completion date for corrective action plan: 03/10/2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Yvonne Hoffmaster Contact Phone Number: 219 873-1404 Ext. 2004 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: To bring the City into compliance with effective internal controls to ensure requirements related to the grant agreement and the Suspension and Debarment are satisfied, the City has created a checklist, Exhibit A, that contain a sign off by the Department Head and Board of Works as necessary. Anticipated Completion Date: The checklist will begin to be utilized on May 1, 2023.

Recommendation: We recommend the District include contract language which ensures vendor 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. Responsible official: Keith Lucius, Assistant Superintendent Anticipated completion date: June 30, 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Pia O?Connor, Auditor Contact Phone Number: (812) 379-1510 Views of Responsible Official: I agree with the findings as stated Description of Corrective Action Plan: The Auditor?s Office will continue to work with the Commissioner?s Office and other county departments to improve upon the process of administering the COVID-19 Coronavirus State and Local Fiscal Recovery Fund. The County will implement a Procurement, Suspension and Debarment Policy. By establishing this system of Internal Controls and developing the proper policies and procedures, this should help ensure contractors and sub recipients, as appropriate are not suspended, debarred or otherwise excluded prior to entering any contacts or sub awards. The Auditor?s Office continues to work with the Commissioners to improve the process of administering the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. This includes, but is not limited to, internal controls and procurement, suspension and debarment processes. Anticipated Completion Date: Policy and Procedures will be implemented by December 31, 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Elizabeth J Billue Contact Phone Number: 574-583-1515 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All current and future federal grant funding recipients/contractors will be searched for their suspension & debarment status on SAM.gov. If the contractor is not registered through SAM.gov a form will be created for use by the Auditor?s office, as well as any County office, requesting verification from the contractor and/or subrecipient of their standing in regards to suspension, debarment, or any other reason that would exclude them from entering into a contract or subaward. Anticipated Completion Date: 12/31/23

Finding No. 2022-007: Procurement Policy - Material Weakness in Internal Control Over Financial Reporting U.S. Department of Health and Human Services, Health Center Program Cluster; CDFA No. 93.224 Condition: There is no formal documentation or evidence to support that competitive price analysis for vendors selected by CCI several years ago or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Recommendation: Marcum recommends that CCI update its existing procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. Marcum also recommend that a review of all vendor contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Action Taken: CCI is recommending to the board to update its procurement policy by obtaining at a minimum-three separate bids for anything above $50,000.00. We are also in the process of hiring a full-time purchasing manager to oversee procurement policy and strategy. Anticipated Completion/Implementation Date: End of fiscal year 2024.

Findings: 2022-003 Significant Deficiency in Internal Control over Compliance Personnel Responsible for Corrective Action: Kerry Romero, Director of Accounting Anticipated Completion Date: December 31, 2023 Condition: The Organization had not adopted a procurement policy and no procurement procedures were performed in selecting contractors. Corrective Action Plan: The Organization will develop and adopt a procurement policy that will include procedures for receiving competitive bids for the acquisition of property and/or services. The policy will include screening vendors to ensure eligibility. The Organization will ensure contracts include a conflict-of-interest clause.

Findings: 2022-002 Significant Deficiency in Internal Control over Compliance Personnel Responsible for Corrective Action: Kerry Romero, Director of Accounting Anticipated Completion Date: December 31, 2023 Condition: The Organization had not adopted a procurement policy and no procurement procedures were performed in selecting contractors. Corrective Action Plan: The Organization will develop and adopt a procurement policy that will include procedures for receiving competitive bids for the acquisition of property and/or services. The policy will include screening vendors to ensure eligibility. The Organization will ensure contracts include a conflict-of-interest clause.

Reference Number: 2022-011 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Department Name: Department of Health and Social Services State Division Name: Division of Social Services Federal Program: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: SLFRP0139 (3/3/2021 ? 12/31/2024) SLFRP2629 (3/3/2021 ? 12/31/2024) Compliance Requirement: Procurement, Suspension & Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: The Division should review and enhance controls and procedures to ensure that it follows the State?s procurement policy and Federal suspension and debarment regulations for all goods and services charged to the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We agree with the auditor?s recommendation. Ongoing meeting, training, and monitoring have helped and will continue to help DSS staff to achieve compliance. The following actions have been taken to improve the Procurement process. ? Program unit staff will receive Procurement Bootcamp training on contract rules. ? Program unit & Fiscal unit staff will monitor and track all contracts, MOU/MOA?s and agreement so they are in compliance with State Procurement policy. ? Fiscal unit will ensure they have an approval to pay for any invoices. ? Conduct monthly meetings with OSEC CMP Managers and DSS Fiscal unit. Name(s) of the contact person(s) responsible for corrective action: Thomas Hall, DSS Director Victor Ting, DSS Chief of Administration Janneen Boyce, DSS Policy, Social Service Chief Administrator Joanne Sunga, DSS Fiscal, Social Service Chief Administrator Planned completion date for corrective action plan: ? Procurement Bootcamp training was completed March 22, 2023. ? Procurement monitoring, ongoing. ? Fiscal approval workflow, ongoing. ? Monthly Procurement meeting, ongoing.

Reference Number: 2022-003 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Department Name: Department of Education Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559, 10.582 Award Number and Year: 1DE303301 (10/1/2020 ? 9/30/2022) Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: The Department should 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 subrecipients prior to issuance of the subawards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Delaware Department of Education (DDOE) Nutrition Team will update the online School Nutrition application to include a certification statement similar to the statement below. Have any current principal staff been debarred, suspended, proposed for debarment, declared inelligible, or voluntarily excluded from participation in this transaction by any Federla department or agency. Yes/No The DDOE Nutrition Team will check SAM exclusions on sam.gov until the application is updated. Name(s) of the contact person(s) responsible for corrective action: ? Jeremy Coleman, Support Staff ? Marianne Bernardi, Support Staff Planned completion date for corrective action plan: April 28, 2023

U.S. Department of Health and Human Services 2022-003 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization follow the suspension and debarment policy in its new procurement policy and also ensure the correct vendor is being searched via other identification methods besides just vendor name. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will follow suspension and disbarment policy and incorporate procedures to ensure correct vendor is researched via identification methods outside of just vendor name. Name(s) of the contact person(s) responsible for corrective action: Jenny Singh, Finance Officer Planned completion date for corrective action plan: December 31, 2023

The responsible party is Putnam Moreman, Finance Director. The findings will be corrected by October, 2023. 2022-002 SUSPENSION AND DEBARMENT U.S. Department of Treasury ALN 21.027 ? COVID-19 Coronavirus State and Local Recovery Funds Contract No. Y5082 (2021) 2022 Funding U.S. Department of Environmental Protection Passed through Florida Department of Economic Opportunity ALN 66.460 ? Nonpoint Source Implementation Grant Contract No. NF068 (2020) 2022 Funding Recommendation: We recommend the City establish a procedure that requires a search for suspension and debarment for vendors receiving grant funds in excess of $25,000. Management?s Response: Whenever the City has a State or Federal grant, we always ensure that the vendors we do business with are not debarred from receiving State or Federal money. In this instance, we were buying relatively small tracts of land from our local pizza shop owner, a private individual, and we did not realize that the same rules applied. We have since ascertained that this individual is in fact not debarred. Going forward, Finance will ensure all expenditures of this nature document that the vendors are not debarred individuals.