Corrective Action Plans

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

County Judge/Executive’s Response: Staff will use purchase orders for all funds including disbursements from the American Rescue Plan Fund. However, it should be noted that the information included on a purchase order including date, approval, general ledger account number, and amount were listed on each invoice included in this finding. The only item not included was the title “purchase order.” In addition, a separate ledger is maintained for this fund to monitor expenditures and appropriations. The current controls in place over federal funds provide the same assurance that expenditures will not exceed budget appropriations. This alternative procedure serves as an effective compensating control.

Condition: Suspension and debarment compliance was not verified for two covered transactions. Corrective Action Planned: Management was unaware of the Federal procurement process requiring suspension and debarment verification of vendors. Since becoming aware management has verified the good standing of both vendors in question. Management has updated its internal financial operating procedures to ensure future compliance with procurement procedures on all applicable contracts for goods and services. Anticipated Completion Date: Completed Contact: Stephen Marshall, Assistant Superintendent of Finance & Operations

The District agrees with the above condition. The District will implement a process to review vendors for suspension and debarment status.

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to help ensure compliance. 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 prior to entering into the transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Copies of all federal vendors’ SAM.gov Active Registration and status reports are kept on file; copies of all bids are kept with the winning bid’s invoice and supporting documentation. Name(s) of the contact person(s) responsible for corrective action: Pamela Tesch, Director of Business Services Planned completion date for corrective action plan: Ongoing

Management has updated procedures to ensure vendors are not suspended or debarred and has shared and reviewed this information with staff to ensure that the procedure is carefully followed.

Recommendation: We recommend the District include contract language which ensures vendor are not suspended or debarred as well as utilize sam.gov 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.

Lincoln County (submitting Department and County Clerk’s Office) will verify through Sam.Gov that all claims submitted for payment using federal funds are not suspended, debarred, or excluded from receiving federal dollars prior to payment of the claim.

CORRECTIVE ACTION PLAN November 7, 2023 U.S. Department of Health and Human Services Boys and Girls Clubs of Kennebec Valley respectfully submits the following corrective action plan of the year ended June 30, 2023. Name and address of independent public accounting firm: One River CPAs 46 FirstPark Drive, Oakland, ME 04963 FINDING – FINANCIAL STATEMENT AUDIT 2023-001 – Material Weakness – Internal Control Material Weakness in Internal Control: Property and equipment adjustments were necessary to expense equipment below the capitalization policy. Additionally, depreciation expense was adjusted based on a revised useful life of the disposal of the old building as required for the financial statements to be fairly stated in accordance with U.S. Generally Accepted Accounting Principles (GAAP). Also, a gifts in kind adjustment was necessary to adjust for a duplicated item. The following errors were noted and corrected as a result of audit procedures: • Building Improvements was overstated by $122,249 • Net assets without donor restrictions were overstated by $258,704 • Revenues were understated by $252,387 • Expenses were understated by $115,932 Recommendation: Management should strengthen their review over purchases for compliance with their capitalization policy, review of useful lives of assets, and review the accuracy of recording gifts in kind revenue and expenses. Responsible Person for Corrective Action: Paula Burke, CFO Corrective Action to be Taken: CEO & CFO will review capitalization policy with the Finance Committee, and monthly during Finance Committee meetings review any expenditures over $10,000. CFO will review gifts in-kind with Resource Development Director prior to end of fiscal year adjustments. The anticipated completion date for this corrective action is January 2024 and June 2024. FINDING – FEDERAL AWARD PROGRAMS AUDIT U.S. Department of the Treasury 2023-002 – 21.027 Coronavirus State and Local Fiscal Recovery Funds Significant Deficiency and Noncompliance: There was not a process in place to formally document the review of the contracted entity for suspension and debarment prior to entering into the agreement. Recommendation: Management should strengthen their processes, controls, and review over suspension, and debarment processes and ensure compliance with Uniform Administrative Requirements. Responsible Person for Corrective Action: Paula Burke, CFO Corrective Action to be Taken: Request construction manager to check suspension and debarment of all subcontractors prior to hire, if project has not already been started. The anticipated completion date for this corrective action is November 2, 2023. Per contact with Joe Lajoie (construction manager), he confirmed none of the contractors were on the debarment and suspension list. If the U.S. Department of Health and Human Services has questions regarding this plan, please contact Paula Burke, CFO at 207-582-8458 or pburke@bgckv.org. Sincerely, Ingrid Stanchfield, Chief Executive Officer

It will be the practice of Antelope County to check vendor status with the SAMS/DUNS before any payments are made utilizing Federal funds. To further insure the funds are safely being utilized and spent, regular checks on the vendor status will be completed.

Holt County's first choice will be to obtain a certificate or an agreement with each entity stating they are in good standing.