Corrective Action Plans

Finding No. 2022-004: Procurement Policy ? Material Weakness in Internal Control Over Financial Reporting; U.S. Department of Health and Human Services, Rare Disorders: Research, Surveillance, Health Promotion, and Education; Assistance Listing Number 93.315 Condition There is no evidence of a documented formal procurement policy with regards to federal grant awards and expenditures, no documented support that a competitive price analysis for vendors and organizations funded with federal grant funds were performed and no evidence that suspension and debarment verifications were performed for certain vendors and organizations, as required by the general procurement standards of the Uniform Guidance. Recommendation It was recommended that the Association establish a written 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. It was also recommended that a review of all existing vendor or sub-awardee contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Action Taken The Spina Bifida Association will take action to ensure an up-to-date Procurement Policy is approved by the Board of Directors. Anticipated Completion Date December 2023

CORRECTIVE ACTION PLAN JANUARY 10, 2023 The Brevard Health Alliance, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Carr, Riggs, and Ingram, LLC 215 Baytree Drive Melbourne, FL 32940 Audit Period: Fiscal Year October 1, 2021 - September 30, 2022 The finding from the January 10, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. 2022-001 PROCUREMENT PROCEDURES COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care For Homeless and Public Housing Primary Care) ? American Rescue Plan Act Assistance Listing Number: 93.224, Contract Numbers- H8F41284 Department of Health and Human Services (HHS) 2022 Funding Pursuant to 2 CFR ?200.1, Simplified Acquisition Threshold (?SAT?), acquisitions which exceed the SAT of $250,000 must use one of the following procurement methods: the sealed bid method, the competitive proposals method, or the noncompetitive proposal method (sole source). The Alliance did not utilize the sealed bid method or competitive proposals method for a purchase of computer hardware, which exceeded the $250,000 SAT. The Alliance?s procurement policy was not updated to be in compliance 2 CFR 200.1 until April 2022. This purchase began in fiscal year 2021, but the remaining items under the contract were procured in fiscal year 2022. Perspective: The purchase made at the beginning of the year was procured under the old purchasing policy. The policy was updated in April 2022, and the additional purchase exceeding the bid threshold made subsequent to the new purchasing policy was procured under a competitive process. Recommendation: The Alliance should continue to follow its updated procurement policy. Responsible Party: Shannon Wherry, Controller Corrective Action: Management updated the procurement policy April 2022 to comply with the provisions of 2 CFR ?200.1, 2 CFR ?200.67, and 2 CFR ?200.214. The updated policy has been implemented since this occurrence and will continue to be followed.

2022-002 Suspension and Debarment State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the City review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will improve our process by documenting the search on SAMS.gov. This documentation will include snapshots of the search. Name(s) of the contact person(s) responsible for corrective action: Maryanne Groat, Finance Director Planned completion date for corrective action plan: 9/26/2023 If the U.S. Department of the Treasury has questions regarding this plan, please call Maryanne Groat, Finance Director, at 715-261-6645.

U.S. Department of Health and Human Services 2022-003 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Health Center follow the suspension and debarment policy with all applicable transactions, and retain documentation supporting the procedures performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement policy was revised in Oct 2022, with staff trained on requirements related to testing of vendors related to suspension and disbarment. Staff will retain documentation per the revised policy under UFM?s record retention policy. Name(s) of the contact person(s) responsible for corrective action: Lori Zook, CFO Planned completion date for corrective action plan: 12/20/2022

Corrective Action Plan Year Ended December 31, 2022 Finding 2022-001: Suspension/Disbarment Searches Management response: IWPR was able to provide vetting which confirmed that monies were not provided to any suspended or debarred parties as required per 2 CFR 200.214. Vetting was undertaken after the fact but prior to the audit in a small sample of transactions within our Central Asia region of operations only, and represented only a very small percentage of overall operations. Nevertheless vetting is a matter which IWPR takes very seriously, alongside wider compliance obligations. IWPR hired a Compliance Manager in November 2021 to work with staff across all programs to ensure IWPR's compliance with all aspects of USG regulations, including all vetting requirements. This included all staff training on IWPR's Vetting Policy and Procedures, which include new vetting software and staff access. Reflecting the critical importance of ensuring IWPRs procurement is compliant, IWPR has undertaken a full review of its Procurement Policy and Procurement Guidelines involving a lengthy, rigorous and collaborative process to update the Policy, which has now been approved by the Board and which will be rolled out in 2023 alongside Guidelines and through mandatory interactive training for all staff. For 2023, all vetting for procurements has been carried out in a timely manner, prior to contracting. A routine internal audit visit has already been scheduled to take place in Central Asia in 2023 to further validate the correct application of all compliance requirements, through training around finance and compliance which will include a refresher on USG rules and regulations, the new Procurement Policy and the Vetting Policy. Furthermore, a mandatory refresher training on the IWPR Vetting Policy and Procedures will be carried out for the entire organization in 2023 and then yearly thereafter. Name of Responsible Official: Stephen Ramsey, Chief Operating Officer Anticipated Completion Date: September 2023

FINDING 2022-001 Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: United States Department of the Treasury Passed-through: N/A Compliance Requirements: Procurement, Suspension and Debarment Auditor Recommendation: We recommend the City modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. Views of Management/Responsible Officials and Corrective Action: The City concurs with the auditor?s recommendation and will modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. The City has never had a finding in its Single Audit before and was not aware that the procurement standards identified in Title 2 of the Code of Federal Regulations (CFR), specifically 2 CFR sections 200.317 through 200.326, had to be included in the City?s procurement policy. Being that this was the first time the City received the ARPA funding and was subject to this requirement, this deficiency came up. The City will review and bring its current policy up to date. The City also made an effort to comply when a deficiency was known. In August 2022, the City established its Debarment and Suspension policy. With this policy in place, the City will review its current process to ensure that going forward, verifications for debarment and suspension are performed for contractors prior to entering into transactions with them. Name of Responsible Person: Kim Sao, Finance Director Implementation Date: 6/30/2023

Bonnie Baerwald, MPA, CPA, President CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 United States Department of Education Moraine Park Technical College District 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 are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS United States Department of Education 2022-002 COVID-19: Higher Education Emergency Relief Fund ? Assistance Listing No. 84.425 Recommendation: The auditors recommended the District design and implement controls to ensure adequate documentation of controls over verification of vendors status as not suspended or debarred under the requirements of 2 CFR Park 200 Section 200.214 are properly retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Moraine Park Technical College will take or has already taken the following actions: 1. Reviewed and updated policies and procedures related to suspension and debarment. 2. Communicated requirement reminders to purchasing agents under federal grants. 3. Training will be conducted for purchasing agents on verifying vendors and retention of documentation prior to procurement. 4. Reviewed documentation of verification retention requirements. Name(s) of the contact person(s) responsible for corrective action: Timothy Keenan, Tara Wendt If the United States Department of Education has questions regarding this plan, please call Timothy Keenan, Purchasing Manager at (920)924-3240.

U.S. Department of the Treasury and Wisconsin Department of Health Services (DHS) 2022-004 Suspension and Debarment Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend the County use sam.gov or the ELPS listing to review clients prior to entering into procurement transactions in excess of the covered transaction threshold in accordance with the Uniform Guidance. We also recommend that there is a review of this documentation prior to approval of use of the vendor and that documentation of the search and approval is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Departments have been given instructions on how to use the sam.gov website, some have worked with CLA to make sure necessary proof is documented and we continue to remind departments at department head meetings as well as in emails when departments are making purchases. Name(s) of the contact person(s) responsible for corrective action: Sarah Luchini Planned completion date for corrective action plan: 2023

District Response: A. What corrective action will be taken: District will follow all the requirements of 2 CFR 200 with respect to federal procurement requirements. B. Who is responsible (name and position): Dr. Stephen Gregory, Federal Program Director C. When will the plan be implemented? Corrective action started May 5, 2023, and will continue.

FINDING 2022-002 Contact Person Responsible for Corrective Action: LaGrange County Auditor Contact Phone Number: (260) 499-6310 Views of Responsible Official: We concur with the findings from SBOA The County will establish a internal control system of checking Excluded Parties List System, collecting a certification from that person or adding a clause or condition to the covered transaction with that person for all vendors equal to or in excess of $25,000 for SLFRF award funds to ensure such contractors and subrecipients are not suspended, debarred or otherwise excluded. Copies of supporting documents to be retained. Anticipated Completion Date: Implementation will begin immediately.

Finding Number: 2022-003 Condition: The City had no controls in place, as required by the Uniform Guidance, to ensure that all parties that the City enters into covered transactions with are eligible for participation in federal assistance programs or activities. However, during our testing, we found that all covered transactions entered into by the City were with eligible parties. Planned Corrective Action: The City has adopted a procurement policy on 10/03/22, which states that the City will only hire contractors which are eligible for participation in federal assistance programs or activities. Contact person responsible for corrective action: Kathryn Beemer, City Administrator Email: kbeemer@fennville.com Office Phone: 269-561-8321 Cell Phone: 269-543-2645 Anticipated Completion Date: 10/03/2023

Finding 2022-002 Procurement and Suspension and Debarment Management?s or Department?s Response: Management agrees. Views of Responsible Officials and Corrective Action: On October 19, 2022, CPMM proactively conducted a check on all active procurements to ensure a SAM report was pulled. If one was not present in the file, CPMM pulled a SAM report. Going forward, CPMM will use the checklist to ensure a SAM report is pulled for all future procurements. SCRRA has already implemented the use of the checklist for all the required documents associated with a procurement. The checklist includes all required documents to complete a procurement including the verification of suspension and debarment documentation. Name of Responsible Person: Cynthia Minix Implementation Date: June 30, 2023

Respectfully, the school corporation does not agree with several of the findings in regards to segregation of duties and purchases. First, the SBOA auditors' told the school corporation during the 2019 audit that operating the school lunch program through the extracurricular account was not legal. The school corporation was informed that this account must be transferred to Central Office and a Corrective Action Plan must be in place. This directive was incorrect and pointed out in the official response from November 5, 2019 under IC 20-26-5-4(a)(l l). Second, segregation of duties, oversight, and approval of functions existed in 2019 and are presently occurring daily, weekly, and monthly within the cafeteria program under the corporation accounts and supervision of Central Office. Cafeteria workers record and submit timesheets of duties performed during each payroll period. The Cafeteria Director verifies and signs timesheets to be submitted to the Treasurer and Deputy Treasurer for review and payment from the Cafeteria account. A payroll docket report is sent to the Superintendent prior to payment from the bank. Prior to the 2019 audit, the High School Treasurer spent approximately two hours per day counting cash received each day from school lunches purchased. She also receipted those funds it into the software system, made deposits to the bank, paid invoices for food expenses, and processed part of payroll. Tasks conducted by the High School Treasurer were segregated by a timesheet and supervised by the High School Principal. All those tasks were shifted to Central Office in 2020 and are now segregated to the Treasurer and Deputy Treasurer. The Treasurer documents hours spent on Cafeteria accounts on a timesheet for review and signature by the Superintendent. Financial reports of expenditures and revenues are provided for review and oversight to the Superintendent and School Board at monthly board meetings. Third, RSSC has a small Central Office consisting of a Superintendent, Treasurer, Deputy Treasurer, and Secretary. It has no Assistant Superintendents, Human Resources Director, or Business Manager. Each person in Central Office wears multiple hats and performs multiple duties each day. It was noted in the Audit Report filed from July 1, 2008 to June 30, 2010 that " ...Randolph Southern School Corporation is unable, due to financial limitations, to employ additional personnel to segregate duties in our receipts and cash and investment balances. This statement would apply to all of our internal controls. " The circumstances for RSSC have not changed in the audit periods from July 1, 2010 through June 30, 2022. Corrective Action Plan: The School Board had chosen not to add additional staffing due to costs. RSSC is still unable to segregate duties for financial transactions and reporting. Fourth, the Cafeteria Program only has one full-time staff member, the Cafeteria Director. Eight part-time cafeteria workers prepare and feed up to 300 students each day. This food service program is one of the best run programs in the State oflndiana. It has not had one food preparation or sanitation violation from IDOE or Department of Health in the last 12 years. Fifth, the Cafeteria Program is economically efficient and fiscally responsible. The account carries at least a 3-month cash balance at all times. This success is a direct result of oversight by the combination of the Superintendent, Treasurer, and Cafeteria Director. RSSC adopted board policy 6114 Cost Principles-Spending Federal Funds on May 9, 2016. RSSC has had an Indirect Cost Rate in place since 2013. The adopted policy allows the school corporation to apply Indirect Costs to all federal funds including the Cafeteria account. On December 5, 2019, email communications between the Dr. Donnie Bowsman, Superintendent and Tina Herzog, IDOE Assistant Director of Operations and Food Distributions clearly state the school corporation can apply the Indirect Cost Rate to the Cafeteria account. The email communication clearly states that the high cash balance was a result of not applying the Indirect Cost Rate to the Cafeteria account (See Exhibit 1 Emails). The Indirect Rate was approved by the IDOE Office of School Finance and existed prior to the audit years being referenced in the finding. Technically, the prospective portion (going forward for the next school year) as referenced on pages 24-25 of USDA Indirect Cost Guidance Manual pertains to the 2013 Fiscal Year. Moreover, the fact was reiterated by the IDOE School Nutrition Office with email communications on December 5, 2019, not 2021 or 2022 as referenced in the finding. RSSC has not charged or recouped the Cafeteria Account the Indirect Cost rate for many years and has subsidized this account which should be independent and self-sufficient. The School Corporation did not apply the Indirect Cost Rate in 2020 or 2021 because we were not sure how many students would be eating and how fiscally sound the account would be due to students not attending school because of COVID. Corrective Action Plan: The Indirect Cost Rate will be applied and collected in the future prior to June 30 of each current fiscal year. It should also be noted that in 2021, RSSC purchased a new cafeteria dishwasher utilizing ESSER II funds. This unit was 20+ years old and needed to be replaced in order to continue feeding children and to run the food service program. This expense could have been and should have been a direct cost of $58,189 to the Cafeteria account. However, due to the unknown circumstances of COVID, the RSSC could not take a chance. The ESSER II grant is still open and we are now questioning whether this expense could be charged directly to the Cafeteria account. Those ESSER II fund could be utilized for staffing to support student learning loss and remediation. Sixth, COVID caused this financial account to increase exponentially from 2020 to 2021. ESSER funds were provided by the federal government to provide free lunches to every child which paid the food operations expenses for two school years. Student participation of eating school lunches increased during these time periods. Additionally, staff members were receiving hazard pay incentives on top of their regular hourly rate. Further, the School Corporation and Cafeteria Program took on the enormous task of feeding children over the summers of 2020 and 2021 when COVID cases were at its peak. The cafeteria personnel fed 5286 and 5740 students respectfully during those summers. The number of meals served during the summer almost equaled the total amount of meals served during the entire school year for each respective academic year. These additional meals created additional unexpected revenues for the fiscal year. The school corporation did not charge mileage for satellite lunches being delivered or indirect costs.

Finding 2022-002: Procurement and Suspension and Debarment - Material Noncompliance Management?s Response: Our commitment to maintaining strong financial controls and compliance with grant reporting requirements remains unwavering. In response to the audit finding and in our ongoing efforts to continually improve our internal controls and procedures, we have developed a comprehensive corrective action plan to address the noncompliance and strengthen our procurement and suspension/debarment processes: Procurement Policy Update: We have initiated a review and update of our procurement policy to ensure alignment with the Uniform Guidance Procurement Standards. This updated policy will incorporate the necessary provisions and requirements outlined in government regulations. Vendor Review Process: We have implemented a formal process to review vendor suspension and debarment status within the SAM Exclusion system prior to contracting. This process will be integrated into our procurement procedures to ensure compliance with the Uniform Guidance Procurement Standards. Training and Awareness: We will provide training sessions to staff involved in procurement processes, emphasizing the importance of adhering to the updated procurement policy and conducting thorough vendor reviews within the SAM Exclusion system. This training will enhance their understanding of the regulatory requirements and their roles in compliance. Documentation and Record-Keeping: We have established procedures for documenting and retaining records of vendor reviews within the SAM Exclusion system. This documentation will serve as evidence of our due diligence and compliance with the Uniform Guidance Procurement Standards. Monitoring and Internal Controls: We will strengthen our monitoring procedures and internal controls to ensure ongoing compliance with procurement and suspension/debarment requirements. Regular reviews will be conducted to verify adherence to the updated procurement policy and vendor review processes. Continuous Improvement: We are committed to continuous improvement in our procurement and suspension/debarment processes. We will establish a mechanism for periodic reviews of our policies, procedures, and controls to identify areas for enhancement and ensure they remain effective and aligned with the Uniform Guidance Procurement Standards. Anticipated Completion Date: Already Implemented Responsible Contact Person: Dr Malik Mamoon Munir, Global Operations Officer, +1 678-580-0853

The Town of Winchester, 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 10.553 and 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: Winchester Public Schools complies with the Audit Recommendation. Due to the change in leadership in the FY22 school year the department was late in receiving the required documentation. Name(s) of the contact person(s) responsible for corrective action: Finance Director Planned completion date for corrective action plan: FY23

Identifying Number: 2022-003: U.S. Department of Education: Education Stabilization Fund: Student Aid Portion ? 84.425E (HEERF); U.S. Department of Agriculture: Child Nutrition Cluster ? 10.553, 10.555, and 10.559 (CNC) Finding: For one vendor paid with HEERF funding and one vendor paid from CNC funding, there was no documentation to support that the District had verified that the vendors were not suspended or debarred prior to purchases. Corrective Action Taken or Planned: This relates to the Entity Exclusion (Suspension/Debarment) list maintained on the federal SAM.GOV website. Access to the website and specifically the Entity search functions is limited to authorized/registered users. The corrective action plan for HEERF will include the designation of a Southeast Technical College employee with SAM.GOV access that will be the initial point of contact for vendor exclusion information for all Southeast Technical College employees. Additionally, the designated employee will periodically download, and post debarment lists to the Southeast Technical College internal website (myTech) that will be available to all employees purchasing goods/services that would be charged to federal programs. Additional corrective actions will include a review of existing Southeast Technical College procurement policies contained within Section D: Fiscal Management. Policies will be reviewed/revised to expand and reflect current federal procurement requirements under 2CRF200. Revised policies, debarment lists, and training will be provided to all employees on a periodic and ongoing basis. For the Child Nutrition Cluster, this particular vendor was not expected to go over $25,000 and was used for emergency purchases that did not go over $25,000 until the last purchase in June, 2022. It was recommended that all purchases with amounts expected to go over $25,000 be vetted through the District?s purchase order process. Since this vendor was not expected to go over $25,000, it did not go through the purchase order process. The District will continue to use the purchase order process for vendors expected to go over $25,000 to ensure debarment requirements are being followed. Contact person: HEERF: Rich Kluin, Vice President ? Finance and Operations, Southeast Technical College. CNC: Gay Anderson, Child Nutrition Supervisor. Status of finding ? HEERF procedures will continue to be followed. The CNC procedures will continue to be followed.

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Angela C. Birchmeier, County Auditor Contact Phone Number: (574) 935-8555 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County and Auditor?s office were unaware of the requirement that a contract over $25,000 needed verification that the contractor had not been suspended or disbarred. Now that we are aware, each contract will be verified by either checking the EPLS (Excluded Parties List System) or that the clause for disbarment or suspension is included in the contract. The Department requesting the contract will verify if the clause is in the contract. The Claims Deputy will also verify during the claims process for payment and the 1st Deputy will also verify. Anticipated Completion Date: We have already implemented this procedure effective April 2023.

The following is Management's Response to the Findings Required to be Reported by the Uniform Guidance. This document was prepared by management of Oklahoma Mental Health Council d/b/a Red Rock Behavioral Health Services. 2022-001 Substance Abuse and Mental Health Services Projects of Regional and National Significance, Assistance Listing Number 93.243, U.S. Department of Health and Human Services, Award Year 2022 Finding Summary: Red Rock's procurement procedures were not adequate to meet the requirements of 2 CFR ? 200.317- .327; 2 CFR ? 200.214 - Procurement, Suspension, and Debarment Explanation of Agreement/Disagreement: Management concurs with the finding and will change Red Rock's procurement policy. Officials Responsible for Ensuring Corrective Action: Kile Kuykendall, Chief Financial Officer E-mail - kilek@red-rock.com Planned Completion for Corrective Action: Corrective action will be completed in FY 2023. Action in response to finding: Purchasing staff will be trained on federal procurement requirements and will be provided a copy of the new policy.

2022-011 ? Suspension and Debarment (Significant Deficiency) Governor?s Office care of State Department of Budget and Finance AL Number: 21.027 Program Title: Coronavirus State and Local Fiscal Recovery Fund Direct Award from: U.S. Department of Treasury Condition 2 CFR Section 200.214 requires non federal entities to comply with non-procurement debarment and suspension regulations. 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 auditing firm selected a sample of subawards that were open in FY 2022. There was no evidence of a suspension or debarment review for 100% (7 out of 7) of the sample of subawards tested. The auditing firm was unable to verify that the State had checked whether the entities were federally suspended or debarred on the SAM.gov website prior to executing the subawards. Current Status of Corrective Action Plan Concur. B&F will modify its procedures to check for debarment or suspension on SAM.gov prior to issuing a subaward to an entity and retain evidence of the verification including who performed the check and the date performed. Person Responsible Mark K. Anderson, Office of Federal Awards Management, Administrator Anticipated Date of Completion July 1, 2023

CORRECTIVE ACTION PLAN JUNE 30, 2022 REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Wendi Allardice - Superintendent Karen Hancock - Title I/ESSER Grants Manager 2. Corrective action planned: A. Protocols developed to obtain at least 3 vendor quotes for any items over 10,000 with an analysis and justification of vendor chosen. B. Protocol in place for checking for vendor suspensions or debarment prior to purchase approval. C. Monthly meeting for comparison of proposed and estimated purchases and actual purchases and charges to the Grant. 3. Anticipated completion date: Anticipated completion date for above listed plan: 08/31/2022

Finding 2022-003: Procurement, Suspension, and Debarment (Material Weakness) Information on the Federal Program: U.S. Department of State ALN 19.040 Criteria or Specific Requirement: 2 CFR Section 200.214 requires that, for covered transactions, a non-Federal entity must verify that entities are not suspended, debarred or otherwise excluded. This verification may be accomplished by checking the System for Award Management (SAM) website maintained by the General Services Administration. Condition: For all disbursements tested, FCE could not provide documentation of their verification, prior to payment, that the vendors were not suspended, debarred or otherwise excluded. Cause: FCE did not require evidence of SAM checks be maintained in its vendor files. As a result, FCE did not maintain adequate support to provide evidence that appropriate suspension and debarment searches were performed. Despite the lack of documentation, a search was performed after the fact to verify that the vendors or individuals in our sample were not suspended, debarred or otherwise excluded. Therefore, no questioned costs have been reported related to the sample that was tested. Effect or Potential Effect: FCE was not in compliance with the procurement documentation requirements of the Uniform Guidance. As a result, FCE could not readily provide evidence that it had assessed whether or not its vendors were suspended, debarred, or otherwise excluded. As a result, the potential for payments to suspended, debarred, or otherwise excluded vendors and individuals exists. Recommendation: FCE should establish internal controls to ensure proper documentation is maintained as evidence to support that it performed the required suspension and debarment searches on the SAM website. Action Taken: FCE acknowledges the importance of proper vetting procedures and shall implement policies and procedures with respect to screening potential vendors. The policy will include the requirement to consult the System for Award Management (SAM) website to ensure a potential vendor is not suspended, debarred, or otherwise excluded from qualification to receive Federal award funds. Proper documentation to support the completion of the required suspension and debarment searches will be maintained in accordance with the policy.

2022-005: Suspension and Debarment (Significant Deficiency) Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. The Authority expanded its policies and procedures related to suspension and debarment to all grant expenditures effective January 2022. Completion Date ? January 2022 Contact Person ? Jami Blosmo, Accounting Manager

vendors prior to commencement of their affiliation with PCC and simultaneously adding all new vendors to the existing monthly search for suspended and debarred vendors in the federal exclusions database with the Senior Executive Assistant responsible for queries. The Senior Executive Assistant to review entire list of vendors on a monthly basis to ensure all current vendors have been added to the master list prior to running query each month. The Senior Executive Assistant will work with CEO to identify any new vendors prior to commencement of their affiliation with PCC in a timely manner.

U.S. Department of Health and Human Services 2022-002 Health Center Cluster ? Assistance Listing Numbers 93.224 & 93.527 Recommendation: As the policy has already been revised, we recommend the Center follow the requirements under the new policy and ensure documentation is maintained as appropriate to support vendor checks against the SAM Exclusions list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management has revised the suspension and debarment policies and procedures to meet Uniform Guidance requirements, and will ensure the new policy and procedures are followed moving forward. The Center also had a call with Keith Schwartz, HRSA Program specialist to discuss the progress made on the prior findings on April 25, 2023. Name(s) of the contact person(s) responsible for corrective action: Jennifer Beckius, CFO Planned completion date for corrective action plan: New policy was implemented in June 2022

The Board Trustees has authorized a reorganization of the Fiscal Services department that includes adding Purchasing Manager and Purchasing Technician to ensure the District follows all purchasing guidelines and compliance requirements related to purchasing. The Purchasing Manager will also be responsible for our warehouse and inventory processes. This reorganization was approved effective July 1, 2023. Recruitment has begun for these positions.