Corrective Action Plans

2022-001: Procurement and Suspension and Debarment Corrective Action: Northwest College will perform a review of its current procurement policy, including purchasing thresholds, record retention of supporting documentation regarding method of procurement utilized, and maintaining supporting documentation regarding suspension and debarment for all contracts or purchases expected to equal or exceed $25,000 of Federal funds. Northwest College will revise its procurement policy as determined necessary and in accordance with Northwest College?s policies. Anticipated Completion Date: June 30, 2023 Contact Persons: Brad Bowen, Finance Director

2022-002 Health Centers Cluster ? Assistance Listing No. 93.224 and 93.527 Health Center Infrastructure Support ? Assistance Listing No. 93.526 Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) Procurement ? missing documentation for sole source purchase justification or price comparisons. Heartland?s purchasing policies and procedures were reviewed for content and clarity. In addition to the policy and procedure review, we will implement a more robust documentation, review, and approval process regarding larger purchases and sole sourcing. Purchases that are grant related and > $2,500 where the 3 bid minimum decision-making process is being waived and sole source is being utilized will be documented by the purchasing manager and reviewed, approved, and signed by our CEO as to why this is the optimal vendor (1). (See attached template) 2) Suspension and Debarment- missing documentation for quarterly review of vendors. Vendors will be reviewed on a quarterly basis to ensure that they are not on the exclusion list. The Accounting Specialist will report to the Controller on a quarterly basis regarding the status of the vendor review, and documentation of the review will be provided to the Controller at that time. Name(s) of the contact person(s) responsible for corrective action: Michael Cohlman, CFO and Tony Bartlett, Controller Planned completion date for corrective action plan: 4/1/23

Action planned/taken in response to finding: Train staff on 1. Sam.gov and ELPS sites 2. Collecting a certification from entity (SBA Form 1624, Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions) 3. Adding a clause or condition to the covered transaction with entity (2 CFR section 180.300) Name(s) of the contact person(s) responsible for corrective action: Kim Merrill, Finance Manager Planned completion date for corrective action plan: Staff Training ? November 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Auditor Mark Hoelscher Contact Phone Number: 765-973-9318 Views of Responsible Official: We concur with the findings. Wayne County Auditor's office will begin checking all contracts for suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs prior to the purchase. Anticipated Completion Date: December 31, 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tammy Chavis, Superintendent Contact Phone Number: 765-647-4128 Views of Responsible Official: As Superintendent, I concur with the finding that an effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Description of Corrective Action Plan: The Superintendent will be in close contact with the Special Education Co-Op, and require all supporting documentation of Procurement and Suspension and Debarment. Anticipated Completion Date: March 16, 2023 Tammy Chavis Superintendent March 16, 2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Lisa McCormick Contact Phone Number: 260-824-6474 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Wording will be included in all bid packets requesting suspended or disbarred status from all vendors prior to issuing contracts. Also, wording will be added to bid packets asking vendors to notify Wells County if they become suspended or disbarred during the life of the contract. Anticipated Completion Date: Immediately

Views of Responsible Officials and Planned Corrective Action: Management agrees with the above finding and will amend the Procurement Policy to include a vetting process to avoid a selection of a contractor /vendor that has been suspended or debarred from working on Federal Contracts.

2022-002 - ALN 21.027 - Coronavirus State and Local Fiscal Recovery Funds - Procurement, Suspension, and Debarment: Lack of Controls for Suspension and Debarment (New Comment) Auditor's Comment: According to the Coronavirus State and Local Recover Funds (CSLRF) Final Rule, Suspension and Debarment is covered under CFR 200.214 in Subpart C, which is fully applicable under the revenue replacement method. As such, suspension and debarment should be evaluated and documented for all non-payroll expenditures under this program. Management's Response: The City will create internal control procedures to ensure evaluation and documentation relating to Final Rule, Suspension and Debarment as required under CPF 200.214 in Subpart C.

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Debra A. Carnes Contact Phone Number: 317.477.1105 We concur with the finding As a pass-through entity for Federal ARPA funds, the Hancock County Auditor will design and implement a system of internal controls related to suspension and debarment procedures to ensure entities are neither suspended nor debarred or otherwise excluded or disqualified prior to entering any covered transactions. All current recipients of ARPA funds will be verified and documented as well. These controls will be utilized for all State and Federal grant funds that will be disbursed. Anticipated Completion Date: July 31,2023

CITY OF WAUWATOSA CORRECTIVE ACTION PLAN YEAR ENDED DECEMBER 31, 2022 United States Departments of Treasury and Health and Human Services The City of Wauwatosa respectfully submits the following corrective action plan for the year ended December 31, 2022. Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Period: March 2020 through December 31, 2024 Audit Period: January 1, 2022 to December 31, 2022 The findings from the schedule of findings are discussed below. The findings are numbered consistently with the numbers assigned in the schedule FINDINGS ? FEDERAL AWARD PROGRAM AUDITS SIGIFICANT DEFICIENCY 2022-001 Internal Control over Compliance ? Verification of non-debarment status Recommendation: We recommend the City of Wauwatosa design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred. Explanation of disagreement with the audit finding: There is no disagreement with the audit finding. Action planned in response to finding: This correction was made in October 2022 after it was brought to the City?s attention. The Purchasing Manager has been added as a required approver in the electronic requisition workflow process for all requisitions (Previously she was only a required approver for those greater than $25,000). At this step, the Purchasing Manager will look-up the vendor on Sam.gov and attach a screenshot on the requisition to show the vendor is not debarred. An affidavit of non-debarment status will also be added to the City?s standard terms and conditions document as well as its public construction contracts. Name(s) of the contact person(s) responsible for corrective action: John Ruggini, Director of Finance Planned completion date for corrective action plan: October 31, 2022 ****** If the United States Department of Treasury or Health and Human Services has questions regarding this plan, please call John Ruggini, Director of Finance at 414-479-8962.

FMCS concurs with the finding. Part of the issue is related to staffing shortages, which increases the demands on the providers---resulting in staff burnout. We have already developed policies and procedures for locking notes as well as attempting to hire an auditor. In addition, we send out monthly reminders to lock notes. We have refrained from taking punitive actions for fear that the provider will leave and that our patients will be impacted. We will increase the frequency of the reminders to bi-monthly and continue our efforts to recruit an auditor.

Department: Health and Human Services Title: Internal control over ELC program suspension and debarment needs improvement Questioned Costs: None Status: Management?s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Uniform Guidance part 200.214 identifies that non-Federal entities are subject to the non-procurement debarment and suspension regulations in 2 CFR part 180. 2 CFR part 180 requires that ?when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.? The Department meets this requirement as part of the contracting process by collecting certifications from the Community Agencies stating that they are not suspended or debarred. Therefore, we are in compliance with the Federal requirements for Suspension and debarment. The intent of the Department?s policy to utilize the System for Award Management Exclusions (SAM) is to be an optional and additional assurance to the required collection of certifications that the next lower tier persons are not suspended or debarred. The SAM is utilized as time and resources permit and is not intended to replace the certifications. Completion Date: N/A Agency Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tiffany Deakins Contact Phone Number: 260-248-3176 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Whitley County will make sure that moving forward we will verify there is proper verbiage in contracts over $25,000 stating that the vendor is not suspended or disbarred. Our Attorney has already been made aware of this and will immediately implement this step. Anticipated Completion Date: Immediate

Compliance requirement ? Procurement, and suspension and debarment Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor findings on the deficiencies in a), b) and c), about requesting quotation because, In accordance with the procedures under 2 CFR ? 200.320, and the definitions under 2 CFR 200.1 and 48 CFR Part 2, subpart 2.101 to support response to an emergency; the seven (7) referenced procurement transactions were under the Micro-purchase threshold for a national emergency response and the purchase could be awarded without soliciting competition or quotations. 2. The institution concurs with the auditor finding. The institution will incorporate the verification of suspension and debarment under the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution. Actions Taken or Planned: The institution will incorporate the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution.

Child Nutrition Cluster Procurement and Suspension and Debarment Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, 10.559 and 10.582 Recommendation: CLA recommends that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to 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. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The procurement requirements are being reviewed with staff and in-house information will be maintained and approved in-house in the future. Name(s) of the contact person(s) responsible for corrective action: Joe Green or Jeri Haase Planned completion date for corrective action plan: reviewed in 2022-23 and completed for 2023-24

FINDING 2022-006 Contact Person Responsible for Corrective Action: Laura Martin Contact Phone Number: 765-584-3149 Views of Responsible Official: I agree with the finding Description of Corrective Action Plan: The county will create a Certification to supply to any contractor with an expected purchase to exceed $25,000.00. If the contractor does not submit the certification the Auditor will check the Sam?s for any suspension, disbarment or exclusion and sign the certification. Anticipated Completion Date: July 28, 2023

Finding: 2022-003 ? Material Weakness over Federal Awards ? Controls over Suspension and Debarment Auditor Description of Condition and Effect: The Village had no controls in place, as required by the Uniform Guidance, to ensure that all parties that the Village 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 Village were with eligible parties. As a result of this condition, the Village had increased risk of inadvertently entering into a covered transaction with an ineligible party. Auditor Recommendation: We recommend that the Village Council and management adopt, and follow, written policies and procedures (that conform with requirements of the Uniform Guidance) to ensure that future contracts are properly documented and awarded in a manner that documents that the Village verified all parties under covered transactions are eligible for participation in federal programs or activities. Corrective Action: The Village agrees to the condition/finding of controls over suspension and debarment. Management and Village Council will implement a policy and controls in place no later than 12/31/23 Responsible Person: William Ward Anticipated Completion Date: December 31, 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will verify that all vendors are not suspended, debarred, or otherwise excluded and verify this has been done by the Deputy Auditor. Anticipated Completion Date: May 15, 2023

Views of Responsible Officials and Planned Corrective Actions: In December 2021, the Organization?s Board of Directors approved and adopted a procurement policy for the organization. The organization acknowledges that there is an opportunity for improvement of this policy, specifically to address suspension and debarment, and to establish procedures to ensure that purchases and subawards made under covered transactions are not made to parties that are suspended or debarred. Management has created a Vendor Monitoring Tracking spreadsheet and effective November 1, 2022, this spreadsheet will be maintained by the Bookkeeper to document that new and existing vendors are monitored to verify that the vendor is not debarred, suspended, or otherwise excluded or ineligible for participation in Federal assistance programs or activities. Vendor status will be verified before using a new vendor and on an annual basis for existing vendors. Documentation of findings will be copied, saved, and retained. On at least a quarterly basis, Management will review the vendor monitoring tracking spreadsheet and documentation of findings. The Organization?s procurement policy will be updated by November 1, 2022, to reflect the adoption of this procedure to address suspension and debarment.

2022-003 Coronavirus Relief Funds ? Assistance Listing No. 21.027 Recommendation: CLA recommends the County use sam.gov or the ELPS listing to review clients 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 taken in response to finding: Dickinson County will use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Name of the contact person responsible for corrective action: Brian Bousley, Controller/Administrator Planned completion date for corrective action plan: December 31, 2023 If the State of Michigan has questions regarding this plan, please call Brian Bousley at 906-774-2573.

Contact Name: Barbara Staggs, CFO Contact Phone Number: 870-863-8194 Audit Period Ending: June 30, 2022 Audit Firm: FORVIS, LLP Federal Program: Child and Adult Food Care Program, Assistance Listing No. 10.558 Federal Agency: U.S. Department of Health and Human Services Starting in August 2023, SADCCF will notify potential bidders of the opportunity to bid on the USDA meal program by radio announcement.

Management?s Corrective Action Plan: This is not a repeat finding from a prior year. However, management will implement the following action plan to ensure that future revenues are reviewed thoroughly in order to make a determination on whether the asset has donor restrictions. ACTION ESTIMATED COMPLETION DATE RESPONSIBLE PARTY STATUS/COMMENTS 1. Update existing procedures to detail examples of when revenue is restricted or unrestricted. 2. Review all unrestricted revenues received in 2023 to confirm whether they should be restricted. 10/31/2023 Yolanda Rodriguez N/A 11/30/2023 Yolanda Rodriguez N/A

There is no disagreement with the finding. The District does have an appropriate Procurement, Suspension, and Debarment policy in place. The District has already begun reviewing policies and procedures to ensure that documentation related to suspension and debarment is consistently documented in accordance with District policy.

Child Nutrition Cluster Procurement and Suspension and Debarment Child Nutrition Cluster - Assistance Listing No. 10.553, 10.555 Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to 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. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action Planned/Taken: Food Service Director now updated on requirements in district policy (6325) on procurement. Necessary controls have been reviewed for any contractual agreements, including debarment documentation, in the future as we are currently in the second year of a five-year contract. Name(s) of the contact person(s) responsible for corrective action: Richard Parks, District Administrator Planned completion date for corrective action plan: January 1, 2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Amy Copeland Contact Phone Number: (812) 689-6311 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Ripley County Auditor, Amy Copeland, has already been in contact with the Auditors in the State of Indiana to help with a Procurement Policy they already have in place. This is so the Ripley County Attorney and I can work on getting Ripley County a Procurement Policy in place as soon as possible. Ripley County will also be writing a Suspension and Debarment Policy for any checks written over $25,000.00 to any subrecipient or contracts. The new polices will address procedures for procurement and suspension and debarment to ensure there is a review and approval process in place to ensure compliance. Anticipated Completion Date: 8/30/2023