Corrective Action Plans

2022-004 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: Implement procedures 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 planned in response to finding: All vendors that the Food Service Department plans to use for quotes will receive a contract which includes a form to report suspension or debarment from participation in Federal assistance programs or activities. Name(s) of the contact person(s) responsible for corrective action: Nancy MillspaughPlanned completion date for corrective action plan: July 1, 2023 If the U.S. Department of Agriculture has questions regarding this plan, please call Nancy Millspaugh at 812-376-4462

Finding 2022-001 Condition: Procurement documentation could not be found in Department files related to purchases of pizza making supplies from a vendor. Corrective Action Plan: This was a result in a change of leadership. Staff has implemented procedures to start procurement files for each department endeavor they partake in to meet the requirements in 2 CFR, section 200.319. Anticipated Completion Date: Completed Contact Information: Keith Buday, Assistant Superintendent for Finance & Operations budayk@holliston.k12.ma.us

FINDINGS?FINANCIAL STATEMENT AUDIT SIGNIFICANT DEFICIENCY 2022-001 Preparation of Annual Financial Report Recommendation: CLA recommends the County continue reviewing the annual financial report. Such review procedures should be performed by an individual possessing a thorough understanding of accounting principles generally accepted in the United States of America and knowledge of the System?s activities and operations. While it may not be cost beneficial to train additional staff to completely prepare the report, a thorough review of this information by appropriate staff of the County is necessary to obtain a complete and adequate understanding of the County?s annual financial report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management believes the cost for additional staff time and training to prepare year-end closing entries and reports outweigh the benefits to be received. Management has reviewed and approved the annual financial report prior to issuance. Name of the contact person responsible for corrective action: Lynnette Lorenz, Administrator Planned completion date for corrective action plan: December 31, 2023

The Town of Clinton/School Department will maintain proper procurement procedures in compliance with Local, State and Federal laws and regulations. State procurement laws (MGL Chapter 30B for Goods and Services and MGL Chapter 149 Construction) are followed however the district is aware of the federal requirements. When there are exemptions from state procurement laws, of when federal regulations are stricter the district will use the strictest rules, under 2 CFR 200.318-327. These procedures have been updated in the Financial Procedures Manual (pages 231-240, under Section II Procurement System). The Town of Clinton/School Department will utilize two methods to determine if a potential vendor has been suspended or disbarred. Prior to approving a requisition for a contracted service in excess of $25,000 funded by a Federal grant, district will check Sam.gov and will require the vendor to sign an affidavit. The Town of Clinton/School Department will expend membership with French River Education Center - Purchasing Cooperative to include several school lunch food products.

Condition: Suspension and debarment compliance is not verified for all covered transactions. Corrective Action Planned: The School Comptroller will ensure that all vendors are checked using SAM for suspension and debarment for all covered transactions in compliance with federal laws. The School Comptroller will print out the support and include with each grant. Anticipated Completion Date: Completed Contact: Robert Dickinson, City Auditor

Views of Responsible Officials: A detailed Procurement process currently exists; however, due to staff attrition we were unable locate all the procurement documentation requested. We will continue to reinforce our Procurement policy (detailed below as it relates to documentation) and now require all documentation be stored in a Central location for all applicable Finance staff. This policy includes a required annual screening of any current vendors and has now been extended to contractors and consultants also. E. Procurement Records and Files: 1. Mary's Center will establish and maintain procurement records and files. The records will be kept in the office of the Chief Executive Officer and/or Finance office and virtual copies will be stored on the Finance shared folder. 2. Mary's Center will document in the procurement files some form of cost or price analysis made in connection with every procurement action. 3. For any contracted service (other than equipment-specific technical support), Mary's Center procurement file will include: a. Basis for selection of the contractor, b. Justification for lack of competition when competitive bids or prices are not obtained, and c. Basis for award cost or price. 4. These records and files will be kept in accordance with Mary's Center's Record Retention and Document Destruction Policy.

CONDITION: Per the on-site monitoring report of the City’s Community Development Block Grant (CDBG) Program performed by the Department of Housing and Urban Development dated May 15, 2024, the City purchased a device called ShotSpotter with CDBG contract B-20-MC-42-0106 funding in the amount of $99,000. The City of McKeesport did not verify if the above vendor was on the excluded parties list in the System for Award Management through www.sam.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the City is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. In addition, the City’s Community Development Block Grant Policies & Procedures Manual in Section VIII for procurement requires this step to be performed. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will utilize the www.sam.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance, and Section VIII of the City’s CDBG Policies & Procedures Manual for procurement. The City will save the results from the website search with each applicable vendor file to document compliance with these requirements. The timeframe for completion of this process is effective immediately.