Corrective Action Plans

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.

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.