Corrective Action Plans

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update, as necessary, its current procurement policies and procedures to ensure compliance with Section 2 CFR 200.237 Subpart D regarding post federal award requirements. In specific, this procedure will ensure that the terms and conditions required by Subpart D are included as part of all future contracts involving the use of federal assistance. This procedure will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

Finding No.: 2022-029 AL Program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Procurement and Suspension and Debarment Questioned Costs: $12,244,415 Contact Peron(s): Tracy B. Norita, Secretary of Finance / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Condition 1&3: The Procurement Services Division agrees with this finding. The Division will revise CNMI’s procurement regulations to ensure alignment with federal procurement standards as outlined in 2 CFR Part 200, particularly the small purchase threshold requirements and competitive procurement procedures. Proposed Completion Date: Policy updates drafted by December 31, 2025 and adopted by March 31, 2026. Condition 2&5: The Procurement Services Division agrees with this finding. To address the lack of consistent verification of vendor eligibility under federal debarment and suspension requirements (2 CFR §180.300), a policy will be implemented requiring all agencies to submit debarment verification documentation at the time of vendor selection. Acceptable documentation may include (1) a printout or screenshot from the SAM.gov Exclusions database, confirming that the vendor is not debarred or suspended, (2) a signed certification from the vendor attesting to their eligibility, or (3) a signed contract clause or provision that explicitly states the vendor is not excluded from federal transactions and complies with applicable debarment regulations. Procurement procedures and standard forms will be revised to include debarment verification as a mandatory step prior to any purchase approval involving federal funds. Procurement Services will ensure that debarment verification documents are maintained in the official procurement file for each transaction involving federal funds. Proposed Completion Date: October 1, 2025 Condition 4&6: The Procurement Services Division respectfully disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, the Division maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Proposed Completion Date: Ongoing

June 9, 2023 Maher Duessel 50.3 Martindale Street-Suite 600 Pittsburgh, PA 15212 To Whom It May Concern: Please see our corrective action plan for the findings reported in the June 30, 2022 Schedule of Findings and Questioned Costs. Finding 2022-001- General Ledger Maintenance and Reconciliation Criteria: Timely reconciliation of financial data is necessary to ensure accurate financial information is reported in order to make appropriate business decisions by management and those charged with governance. Condition: The West Mifflin Area School District {School District) did not consistently perform internal control procedures designed to maintain and reconcile the general ledger throughout the year. As a result, the trial balances originally presented for the audit were not properly reconciled and balanced. Cause: The School District did not consistently follow its procedures to ensure that all balance sheet accounts were reconciled to the general ledger and accurately reported in a timely manner. Effect: The financial data was not fully reconciled and completed throughout the year. The audit was delayed to provide time for the trial balances to be updated and ready. Various adjustments were necessary to update the records for the audit and to prepare the financial statements. Recommendation: We recommend that the School District reconcile all of its accounts in a timely manner. Reconciliations should be completed on a monthly basis to support and ensure that the accounts are properly stated. The review should ensure that the reconciliations are completed accurately and that reconciled amounts agree to the general ledger. The review and approval should be documented. Views of Responsible Officials and Planned Corrective Action: The School District agrees with the recommendation. The process undertaken to update the financial records has been updated to include a more formal procedure to reconcile the general ledger. This review is being performed on a more regular basis and the accounts will be updated and reconciled timely and in advance of the fiscal year 2023 audit. Finding 2022-002- Questioned Costs Related to Procurement Federal Agency: Department of Education Federal Communications Commission Program: COVID-19 Education Stabilization Fund (ESF): 84.425 COVID-19 Telehealth Program: 32.006 Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.237, the School District is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Recipients of federal awards should have internal controls in place to ensure procurement practices are consistent and appropriate. Policies should dictate the method of procurement that should be used, who is authorized to approve purchases, and what procurement documentation and information should be maintained. The policy should also explain which items are eligible for non-competitive procurement (i.e., available only from a single source, public emergency, expressly authorized by awarding or pass-through agency, or if competitive procurement results are deemed inadequate). Condition: The School District did not adequately document its analysis that its technology purchases for the ESF and the Telehealth Program qualified for non-competitive procurement for being available through a single source. As a result, the School District did not have documentation to provide evidence of compliance which resulted in questioned costs. Cause: The School District did not have a formal procedure in place to adequately document the procurement procedures that were used. Effect: The School District was not in compliance with the procurement requirements of the Uniform Guidance. Questioned Costs: $1,001,167 based on the technology equipment invoice applied to the ESF and $499,768 based on the technology equipment invoice applied to the Telehealth Program. Recommendation: We recommend that the School District ensures that their purchasing policy formally reflects the procurement requirements in the Uniform Guidance. We recommend that the School District establish procedures to ensure that their purchasing policy is followed, including the use of competitive bids or proposals, when appropriate. Views of Responsible Officials and Planned Corrective Action: The School District agrees with the recommendation. However, in the beginning of the ESF program, the School District had to act fast to ensure that they could provide the necessary technology to its students. Supply of such equipment was low and the School District had to purchase items that were available in the necessary timeframes for the school year. The School District's management id informally review, justify, and approve all purchases made with ESF and Telehealth funds. Going forward, the School District has recognized its need to enhance its purchasing procedures and will be reviewing its purchasing policy to ensure that it is in compliance with the requirements. Furthermore, the Business Office will ensure that the purchasing policy is followed for all purchases, especially those made through federal programs. These improvements will be in place in advance for the start of fiscal year 2024.

View of Responsible Officials and Planned Corrective Action: EC3 agrees with the recommendation of its auditor, Maher Duessel, that the EC3 Finance Department must ensure that EC3 follows the approved and compliant purchasing practices. However, in the beginning, the College was still in a start-up mode and most of its essential purchases from Vendors could not meet EC3?s aggressive timetable to get the College up and running. So being practical, the College needed to act fast to get its provisions in place to get the College up and running, and although this was an informal process, the Management team diligently reviewed, justified, and approved all the purchases based on the supporting documentation. As of August 2022, the Finance Department has recognized the lack of internal control over the financial purchasing process and has informally enforced the purchasing policy. The Finance Department will be reviewing all EC3 financial policies, including its purchasing policy and will be making recommendations to the EC3?s Cabinet and Board of Trustees. The Finance Department will and must enforce the purchasing policy, once approved, update the policy online and ensure the policy is followed by EC3 staff and its compliant with the Commonwealth of Pennsylvania Policies.