Corrective Action Plans

FINDING 2022-005Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 ? School Breakfast Program, National SchoolLunch Program, COVID-19 ? National School Lunch Program, Summer Food Service Program, COVID-19 ?Summer Food Service ProgramALN Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersContact Person Responsible for Corrective Action: Chad Yencer - SuperintendentContact Phone Number: 765-348-7550Views of Responsible Official: We concur with this findingDescription of Corrective Action Plan:BCS has established the following internal controls to ensure compliance:1. Internal Control: When a purchase is made at $10,000 or more using Federal Funds, thesuperintendent will require that any vendors selected are in compliance with theProcurement and Suspension and Debarment compliance requirement by completing one ofthe following quality checks with each vendor prior to purchase:a. Checking the federal System for Award Management (SAM) database athttps://sam.gov/content/exclusions and maintain a screenshot of the search results.b. Collect a certification from the vendor directlyc. Add a clause or condition to the covered transaction with the vendorAnticipated Completion Date:This corrective action will be implemented and completed immediately with any purchase made that meets theabove threshold.

FINDING 2022-001Contact Person Responsible for Corrective Action: Mayor Terry AmickContact Phone Number: 812-752-3169Views of Responsible Official: I concur with the findings.Description of Corrective Action Plan: The City plans to review existing policies and procedures andmake any needed changes to endure that they are in compliance with the federal compliancerequirements for procurement as well as suspension and debarment. Furthermore, controls will beestablished to ensure that the City?s policies related to compliance with the federal compliancerequirements for procurement as well as suspension and debarment are followed.Anticipated Completion Date: December 31, 2023

Program: Continuum of Care, Emergency Solutions Grant Program Federal Financial Assistance Listing No.:14.267, 14.231 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward, Sacramento County Department of Human Assistance Award Year: 2022 Compliance Requirement: Procurement, Suspension and Debarment Grant Award Number: CA0955L9T032007, CA0955L9T032108, CA0143L9T032013, CA0143L9T032114, CA1303L9T032006, CA1303L9T032107, DHA-PRTS-NM-06-22, DHA-NM-03-22, DHA-NM-03-23, DHA-NM-08-23, DHA-NM-10-23 Finding Summary: The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Management’s Response: We concur. Views of Responsible Officials and Corrective Action: • Management will update policies and procedures to ensure they confirm to the Uniform Guidance regarding procurement, suspension and debarment (2 CFR 200.317 through 200.327, 2 CFR 180). • Train grant staff on new policies and procedures. Name of Responsible Person: Bryan Wagner, CFO Projected Implementation Date: December 31, 2024

Planned Corrective Action: Team Rubicon will institute policies and procedures to ensure compliance with applicable procurement guidelines when accepting federal awards. These will include prohibition against contracts which could be influenced by a perceived or actual conflict of interest, documentation of a search for suspended and debarred parties, and guidelines for approved methods of procurement (including specific situations where noncompetitive procurement may be appropriate, and documentation to be required if so).

Action Taken: Range Mental Health Center, Inc. and Subsidiaries will adopt a documented procurement policy consistent with the standards of 2 CRF section 200.317 through 200.320 to use procurement of the acquisition of property or service required under federal awards or sub-awards.

Finding 2022-003 Procurement The auditors recommended the following: 4. Management adhere to its written policy and maintain documentation to support all management decisions related to federally funded procurements to comply with federal regulations. SDA should consider creating a checklist form to document its procurement decisions and related approvals, as required. Also, we recommend SDA develop procedures to identify federally funded contracts let/awarded during the fiscal year. Context Two contracts were identified that required documentation to validate that the entire RFQ process from RFQ formulation to advertisement to receipt and evaluation were completed. One of the said contracts could not provide the backup documentation to validate that the evaluation process had been completed. There was no evidence that debarment/suspension verification checks were performed prior to awarding the contract. Staffing Corrective Actions In September 2023, SDA hired a permanent Director of Business Growth Services with experience in federal grant funding. In November 2023, SDA hired a permanent Director of Finance and Administration for additional support in management and oversight. Both Directors are responsible for overseeing procurement processes and reviewing documentation of the process. Process Corrective Actions The SDA has created a checklist and training materials on procurement processes and decisions. Mandatory training sessions for Program Directors and other appropriate staff will be held to ensure that the guidelines are understood. All procurement decisions and information will be filed in the password protected e-filing system. Policy Corrective Actions The SDA maintains active written policies on procurement that adhere to federal guidelines. In June of 2023, the SDA board approved an enhancement of the SDA Fiscal Policy to make the procurement policy more accessible to all members of the organization. The Director of Finance and Administration will continue to conduct periodic quality compliance checks to ensure that all procurement follows SDA policy. All procurement decisions and information will be filed in the e-filing system, Google Drive.

Coronavirus State and Local Fiscal Recovery Funds- Assistance Listing No. 21.027 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followeed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures will help ensure compliance ith Compilance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: there is no disagreement with the audit finding. Action taken in response to finding: The Organization will develop a written procurement policy and will develop controls to monitor when expenses approach the various procurement thresholds to help us complete the appropriate procurement procedures in compliance with out policy. Name(s) of the contact person(s) responsible for corrective action: Frank Caruso, Director of Finance and Operations. Planned completion date for corrective action plan: Sarted in January 2024. If the the U.S. Department of the Treasury has questions regarding this plan, please call Frank Caruso, Director of Finance and Operations at (602) 241-4645.

2022-009: Significant Deficiency and Noncompliance – Procurement Documentation Statement of Condition/Criteria: Delta County is not following its procurement policy and is therefore not meeting the requirements of 2 CFR section 200.318 to use documented procurement procedures. The County does not have controls in place to ensure that written records are maintained sufficient to detail the history of procurement including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Planned Corrective Action: County management will develop control to ensure the procurement policy is followed. Contact person responsible for corrective action: Ashleigh Young, County Controller/Administrator Anticipated Completion Date: March 2024

Finding No. 2022-014 Area: Procurement, Suspension and Debarment Views of Auditee and Planned Corrective Action Condition 1 17 (or 28%) transactions totaling $3,281 pertained to small purchases not exceeding $500 and for which no price quotations were made. No evidence was provided showing that a written determination of the reasonableness of price was performed in accordance with § T60-40-210(b). We disagree. Based on existing Public School System Procurement Rules and Regulations, the Public School System through the Finance department strongly maintains that the Commissioner of Education, being the chief state school superintendent and the Chief of Procurement and Supply, are vested with the determination authority in all Procurement and Supply matters, among others. Such affirmation is further articulated in the Public School System's October 30, 2023 letter to Ernst & Young, LLP Executive Director James N. Whitt, that, among others and in particular, as cited in Part T60-40-210(b) 2: “Expertise and Authority of the Chief: The Chief of Procurement and Supply possesses specific and comprehensive experience in the procurement of goods. We argue that their signature is not merely an administrative formality but a professional endorsement of the price’s reasonableness. “ Condition 2 2 (or 3%) transactions totaling $1,824 pertained to procurements entered into by competitive sealed proposals. No evidence was provided showing that the Commissioner of Education has determined in writing that the procurement satisfies the condition for use of competitive sealed proposals in accordance with § T60-40-225(a). We disagree. Based on existing Public School System Procurement Rules and Regulations, the Public School System through the Finance department strongly maintains that the Commissioner of Education, being the chief state school superintendent and the Chief of Procurement and Supply, are vested with the determination authority in all Procurement and Supply matters, among others. Such affirmation is further articulated in the Public School System's October 30, 2023 letter to Ernst & Young, LLP Executive Director James N. Whitt, that, among others and in particular, as cited in the following under: Part T60-40-225(a): Interpreting Rule Language: The rule explicitly requires the Commissioner of Education to determine "in writing" upon the advice of legal counsel when the use of competitive sealed bidding is not practical or advantageous. However, it doesn't prescribe a specific form or extent of justification needed. Commissioner's Signature as Written Determination: We believe that the Commissioner's signature on a cover letter stating that competitive sealed proposals will be used fulfills the "in writing" requirement. The signature, in this context, serves as an acknowledgment that the Commissioner has considered the matter and found it advantageous to PSS. Subjectivity of 'Advantageous': The rule leaves room for interpretation by using the term "advantageous," which is inherently subjective. Since it does not stipulate the need for detailed justification, the Commissioner’s decision that the method is advantageous should suffice. Legal Counsel's Role: The regulation specifies that the determination should be made "upon the advice of legal counsel." It can be inferred that this due process has been followed if the Commissioner signs a letter or document related to competitive sealed proposals, thereby adding another layer of checks and balances. Presumption of Expertise: As the Commissioner of Education, it is presumed that the individual is capable of making informed decisions that are in the best interest of PSS. Their signature, therefore, carries the weight of their expertise and authority. Anticipated Completion Date: N/A Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

Finding No. 2022-013 Area: Procurement, Suspension and Debarment Views of Auditee and Planned Corrective Action Condition 1 7 (or 12%) transactions totaling $1,355 pertained to small and for which no price quotations were made. No evidence was provided showing that a written determination of the reasonableness of price was performed in accordance with § T60-40-210(b). We disagree. Based on existing Public School System Procurement Rules and Regulations, the Public School System through the Finance department strongly maintains that the Commissioner of Education, being the chief state school superintendent and the Chief of Procurement and Supply, are vested with the determination authority in all Procurement and Supply matters, among others. Such affirmation is further articulated in the Public School System's October 30, 2023 letter to Ernst & Young, LLP Executive Director James N. Whitt, that, among others and in particular, as cited in Part T60-40-210(b) 2: “Expertise and Authority of the Chief: The Chief of Procurement and Supply possesses specific and comprehensive experience in the procurement of goods. We argue that their signature is not merely an administrative formality but a professional endorsement of the price’s reasonableness. “ Condition 2 18 (or 30%) transactions totaling $104,603 pertained to procurements entered into by competitive sealed proposals. No evidence was provided showing that the Commissioner of Education has determined in writing that the procurement satisfies the condition for use of competitive sealed proposals in accordance with § T60-40-225(a). Further, Notices of Intent to Award were not provided for the reason that there was only one proposer. § T60-40-225(g) does not discuss about exemptions for instances where there is only one proposer. We disagree. Based on existing Public School System Procurement Rules and Regulations, the Public School System through the Finance department strongly maintains that the Commissioner of Education, being the chief state school superintendent and the Chief of Procurement and Supply, are vested with the determination authority in all Procurement and Supply matters, among others. Such affirmation is further articulated in the Public School System's October 30, 2023 letter to Ernst & Young, LLP Executive Director James N. Whitt, that, among others and in particular, as cited in the following under: Part T60-40-225(a): Interpreting Rule Language: The rule explicitly requires the Commissioner of Education to determine "in writing" upon the advice of legal counsel when the use of competitive sealed bidding is not practical or advantageous. However, it doesn't prescribe a specific form or extent of justification needed. Commissioner's Signature as Written Determination: We believe that the Commissioner's signature on a cover letter stating that competitive sealed proposals will be used fulfills the "in writing" requirement. The signature, in this context, serves as an acknowledgment that the Commissioner has considered the matter and found it advantageous to PSS. Subjectivity of 'Advantageous': The rule leaves room for interpretation by using the term "advantageous," which is inherently subjective. Since it does not stipulate the need for detailed justification, the Commissioner’s decision that the method is advantageous should suffice. Legal Counsel's Role: The regulation specifies that the determination should be made "upon the advice of legal counsel." It can be inferred that this due process has been followed if the Commissioner signs a letter or document related to competitive sealed proposals, thereby adding another layer of checks and balances. Presumption of Expertise: As the Commissioner of Education, it is presumed that the individual is capable of making informed decisions that are in the best interest of PSS. Their signature, therefore, carries the weight of their expertise and authority. Anticipated Completion Date: N/A Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

Finding No. 2022-012 Area: Procurement, Suspension and Debarment Views of Auditee and Planned Corrective Action Condition 1. 2 (or 3%) transactions totaling $26 identified as doc nos. 333590 and 28221 pertained to small purchases not exceeding $500 and for which no price quotations were made. No evidence was provided showing that a written determination of the reasonableness of price was performed. We disagree. Based on existing Public School System Procurement Rules and Regulations, the Public School System through the Finance department strongly maintains that the Commissioner of Education, being the chief state school superintendent and the Chief of Procurement and Supply, are vested with the determination authority in all Procurement and Supply matters, among others. Such affirmation is further articulated in the Public School System's October 30, 2023 letter to Ernst & Young, LLP Executive Director James N. Whitt, that, among others and in particular, as cited in Part T60-40-210(b) 2: “Expertise and Authority of the Chief: The Chief of Procurement and Supply possesses specific and comprehensive experience in the procurement of goods. We argue that their signature is not merely an administrative formality but a professional endorsement of the price’s reasonableness. “ Condition 2. 2 (or 3%) transactions totaling $739 identified as Doc Nos 332318 and 332718 pertained to small purchases not exceeding $10,000 and for which no price quotations were obtained. We disagree. Price quotations for Document Nos 332318 and 332718 were provided to the Ernst & Young audit team. Condition 3. 1 (or 2%) transaction amounting to $575 identified as Doc. No. 27345 pertained to a small purchase not exceeding $10,000 and for which only 2 price quotations were obtained, instead of the 3 quotations required by § T60-40-210(d). We disagree. Doc No. 27345 price quotations were provided to the Ernst & Young audit team. Condition 4. 43 (or 72%) transactions totaling $245,856 were procured through competitive sealed proposals. No evidence was provided showing that the Commissioner of Education has determined in writing that the procurement satisfies the condition for use of competitive sealed proposals in accordance with § T60-40-225(a). We disagree. Based on existing Public School System Procurement Rules and Regulations, the Public School System through the Finance department strongly maintains that the Commissioner of Education, being the chief state school superintendent and the Chief of Procurement and Supply, are vested with the determination authority in all Procurement and Supply matters, among others. Such affirmation is further articulated in the Public School System's October 30, 2023 letter to Ernst & Young, LLP Executive Director James N. Whitt, that, among others and in particular, as cited in the following under: Part T60-40-225(a): Interpreting Rule Language: The rule explicitly requires the Commissioner of Education to determine "in writing" upon the advice of legal counsel when the use of competitive sealed bidding is not practical or advantageous. However, it doesn't prescribe a specific form or extent of justification needed. Commissioner's Signature as Written Determination: We believe that the Commissioner's signature on a cover letter stating that competitive sealed proposals will be used fulfills the "in writing" requirement. The signature, in this context, serves as an acknowledgment that the Commissioner has considered the matter and found it advantageous to PSS. Subjectivity of 'Advantageous': The rule leaves room for interpretation by using the term "advantageous," which is inherently subjective. Since it does not stipulate the need for detailed justification, the Commissioner’s decision that the method is advantageous should suffice. Legal Counsel's Role: The regulation specifies that the determination should be made "upon the advice of legal counsel." It can be inferred that this due process has been followed if the Commissioner signs a letter or document related to competitive sealed proposals, thereby adding another layer of checks and balances. Presumption of Expertise: As the Commissioner of Education, it is presumed that the individual is capable of making informed decisions that are in the best interest of PSS. Their signature, therefore, carries the weight of their expertise and authority. Anticipated Completion Date: N/A Name of Contact Person and Title Contact Person – Arlene Lizama, Director of Finance Contact – arlene.lizama@cnmipss.org

Finding 2022-006: Procurement, Suspension, and Debarment – Material Weakness. The buying policy ordering process has been updated to include blocking GSA (Government Services Administration) & HHS (Health & Human Services) disbarred sellers in accordance with SAM (System of Award Management) system. The overall Procurement policy, contracts and forms will be updated to include suspension and debarment language.

The Treasurer, Town Manager and Select Board will take the following actions to address finding 2022-004: The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted a new Procurement Policy that addresses this deficiency. This policy was approved and implemented by the Select Board at their January 23, 2024 meeting.

FINDING 2022-002 Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchases were followed. There was no oversight, review, or approval process in place and documented at the School Corporation to ensure proper procedures were followed and price or rate quotations were obtained, or documentation to support limited procurement procedures conducted. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000 per Indiana Code. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micropurchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for the five vendors tested that was less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micropurchase threshold. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. The School Corporation also did not follow procurement requirements for contracted services which exceeded the simplified acquisition threshold of $150,000. The School Corporation did not correctly procure a contract for the one vendor that exceeded the simplified acquisition threshold. Additionally, the School Corporation did not adequately maintain documentation of the procurement history or rationale. Finally, the School Corporation did not verify that this vendor was not excluded or disqualified from participation in federal assistance programs or activities. Contact Person Responsible for Corrective Action: Matthew Miles, CFO Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will obtain 3 quotes or do a bid process in the future. If there is limited availability, we will document the reason 3 quotes are not possible. Additionally, the District INDIANA STATE BOARD OF ACCOUNTS 34 will check for suspension and debarment, create a write-up of our findings, and obtain Board approval for the contract. Anticipated Completion Date: The School District will implement changes described in the Corrective Action Plan February in 2024.

2022-005 Significant Deficiency in Controls over Compliance: Administrative Requirements of Uniform Guidance-Administrative Policies The schools have documented their administrative policies effective 3/1/2023.

Rural eConnectivity Pilot Program ? Assistance Listing No. 10.752 Recommendation: We recommend the Commission establish and document procurement policies and procedures in conformity with the Federal requirements ?? 200.317 through 200.327. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will adopt a written procurement policy in accordance with the federal requirements. Since the inception of the Rural eConnectivity program, the Commission has followed the Town of Easton Charter Article IV, Section 2(e) when contracting with third party vendors. The Commission now recognizes compliance with the Charter does not satisfy the necessity for a separate procurement policy to fulfill federal requirements. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: April 30, 2023

Finding 2022-01 Federal Program Title: Education Stabilization Fund ?Higher Education Emergency Relief Fund Compliance Requirement: Procurement, Suspension and Debarment Name of Contact Person: Lynn Feeken, Financial Controller Corrective Action: The College developed and implemented a procurement policy which addressed Uniform Guidance Procurement, Suspension and Debarment requirements. Date of Completion: January 5, 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Sue Hart Contact Phone Number: 812-752-8921 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Each vendor who has received payment from the school district from federal Child Nutrition funds, or is expected to in the future, shall be required to have at least one of the following filed with the school district each year: 1) SAM Exclusions without the vendor being listed as excluded or disqualified; or, 2) Certification of the vendor not being excluded or disqualified; or, 3) Including a clause or condition on any and all contracts or invoices confirming the vendor is not excluded or disqualified. The Director of Food Services shall maintain files with evidence of the above documentation and it shall be updated at least annually and no fewer than once per calendar year. In addition, the Director shall ensure price or rate quotes are acquired from all vendors the Director reasonably expects to pay more than the micro-purchase threshold and contracts shall be executed with vendors when purchases are between $50,000 and $150,000. Such contracts shall also be Board approved with copies uploaded to the Gateway system for ease of access by SBOA or the district in the future. Anticipated Completion Date: June 2023

REFERENCE # 2022-001 PROCUREMENT SUSPENSION AND DEBARMENT ? MATERIAL WEAKNESS- NON-COMPLIANCE Program Name/ALN Emergency Solutions Grant Program (ALN # 14.231) Criteria: As per ? 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition/Context: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR ? 200.318 General procurement standards. We selected two (2) vendors for procurement Suspension and Debarment compliance testing of total population of 2 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: ? To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. ? To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Questioned Costs: Cannot be determined Recommendation: We recommend that the Division must: (1) document procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. (2) The Division?s documented procurement procedures must conform to the procurement standards identified in ?? 200.318 through 200.327. . Corrective Action Plan: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. Step 1 Action Date: Ongoing Final Implementation Date: 9/30/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

FINDING 2022-002 Contact Person Responsible for Corrective Action: Greg Hopkins Contact Phone Number: 812-967-3926 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Small Purchases The Food Service Director of the local School Food Authority will work with the Food Service Management Company to ensure all items purchased are procured properly using the correct thresholds set by the state and federal government. Suspension and Debarment The Corporation is now contracted with a Food Service Management Company (Aramark). The Food Service Director reviews all agreements/contracts related to Food Service to ensure that they meet the requirements related to suspension and debarment. Once contracts/agreements are reviewed, the Food Service Director signs off. Anticipated Completion Date: Effective Immediately

2022-001 Higher Education Emergency Relief Funds ? ALN 84.425F Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment. In addition, We also recommend a supervisor review the documentation prior to payment as a second review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For previously incurred expenses that later fall under the reimbursement guidelines of a Federal or State Grant, the University will review and insure any expenses we submit for reimbursement are verified through our grant procurement policy controls and if the vendor is suspended or disbarred. Name(s) of the contact person(s) responsible for corrective action: John Greentree, Controller Planned completion date for corrective action plan: Completed as of September 2022

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT SIGNFICANT DEFICIENCY/COMPLIANCE 2022-01 Procurement Policies and Procedures Recommendation: Quotes should be obtained whenever possible when purchases are expected to be between $10,000 and $250,000. If purchases are to equal or exceed $250,000, the proper bidding procedures should be followed. Bidding procedures, quotes, and efforts to give preference to minority or women-owned businesses should be documented, including documenting if bids or quotes could not be obtained. A procurement policy should be established as soon as possible and an individual should be assigned to monitor the implementation of the policy. Action Taken: The Organization has begun the process of establishing a procurement policy and have it completed by March 16, 2023. The Organization will also go back to purchases starting July 1, 2022, that exceeded the micro purchase threshold of $10,000 and prepare the required documentation as listed in the recommendation. This will be completed by April 30, 2023. Any purchases exceeding the micro purchase threshold of $10,000 going forward will be supported by the required documentation.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Stacie Light, Director of FNS Daniele Raber, Corporation Treasurer Contact Phone Number: 574-371-5098 ext. 2408 574-371-5098 ext. 2451 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: WCS was fully operating during a pandemic and had to do whatever it took to get products for our students and families. Although we feel we followed the proper procedures for these purchases, we will take your recommendations to make sure we're following protocol. During the pandemic, due to supply chain issues, we had to utilize vendors outside of the co-op in order to meet these needs which resulted in higher total expenditure costs for these vendors. Supply chain issues are not as prevalent as the pandemic has lessened. These purchases to outside co-op vendors are decreasing. We will do payment history checks on the vendors our Child and Nutrition program is utilizing throughout the year to ensure they are under the small purchase threshold and will receive contracts with vendors should they exceed this threshold. We will continue to follow our already established process of checking SAM.gov when new vendors are entered into our system for use. We will begin to do an annual check of vendors that our Child and Nutrition program utilizes to ensure that previously established vendors are not on the suspension or debarment listing. Anticipated Completion Date: We will begin these corrections immediately for the remainder of the school year and will more fully implement these corrections as of the beginning of the 2023-2024 school year.

2022-005 Contact Person Neil Breidenbach Planned Corrective Action The District will create and approve a procurement policy that adheres to state and local regulations as well as 2 CFR Part 200.317 through 200.327. Planned Completion Date December 31, 2023

Finding No.: 2022-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Guam Housing and Urban Development Authority AL Program: 14.231 Emergency Solutions Grants Program Area: Procurement and Suspension and Debarment Criteria: In accordance with applicable procurement and suspension and debarment requirements, the non-Federal entity must have and use documented procurement procedures, consistent with the Procurement Standards in 2 CFR ? 200.318-327, which require formal procurement methods when the procurement of goods or services exceeds the simplified acquisition threshold (i.e., $250,000). Condition: For one (or 20%) of five procurement transactions tested, aggregating $1,512K out of $1,519K in total non-payroll program expenditures, the small purchases method was used to procure rental of 40 rooms to be used as emergency shelters with an annual contract amount of $1,095K. Based on the contract amount, a formal procurement method should have been used in performing the procurement. Cause: Catholic Social Service (CSS) lacks controls over compliance with applicable procurement requirements. The procurement policy of CSS is not prepared in accordance with the Procurement Standards in 2 CFR 200.318-327, as it does not require formal procurement procedures for any transactions. Effect: CSS is in noncompliance with applicable procurement and suspension and debarment requirements. The total questioned cost is $1,095,000. Recommendation: CSS should establish and implement controls over compliance with applicable procurement and suspension and debarment requirements. CSS management should revisit its procurement policy for alignment with the Procurement Standards in 2 CFR 200.318-327. Views of Responsible Officials: CSS disagrees with the finding that CSS is in noncompliance with applicable procurement requirements cited in 2 CFR 200.318-327, resulting in a questioned cost of $1,095,000. The federal ESG-CV grant awarded to Guam Housing and Urban Renewal Authority (GHURA) to respond to the impact of COVID-19 pandemic provided waivers and alternative requirements, including greater flexibility, to establish expedited response actions to mitigate the spread of the coronavirus. Exhibit D of the sub-recipient agreement (SRA) provides for this reference of waivers and alternative requirements. Specifically, page 18 of Section III.F.8 of Exhibit D of the SRA states the following: ?8. Procurement. As provided by the CARES Act, the recipient may deviate from the applicable procurement standards (e.g., 24 CFR 576.407(c) and (f) and 2 CFR 200.317-200.326) when procuring goods and services to prevent, prepare for, and respond to coronavirus. If the recipient deviates from its procurement standards, then the recipient must establish alternative written procurement standards, and maintain documentation on the alternative procurement standards used to safeguard against fraud, waste, and abuse in the procurement of goods and services to prevent, prepare for, and respond to coronavirus. This alternative requirement is necessary to ensure the funds are used efficiently and effectively to prevent, prepare for, and respond to coronavirus. Notwithstanding this flexibility, the debarment and suspension regulations at 2 CFR part 180 and 2 CFR part 2424 apply as written.? The opening of a temporary emergency shelter for families and individuals who are homeless was deemed an emergency response to the coronavirus. CSS emphasizes that the focus of GHURA was to identify readily available units and obtain price quotations to stand up an emergency homeless shelter, and the ?small purchase method? would provide that information to expedite the procurement process. This process was communicated to GHURA, as well as outcome of surveys of available units, and recommendation for selection of site. CSS agrees on the recommendation to revisit CSS? procurement policy overall that would assure objectivity and cost efficiency in the purchase of goods and services, including aligning and/or adopting verbatim procurement requirements outlined in 2 CFR 200.318-327. Contact Person: Diana Calvo, Executive Director Expected Completion Date: September 30, 2023 for policy/procedure development.