Corrective Action Plans

March 10, 2023 Federal Audit Clearinghouse Re: Corrective Action Plan for Community Action Partnership of Mercer County To whom it may concern: Views of Responsible Officials and Planned Corrective Actions: 2022-01 There is no disagreement with the audit finding regarding our procurement policies and the lack of documentation in the Weatherization file that was reviewed. The Organization will review the Procurement policies and make necessary adjustments to how we acquire services from contractors and what the thresholds are. We will also be reviewing our documentation policies in Weatherization and making the adjustments to what documents go into the consumer file. Employee Responsible for Corrective Action: Michelle Clarke Completion Date: May 31, 2023 Respectfully Submitted, Michelle Clarke VP/CFO

FINDING 2022-003 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: The Director of Food Service and Assistant Director of Food Service will review the SAM Exclusions prior to entering a financial agreement with the vendor. The Child Nutrition Secretary will review all claims to ensure no contractors are subject to non-procurement debarment suspension are used. The acquisition threshold will be monitored for all vendors by the Director of Food Service and Assistant Director. Formal bid process and awarding of contracts will be followed as federal regulations required. ANTICIPATED COMPLETION DATE: March 2023

Responsible Contact Person(s): Melinda Raines, Director of Human Resources Karen Holt, Human Resources Business Process Consultant Corrective Action Planned: Corrective Action Plan: In 2018, the Virginia Department of Social Services (DSS) implemented written procedures to administer the Conflict of Interests Act (COIA) as outlined in the Code of Virginia. While an SOEI policy was not created, the procedures were clear, documented, and administered. DSS continues to refine its written procedures and correct identified deficiencies to meet compliance with the COIA. In January 2022, DSS began the process to have oversight responsibility for the COIA reassigned to another Human Resources (HR) unit. HR continues to evaluate and update the approach used to identify and track employees in a position of trust upon hire or change in responsibilities. Prior to the annual disclosure process the SOEI coordinator will review positions against Executive Order 18 (2022) to confirm positions within the agency that are designated as positions of trust. Division directors from various areas will be consulted with to determine if any positions involving contracts, licenses, audits, budgets, policy, or grants should be designated in a position of trust. Team members from HR will review the designation list and any additions or removals from the prior year will be updated in the economic interest field in the statewide accounting system. To capture new hires and transfers in a position of trust throughout the year, the SOEI coordinator will review the new hire and transfer report for the agency twice per month. When a new hire or transfer is moving into a position of trust the employee?s information will be added into the Conflict of Interest Disclosure System. Notifications will be sent requesting the disclosure form is completed on or prior to the employee?s start date. The system will be monitored to track progress of completion. Should the employee not complete the financial disclosure, the employee?s supervisor will be notified. When new employees in a position of trust receive access to the Commonwealth of Virginia Learning Center (COVLC), they are enrolled into the conflict of interest (COI) training and provided a deadline for completing the course. The SOEI coordinator will monitor the COVLC system for completion. Should the employee not complete the orientation training, the employee?s supervisor will be notified. To improve monitoring and tracking of COI training every two years, a spreadsheet will be maintained listing training completion dates. The report will be monitored on the same schedule as the new hire and transfer report. The spreadsheet will flag a filer?s record when the most recent training date approaches the two year mark and needs to be retaken. HR will then enroll the employee in the COI training, notify the employee and the employee?s manager of the training requirement, and monitor for completion. Reassigning oversight of the COIA to another HR unit and following the updated written procedures should show considerable improvement and compliance with the agency?s monitoring of the COIA by April 1, 2024. Estimated Completion Date: 4/1/2024

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

FINDING 2022-001 Contact Person Responsible for Corrective Action: Brian Leitch, Chief Finance & Operations Officer / Treasurer 260-347-2502 ext.: 10017 Roger Urick, Interim Food Service Director 260-347-2502 ext.: 10011 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement: East Noble School Corporation will attempt to solicit (3) quotes for purchases between $10,000 and $150,000. In the event we are unable to acquire the (3) quotes we will document our attempt and state the reason for which vendor we select. Suspension and Debarment: For any contract in excess of $25,000 we will solicit information from said vendor stating, ?They are not suspended or debarred from receiving Federal Funds?. This will be included in the contract or requested to be with the quote. Anticipated Completion Date: April 2023

Finding #2022-002 - Major Federal Award Finding - Procurement and Suspension and Debarment. Material Weakness in Internal Controls over Compliance Corrective Action Plan: Revise the current procurement policy to include federal regulations 2 CFR Section 200.317-200-326 per the thresholds in CFR 200.320. The revised policy will be reviewed with managers responsible for procurement that could potentially exceed these thresholds. A procedure will be drafted and implemented to guide managers responsible for procurement in the required procurement process based on dollar thresholds and allowable methods described in CFR 200.320. Oversight of the procurement process will be the responsibility of the EVP of Operations and the Director of Finance & Accounting.

FINDING 2022-003 Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number: 812-443-4461 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: When appropriate, the Food Services Director will employ a minimum three vendor rotation for Micro Purchases, and use effective reasoning when applicable. Director of Human Resource will review the use of these vendors on an ongoing basis. For intermediate purchases between $10,000 and $150,000, the Asst. Food Services Director will solicit at least three quotes. Once a vendor is selected, a contract will be executed and signed by the Asst. Food Services Director and the Director of Human Resources or another designated Director. For purchases over $150,000, formal bidding procedures including proper advertising and formal Board of Trustees approval. Once a vendor is selected by the Board of Trustees a contract will be executed and signed by the Asst. Food Services Director and the Director of Human Resources or another designated Director. Anticipated Completion Date: August 1, 2023

Finding Number 2022-001 Planned Corrective Action The county administration wholeheartedly agrees that the finance staff should receive government specific accounting training. Finance department personnel will attend Government Finance Officers Association (GFOA) as provided by the Oregon chapter of GFOA. Finance personnel will also attend the annual Caselle user?s conference. Additionally, when GASB specific training is offered, Curry County personnel will attend as workshops become available. Anticipated Completion Date December 31, 2023 Responsible Contact Person Frank Jerome, Finance Director Finding Number 2022-002 Planned Corrective Action Curry County updated its procurement policy January 2023 to conform with procurement standards and establish internal controls. Anticipated Completion Date January 1, 2023. Responsible Contract Person. Anthony Pope, County Counsel.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Karen Scalf, Chief Financial Officer Contact Phone Number: (765)973-3406 Views of Responsible Official: Richmond Community Schools agrees with this finding as this information was unknown and the purchases made were at separate times throughout the year, were cumulative totals, and were due to unexpected equipment breakages. Suspension and Debarment and appropriate contractual controls are important to RCS and routine internal controls are in place. The one sample noted was verified in INBiz at the Indiana Secretary of State?s office as we were unaware that only Sam.gov was permissible as the verification tool. It is routine practice for RCS to verify both areas, however documentation did not exist for the Sam.gov check on this particular sample during the audit period. Description of Corrective Action Plan: The Chief Financial Officer will review with the Business Office and RCS Administrators the necessity for Suspension and Debarment compliance as well as the appropriate processes. Vendors will be checked in Sam.gov prior to any new acceptance of vendors and any new receipt of W-9 Forms. Verifications of this check will be screen prints of the Sam.gov page, dates, and initials of the employee who verified Sam.gov. Vendors who are not in good standing and are not active in Sam.gov will not be accepted for transaction in any federal fund. RCS will also try our best to coordinate contracts with vendors on purchases between $50,000 and $150,000 during the budget year. These contracts may be approved after the purchase as purchases such as this occur due to unexpected breakages or emergencies. Anticipated Completion Date: April 7, 2023

Finding 2022-003 Contact Person Responsible for Corrective Action: Jennifer Anderson, Student Services/Special Education Director. Contact Number: 812-876-6325 View of the Responsible Official: Richland-Bean Blossom C.S.C. concurs with finding 2022-003. Description of Corrective Action Plan: The School Corporation will develop Internal Control procedures over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The School Corporation will develop and maintain an effective internal control system, which would include segregation of duties and would ensure compliance with requirements related to the grant agreement as well as following compliance requirements for Procurement and Suspension and Debarment. The School Corporation will have a control in place to ensure that proper procurement requirements regarding the Small Purchases threshold are met. The School Corporation will retain the appropriate amount of quotes needed and document if there is a unique situation with a vendor where quotes cannot be received. This information will be reviewed and implemented by the Corporation Treasurer, Student Services/Special Education Director or another authorized staff member. Anticipated Complete Date: Implementation of Corrective Action Plan will be set in places as of March 2023.

Corrective Action Planned: The Village of Clearwater, Nebraska's management and Village Board will work on developing formal written procedures for procurement, suspension and debarment transactions. Additionally, the Village will adopt written standards of conduct covering conflicts of interest.. Anticipated Completion Date: Continuous. Responsible: Management and Village Board.

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 followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. These procedures will help ensure compliance with Compliance 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: Management will create a formal, written procurement policy. Management will also review the noncompetitive procurement procedures and will document how and why our vendor(s) meets these requirements, if applicable. Additionally, HTHF will improve internal processes increasing the foundation?s work with our accounting support staff moving to a monthly service from quarterly with expenses entered into QuickBooks each month. Once expenses are entered, they will be reviewed by management and by the board treasurer. Name(s) of the contact person(s) responsible for corrective action: Joseph Holmes Planned completion date for corrective action plan: 10/31/23

FINDING 2022-004 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure that all micro-purchases of $10,000 or less have the appropriate documentation and quotes required by Federal guidelines along with any purchases above the given thresholds based on procurement regulations. Documentation of quotes, bids, or contracts will be maintained by the GCSC Food Service manager and approved by the CFO for accuracy and completeness. A policy and procedure will be created to ensure that supporting documentation is received from the food service vendor that corresponds to any discounts or rebates received and are reflected appropriately in the billing reports. The GCSC Food Service manager will review documentation for billing accuracy prior to claims being paid and approved by the CFO. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

Finding No. 2022-006 ? HEERF Procurement Finding: During fiscal year 2022 certain costs were incurred above the micro-purchase level where there was no evidence of competitive bids received or documentation. Corrective Action Taken or Planned: The purchase noted was related to COVID testing and supplies provided by the Broad Institute. Management determined that this met the requirements of a specialty purchase, however, failed to document approval for the exception. New management is aware of this requirement for federal funds and will ensure compliance in the future. The Controller will be responsible to ensure compliance. Completed March 2023. Responsible person Richard Bowman, Controller

RE: Finding 2022-001: Internal Control over Compliance The following is the Corrective Action Plan (CAP) related to the noted finding. Corrective Action Plan Agency: Colorado Department of Education Audit Period: FY21-22 Audit Finding Number: 2022-001 Audit Finding Title: Internal Control over Compliance Specific Steps to be Taken: Mountain BOCES currently utilizes a mostly decentralized purchasing system. Improved documentation and trainings relating to procurement policies and procedures as well as increased internal controls were put into place during the second half of 2022 and will continue in 2023. Mountain BOCES has been re-writing these policies to include required language and alignment with 2CFR ?? 200.317 through 200.327, particularly the requirements discussing the allowable procurement methods, dollar thresholds, and the requirements for each allowable method. The procurement policy is undergoing a major rewrite in 2023 by the Executive Director and newly hired Business Manager to ensure sufficient internal controls and overall improved efficiencies. Anticipated Completion Date: Ongoing Name(s) and Title(s) of Contact Person Wendy Wyman Executive Director responsible for Correction Action: If you should have any questions or comments, please do not hesitate to contact me at wwyman@mtnboces.org.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Katie King, Director of Child Nutrition Contact Phone Number: 812-866-6254 Contact Email: kking@swjcs.us Views of Responsible O?cial: We concur with this audit finding. Description of Corrective Action Plan: Action taken in an e?ort to remedy finding 2022-007 includes, but is not limited to, the following: ? Informal procurement methods (small purchase procedures) will be followed for any purchases made by, or on behalf of, the Nutrition Services Department exceeding $10,000.00 up to $150,000.00. Quotes from at least three qualified vendors/contractors will be required. Any purchases made on behalf of the Nutrition Services Department (for example, Maintenance contracting work for kitchen appliance repairs) will need prior approval from the Director of Child Nutrition. ? Wilson Education Center was not an approved co-op for school year, 2020-2021, but was retroactively approved to be a co-op for school year 2021-2022. Therefore, the correction has been made. Anticipated Completion Date: February 1, 2023

CRITERIA: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients ?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? 2 CFR section 200.318(i). The Center?s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The Center also has procedures to identify procurement transactions requiring competitive bids or proposals. RECOMMENDATION: We recommend the Center ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. CORRECTIVE ACTION PLAN: The Center will review its procurement policies and internal control and ensure timely action is taken when noncompliance is identified. PERSON RESPONSIBLE: Laci Herbst, Finance Department TIMELINE: Current date through succeeding reporting period.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Stephanie Haynes- Clifford, Food Service Director Contact Phone Number: 260 665 2854 Extension 1202 Views of Responsible Official: 1. Procurement: The School Corporation did not obtain price or rate quotes for milk, bread, or food exceeding $10,000.00 from an adequate number of sources, as required under the small purchase procedures. 2. Suspension and Debarment: The School Corporation did not verify that vendors with contracts over $25,000.00 were not excluded or disqualified from participation in federal award programs. Description of Corrective Action Plan: 1. Food Service will maintain additional prices for like items and/or services. Documentation will be maintained regarding why each vendor is being utilized. Said documentation will be reviewed, initialed and dated by the Food Service Director and an additional staff member. 2. Food Service will maintain annual vendor certificates to ensure that they were not suspended or debarred from participation in federal programs. Anticipated Completion Date: February 10, 2023

Person responsible for corrective action: County Attorney and Sheriff Corrective action planned: The County purchase policy should be followed with any expenditures exceeding $15,000. A reminder memo was sent to all offices for review. Corrective action planned: with only one SAM account for each entity, it will be the responsibility of the county offices to contact the County Clerk for verification of a vendor standing within the SAM program for federal expenditures. Anticipated completion date: August 31, 2023

CORRECTIVE ACTION PLAN Finding No. 2022-001 Procurement Federal Program: Crime Victim Assistance Assistance Listing Number: 16.575 In response to the Single Audit Finding referenced in the 2022 independent audit conducted by Donavon CPAs, Prevail will institute the following action steps to remedy the finding: ? The Interim Executive Director of Prevail, working in collaboration with Prevail?s Director of Operations, will generate a first draft of a Procurement Policy for board input and review. ? The draft will be reviewed by the Prevail Finance Committee on April 25, 2023, for input and suggestions. The Interim Executive Director will make edits in response to recommendations by the Finance Committee. ? The Procurement Plan will then be presented for board approval at the Prevail Board of Directors meeting scheduled for May 10, 2023. ? After approval, it will be the responsibility of the Director of Operations, under the oversight of the Interim Executive Director, to implement and maintain compliance with the plan. When a new Executive Director is hired, plan maintenance and compliance will become the responsibility of this role. ? On an annual basis, the Finance Committee will review the Procurement Plan to ensure Prevail maintains compliance.

The Center was unaware that, in accordance with the Department of Labor (DOL)(40 USC 3141-3144, 3146, and 3147), all laborers employed by contractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for prevailing wage rates. In the future, the Center will follow the guidance of the aforementioned section and adhere to this requirement.

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Micah Williams/Amanda Myers Contact Phone Number: 765-832-2426 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation was under the assumption that the state procurement had secured the bidding/quote information for the vendor in question. Emails were given to document the ?go ahead? from our cooperative to order from the vendor. The corporation now understands that we are responsible for obtaining quotes outside of the cooperative. Anticipated Completion Date: Implemented immediately.

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.

1. The institution does not agree, nor concurs, with the auditors on this finding because the institution used the reimbursement payment method. This method was the preferred one when the non-federal entity, as our institution, cannot meet the requirements in 2 CFR, section 200.305(b)(1) for advance payment and the federal awarding agency sets a specific condition for use of the reimbursement. Title 2 of the CFR Part 200.305(b)(1), establish among others: "The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part". Furthermore, 2 CFR Part 200.305(b)(3) states: "Reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. " Since our institution was not able to meet 2 CFR, section 200.305(b)(1), and the HEERF guidelines has specific condition on how to use the funds; we choose the reimbursement method in the execution of the funds. Our institution adopted all HEERF instructions and guidelines as their policies to comply with the HEERF requirements, in addition to the CFR's regulations. Below some of the guidelines, instructions ad FAQs we adopted followed" a. Higher Education Emergency Relief Fund III, Frequently Asked Questions, American Rescue Plan Act of 2021, Published May 11, 2021, Questions 7 and 11 updated May 24, 2021, Question 36 updated September 30, 2021 b. US Department of Education, Notice of Proposed Institutional Eligibility Criteria, February 25, 2021 c. Federal Register Notice of Interpretation (NOI), regarding Period of Allowable Expenses for Funds Administered under HEERF Program, March 22, 2021 d. HEERF Notice of Interpretation for Period of Allowable HEERF Expenses (March 22, 2021) e. HEERF Lost Revenue FAQs (March 19, 2021) f. HEERF Period of Allowable Expenses Grant Records Notice (March 19, 2021) g. HEERF Grant Program Auditing Requirements (March 8, 2021) h. CRRSAA HEERF II Section 314(a)(1) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) i. CRRSAA HEERF II Section 314(a)(2) Frequently Asked Questions (January 14, 2021) j. CRRSAA HEERF II Section 314(a)(4) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) k. HEERF I and HEERF II Comparison Fact Sheet (Published January 14, 2021 and Updated: March 19, 2021) 1. HEERF Lost Revenue FAQ's, Published March 19, 2021 m. HEERF II, Public and Private Nonprofit Institution (a)(2) Programs (CFDAs 84.425K), FAQ's, Published January 14, 2021 n. HEERF II, Proprietary Institution Grant Funds for Students (CFDA 84.425Q) ((a)(4) Program), FAQ's Published January 14, 2021, Updated March 19, 2021. o. HEERF II, Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F), FAQ's Published January 14, 2021, Updated March 19, 2021. p. CAREST Act HEERF Rollup FAQs (issued October 14, 2020 and revised November 20, 2020) q. CARES Act HEERF Round 3 FAQs (Issued October 14, 2020 and revised November 20, 2020) r. CARES Act HEERF Supplemental FAQs (Issued June 30, 2020 and revised September 08, 2020) s. CARES Act HEERF Student FAQ's (Issued May 15, 2020) t. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) u. CARES Act HEERF Emergency Financial Aid Grants to Students under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) v. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, Issued April 9, 2020 w. COVID-19 FAQ's for Title III, IV, V and VII Grantees, June 16, 2020 x. COVID-19 Letter to HEP Grantees on Flexibilities Available Under CARES Act Section 3518, July 1, 2020 2. The institution does not agree, nor concurs, with the auditors on this finding because, as we mention in number 1 above, the institution adopted and followed the federal award and HEERF guidelines in the execution of the funds. The HEER funds were provided during the special national emergency caused by COVID-19. The DOE and HEERF officials issued many written guidelines, instructions, and FAQ's (Frequently Asked Questions) documents, due to the nature and novel of the national emergency situation. The institution adopted, followed, and relied on the many referenced guidelines and exercise extreme judgment to ensure compliance with the federal requirements and use of the funds. The institution belief this referenced guidelines and instruction were very specific and sufficient to execute the use of the funds. All direct charges to federal awards were for allowable costs under the guidelines and instructions from the Department of Education. Some of the allowable costs were verified and validated by an officer of the Department of Education and reviewed by an independent consultant. 3. The institution concurs with the auditor finding. Actions Taken or Planned: The institution begins in addition to the adopted HEERF guidelines, instructions, and CFRs; to develop additional procurement policies and are in the process of completing those policies. The institution expects to have those completed by May 31, 2023.

Finding Number: 2022-002 Planned Corrective Action: The District is currently working with OSBA to update the policies and policy DJC states ?If feasible, all purchases over $20,000 and not otherwise subject to required federal or state bidding requirements will be based on price quotations submitted by at least three vendors.? The Treasurer and Business Manager will ensure that policy is followed when applicable. Anticipated Completion Date: October 31, 2023 Responsible Contact Person: Muata Niamke, Business Manager and Taylor Friedrich, Treasurer/CFO