Corrective Action Plans

FINDING 2024-003 Finding Subject: Special Education Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Marcia Fullenkamp, Treasurer Contact Phone Number and Email Address: (812) 623-2212; mfullenkamp@rodspecialed.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ROD Special Education Cooperative will make notes in the Board Minutes regarding the fact that only one vendor can provide specific services prior to entering into a contract or purchasing said services. Each company providing services will be checked on the SAM.gov website to ensure that the vendor has not been suspended or debarred. Anticipated Completion Date: February 1, 2024

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, DIRECT ALLOCATION; GRANT No. AM-22-0072 Name of Contact Person: Stacey Amundson Corrective Action: When the Glasgow City Council adopts a revised purchasing policy, it will include the process to run a background check on the lowest responsible bidder of a project and check the SAM system for all required entities before awarding the contract. Proposed Completion Date: June 2025

Finding 2024-004 Internal Controls Over Procurement Condition: Northern Illinois University (the University) included incorrect documentation within purchase requisition forms for small purchases and simplified acquisition procurement transactions at the time of approval of the purchase which did not allow a reviewer to determine the appropriateness of the procurement method in the Fund for the Improvement of Postsecondary Education program. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) The University has already initiated a review of current processes and is taking steps to address the recommendation. Individual(s) Responsible for Corrective Action: Sponsored Programs & Procurement Services & Contract Management Staff Anticipated Completion Date: June 30, 2025

Finding 2024‐002 Finding Subject: Special Education Cluster (IDEA) ‐ Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Todd A. Armstrong, Assistant Superintendent Contact Phone Number and Email Address: (812) 897‐6036 tarmstrong@warrick.k12.in.us Views of the Responsible Official: We concur with the finding. Additional Explanation: Although the vendors selected provided specific services outlined in the federal grant, proper documentation of how those vendors were selected was not maintained. Moreover, the department believed by following the spending allotted in the grant, they were meeting necessary purchasing guidelines. Internal controls did not identify this misstep and allowed the services to be purchased. To avoid this in the future, guidelines will be prepared for all departments submitting purchase requests, and an additional control will be put in place to verify that procedures are followed. Description of Corrective Action Plan: 1) Create and write an administrative guideline that outlines expected purchasing procedures. 2) Distribute and make available the administrative guideline to employees. 3) Create an additional internal control in the business office to verify that those procedures were met with each requisition or request for purchase. 4) Provide necessary corrections to any request that does not follow guidelines. Mr. Armstrong will oversee, direct, and coordinate this process. He will work with the Corporation administrative team to develop and write the guidelines. The Business department will distribute the guidelines to all interested parties and have guidelines available upon request. Mr. Armstrong will outline expectations and determine when they have been met satisfactorily. Anticipated Completion Date: The remedy for this finding will be in place prior to June 30, 2025.

FA 2024-001 Improve Controls over Procurement, Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.027 - Special Education Grants to States 84.173 - Special Education Preschool Grants Federal Award Number: H027A220073 (Year: 2023), H027A230073 (Year: 2024), H173A220081 (Year: 2023), H173A230081 (Year: 2024), Questioned Costs: None Identified Description: A review of expenditures charged to the Special Education Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: To improve controls over procurement and suspension and debarment within our federal programs, we will: 1. Conduct an audit review training session in which we will review the audit findings, the corrective action plan, and the proper procedures for procurement and suspension and debarment. Attendance will be mandatory for all employees involved in the purchasing process for federal programs. A sign-in sheet will be used to document attendance. 2. Require all employees who are involved in the purchasing process for federal programs to review the Federal Programs Handbook annually and sign an attestation that they have done so. 3. Create a checklist that must be completed as part of the purchasing process for federal programs requisitions. This checklist will include steps found in the procurement and suspension and debarment policies set forth in the Federal Programs Handbook. Completed checklists will be maintained with voucher packets for each requisition. Estimated Completion Date: 6/30/2025 Contact Person: Nicole Price, Finance Director Telephone: 229-649-2234 Email: price.nicole@marion.k12.ga.us

Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials: We concur. Corrective Action Plan: The City’s grant policy requires compliance with grant guidelines, referencing CFR 200.303(a) and directing staff to the SAM.gov website and CFR 200 guidelines. However, the department that applied for and accepted the grant failed to include CFR 200 Appendix II in the Professional Services Agreement and did not document the review of contractor status on SAM.gov. To address this, the City will provide targeted training for departments and staff involved in grants, focusing on compliance with grant policies, special provisions, and proper documentation of actions. Responsible Individual(s): Anna Guiles, Assistant Community Development Director Anticipated Completion Date: To be completed by 3/31/2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, YEAR ENDED JUNE 30, 2024 Name of contact person: City Manager Corrective Action: Employee training has been completed with all department heads to ensure future compliance with federal debarment requirements. We will do annual staff training on this and will work with our engineers to make sure they too are complying with the requirements. Proposed Completion Date: Ongoing

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Robert Glover Jr. Contact Phone Number: (219) 945-0250 Contact Email Address: rglover@hobart.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As a member of the Northwest Indiana Special Education Cooperative (NISEC), School City of Hobart usually expends contracted services out of our general education fund. For the fiscal year 2023-2024, we included our contracted speech services into our federal grant funds. During the audit, Hobart was notified that we didn’t follow the procurement procedures when expending out of the federal grant. This finding was due to Hobart not going out and receiving multiple bids for contracted companies that provide services to our students. Hobart uses three contracted companies to provide Speech Pathologist and Speech Language Assistants. We have used these three companies for many years and have built great working relationships with these providers. After receiving the finding, and discussing with the auditor, we created a memo that we took to our board. In the memo we explained why we use the three contracted vendors instead of going out for bids. Finding Speech Pathologists and Speech Language Assistants is very difficult in the school setting, and they have created great working relationships with these three contracted companies. Within the memo, we listed all the contracted vendors that they use and why they work directly with them instead of going out for bids. If any contracted services are not bid, at the beginning of each school year, they will create a new memo with any contracted companies that they will be using during that school year and the memo will be approved by the School Board. Anticipated Completion Date: 4/30/2025

FA 2024-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.027 - Special Education Grants to States 84.173 - Special Education Preschool Grants Federal Award Number: H027A220073 (Year: 2022), H027A230073 (Year: 2023), H173A230081 (Year: 2023) Questioned Costs: $44,955 Description: A review of expenditures charged to the Special Education Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: We are implementing a more structured approach to larger purchases, which should help improve oversight and accountability. A new purchasing policy was implemented to ensure that significant expenditures are carefully reviewed and align with the district's financial strategy. Having the new CFO involved in reviewing and overseeing large purchases, as they'll be able to bring financial oversight to the process. Offering training to staff members who need help understanding the new policy will also ensure smooth adoption and compliance across the board. Estimated Completion Date: June 30, 2025 Contact Person: Shannon White, Business Services Director Telephone: 229-671-6045 Email: swhite@goats.org

Name of contact person and title: Deepak Butani, CFO Response: The Organization has engaged a professional services firm in a consulting engagement to review and assist in revising their procurement policy to align its policies and procedures for procurement with Uniform Guidance. Anticipated completion date: 6/30/2025

Corrective Action Plan Finding 2024-001 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 School’s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The School also has procedures to identify procurement transactions requiring competitive bids or proposals. Auditor Recommendation: We recommend the Academy ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Auditee Response/ Corrective Action Plan: The Academy will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified. Person Responsible: Dane Roberts, Executive Director and Randi Limb, Business Manager Timeline: All future contract solicitations will follow the required procurement standards.

Finding 2024-004 Internal Controls over Procurement Plan: University will work with information technology to enhance the eprocurement system to ensure appropriate documentation support is captured when a user selects the method for a non-competitive procurement. Expected Implementation Date: December 2025 Contact: Aaron Rosenthal, Assistant Vice Chancellor Purchasing and Contract Management University of Illinois Chicago Aaronr1@uillinois.edu 312-996-8074 Bradley Henson, Director of Purchasing Purchasing and Contract Management University of Illinois Urbana-Champaign Bhenson4@uillinois.edu 217-300-2459

Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Shirley Klowetter, Secretary sklowetter@swraider.com Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Cluster and Procurement and Suspension and Debarment compliance requirements. Context: Procurement The School Corporation participates in the Region 8 Education Service Center Cooperative which procures vendors for many food purchases and other supplies on behalf of its members. During the audit period, the School Corporation contracted with vendors outside of the Cooperative. One vendor with aggregate annual purchases of$200,000 for fiscal year 2024 exceeded the simplified acquisition purchase threshold (greater than $150,000) but was subjected to small purchase acquisition instead of the policy to perform a formal procurement consisting of a request for proposal (RFP) that is publicly advertised. Suspension and Debarment For two vendors tested which were not procured by the Cooperative and had aggregate annual disbursements exceeding the federal suspension and debarment threshold of $25,000, the School Corporation did not perform suspension and debarment checks to confirm the vendors were not suspended or debarred before entering into the contract or disbursing federal funds. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will implement a procurement checklist that is reviewed after the purchasing process has been completed to ensure compliance with purchasing requirements for federal awards. Sam.gov will be checked for each vendor with aggregate purchases above $25,000. Responsible Party and Timeline for Completion: Superintendent or designee will immediately implement the above plan.

Context: For the three small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The total amount disbursed for the sample items was $114,123 in FY23 and $13,404 in FY24 for contracted rehabilitation therapy and speech pathology services. The School Corporation did properly perform a suspension and debarment checks on the sample vendors. Contact Person Responsible for Corrective Action: Patrick Biggerstaff, Assistant Superintendent Contact Phone Number: (317) 831-0950 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Three quotes will be obtained, according to local policy (po6320) as well as state and federal guidance, when relevant purchasing and cost thresholds are reached. Anticipated Completion Date: April 1, 2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2025.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING FUNDS ASSISTANCE LISTING No. 66.458 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2025.

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; Direct Allocation, YEAR ENDED JUNE 30, 2024 Name of contact person: Fallon County Commission/Clerk and Recorder Corrective Action: Procedures will be developed that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract or agreement for purchase of goods or services is made with any suspended or debarred party. Proposed Completion Date: Immediately

FINDING 2024-003 Finding Subject: Childhood Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Ralph Shrader, Superintendent Contact Phone Number and Email Address: (765) 762-3364 / rshrader@msdwarco.k12.in.us Views of Responsible Officials: Option 1: We concur with the finding Description of Corrective Action Plan: We will obtain quotes for any purchases that qualify under the small purchases requirement Any director responsible for corporation contracts, will be responsible for checking Sam.gov to ensure the vendor is not on the suspension and disbarment list. A secondary individual will verify the findings. In addition, the micropurchase threshold will be raised to $50,000. Anticipated Completion Date: Effective Immediately

FINDING 2024-005 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Summary of Finding: The school corporation made purchases from vendors without using the procurement method and verifying that the vendor was not suspended or debarred. The School corporation did not properly implement a process to identify and assess internal and external risks, or monitor internal control activities to ensure they were operating effectively. Contact Person Responsible for Corrective Action: Melissa Embry Contact Phone Number and Email Address: 812-547-2637 melissa.embry@cannelton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will follow all correct procurement plans set forth in the future. We will also verify with each vendor and have a form filled out stating that they are not suspended or debarred. Cannelton management will establish a proper system of internal controls including policies and procedures related to risk assessment and monitoring activities within the federal program. Anticipated Completion Date: The School will ensure proper procurement methods are followed and that vendors are properly checked for suspension and debarment by December 2025. The additional controls will be implemented by August 2025.

2024-002: Suspension and Debarment Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Agency is committed to following the procurement process and requirements outlined within the policies and procedures. The Agency plans to revise current procurement policy to have a process for debarred, suspended, or excluded and documentation maintained to support the determination. All procurement will be monitored through the Sage Intacct and Ramp system, which has already been implemented. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Immediately If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Dhiren Shah, CFO, at 630-248-1181.

Internal Control: When a purchase is made with any vendor over the $25,000 threshold from Fund #800, School Lunch, Fund, the superintendent along with the treasurer or deputy treasurer (minimum of two people) will require that any vendors selected are in compliance with the Procurement and Suspension and Debarment compliance requirements by completing one the of following quality checks with each vendor prior to purchase: a. Checking the federal System for Award Management (SAM) database at https://sam.gov/content/exclusions and maintain a screen shot of the search results b. Collect a certification from the vendor directly c. Adda clause or condition to the covered transaction with the vendor

Information on the federal program: Subject: Special Education Cluster – Internal Controls Federal Agency: Department of Education Federal Program: Special Education Preschool Grants Assistance Listing Number: 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 23619-008-PN01; 22619-008-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Context: The School Corporation is a member of the Delaware-Blackford Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education preschool program and spent the federal money on behalf of six of its seven members. As the grant agreements were between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, 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. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. Two vendors exceeded the small purchase threshold during the audit period. The Cooperative provided evidence of a quote being obtained for the first vendor, however, evidence of obtaining multiple quotes was not retained for audit. The chosen quote was attached to the accounts payable vouchers and provided for audit; however, the other quotes obtained for the purchase were not maintained. For the second vendor, the Cooperative determined psychological services were to be provided by a single source provider, however, they did not have a documented rationale or support for the decision. Documentation detailing the history of procurement, which must include the reason for the procurement method used, selection of the vendor, and the basis for the price, was not available for audit for either purchase. Suspension and Debarment The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As such, the Cooperative entered into a contract totaling $32,388, which exceeded $25,000, for psychological services. The Cooperative did not perform procedures to ensure that the vendor was not suspended or debarred from participation in federal programs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Dr. Greg Roach Contact Phone Number: 765-378-3329 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: During quarterly meeting with MCS Co-op, will discuss that internal controls are in place for procurement, suspension and debarment requirements are in place for purchases. Anticipated Completion Date: 2025 next quarterly meeting with Muncie Community Schools Co-op

NGA had previously developed and socialized our procurement process and procedure with our staff members. In response to this finding, NGA will continue to train program staff on the documentation requirements regarding procurement decisions required to comply with our established policy. We will continue to review new contract requests carefully to ensure that all the necessary compliance documentation is captured and easily accessible to auditors in the future. Also, in cases where circumstances require that NGA work with a specific entity, we work with program leaders to produce a memo to file highlighting the particular requirements of the work and decision criteria that lead to our selection of individual vendors. The CFO will also work with management to inform supervisors when procedures are not followed. They may follow up with individuals who have not completed the compliance requirements or steps.

The District will update the procurement policy to reflect all the required files as noted in the procurement standards set out at 2 CFR sections 200.318 through 200.327. The District Board of Directors will review and approve all updates through Board action at a Regular Meeting of the Board of Directors

Views of Responsible Officials:  The Organization will update its procurement policy to be in conformance with Federal cost principles for approval at the next Board Meeting on February 24, 2025.  Supporting operating procedures will be reviewed and adjusted accordingly to ensure compliance with the policy by February 28, 2025.  The situation resulting in this finding was for the procurement of support services for a new electronic health records system which was successfully implemented using the services purchased at a reasonable cost; however, the procedures followed by previous staff did not fully comply with the Organization's policies and procedures nor the Federal cost principles. The Organization has since implemented additional procedures to ensure documentation for competitive bids and justification for all purchases to comply with Federal requirements enhancing the Organization's internal procedures. The Organization will do a full review of the Federal cost principles and suggested procedures to ensure full compliance and implement new policies and additional procedures, as necessary, by February 28. 2025.