Corrective Action Plans

Contact Person(s): Sarat Puthenpura Corrective action planned: ONF is in the process of upgrading its current written procurement policy to better comply with Federal audit requirements. The policy will be updated to include: • Inclusion of services under coverage of the policy • Micro purchase threshold explicitly defined. • Clear provisions for maintaining detailed procurement records including a requirement that such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. • The simplified acquisition threshold explicitly defined and incorporates all relevant elements including sealed bids method. Anticipated completion date: 11/30/25

CHA currently has a general procurement plan in place to guide its purchasing and contracting activities. However, to ensure full compliance with federal regulations, CHA will be updating its existing procurement policy to align with the Uniform Guidance requirements. This update will formalize procedures related to vendor selection, competitive bidding, and documentation to maintain transparency, accountability, and consistency across all procurement processes.

U.S. Department of Health and Human Services Material Weakness in Internal Controls over Compliance and Material Noncompliance: Procurement, Suspension and Debarment Recommendation: CLA recommends the Alliance to develop the procurement policy compliance in with Uniform Guidance, including such documentation as the procurement threshold of the transaction, price comparisons and analyses made, bids obtained, proof of any limited competition, dated vendor screenings and signed authorization of the appropriate program personnel. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within the Alliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HIV Alliance updated our Procurement Policy to comply with the federal guidance using the recommendation provided by CLA. The Board of Directors voted toapprove the updated Procurement Policy in June of 2025 and we implemented the updated policy on July 1, 2025. Name(s) of the contact person(s) responsible for corrective action: Wayne Hamblin, Finance Director Planned completion date for corrective action plan: July 1, 2025

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, DIRECT ALLOCATION, GRANT No. AM-23-0295, YEAR ENDED JUNE 30, 2024 Name of contact person: Mayor and City Council Corrective Action: The city procurement policy will be updated to include references to all federal procurement standards and requirements. All directors and relevant individuals will be trained on the updated policies. Proposed Completion Date: December 31, 2025

Management accepts the recommendation and will ensure compliance with the procurement standards in 2 CFR §§ 200.318–200.327 for all federally funded purchases by either conducting a competitive bidding process or documenting and obtaining approval for a sole source procurement as allowed under 2CFR §200.320(c)

Formula Grants for Rural Area and Tribal Transit Program Federal Assistance Listing #20.509 Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 and state requirements for procurement. The Organization should ensure documents are retained to support whether procurement policies were followed for vendors procured in years past. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review the procurement standards as well as ensure documents are retained to support whether procurement policies were followed. Name(s) of the contact person(s) responsible for corrective action: Carrie Beithon, Director of Financial Services Planned completion date for corrective action plan: 12/31/2026

Internal Controls over Compliance and Compliance with Procurement Standards Individual Responsible for Corrective Action Plan: Christopher Holleman, Interim CFO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Management will ensure that the policy be redistributed for retraining purposes underscoring the vital importance of following the policy and federal guidelines related to procurements. In addition, the CFO will take lead to ensure that the procurement policy is appropriately applied, and documentation meets required standards.

The Village will ensure that proposals be submitted for architectural and engineering professional services, and that documentation will be maintained for the proposals obtained as well as the Village’s determination of the most qualified vendor.

Views of Responsible Officials: We agree with the auditor’s findings and recommendations. Below $50k there will also be formal procedures with increasingly more oversight for purchases as they increase in cost. We will form and document a detailed procedure for issuing RFPs for PO amounts over $50k. We will review at least 3 proposals and once one is chosen, the vendor will be vetted before the proposal is accepted.

FINDING 2024-001 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: K. Rochelle Seneff Contact Phone Number and Email Address: (812)649-2242 ct@rockportin.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement As Clerk-Treasurer, I will educate all parties involved on the requirements that were found to be unfulfilled through this Federal Audit. For the duration of any federally funded projects, a discussion will be held during a public board meeting, detailing the rationale behind the City's decision to work with the vendors selected for small purchases and simplified acquisitions. This will be done to verify that all vendors, even when bids are not required, were retained through appropriate methods. A procurement policy that outlines the City's procedures and conforms to applicable federal, state, and local laws will be developed and taken to the Common Council for approval. Suspension and Debarment All vendors who participate in the project will receive a Suspension and Debarment Certificate provided by the City that must be signed by a representative of the vendor and filed with the vendor's contract or in the project folder. Anticipated Completion Date: December 23, 2025

Corrective action plan to address finding 2024-002 – No Written Procurement Policy The following steps will be taken to bring the Authority into compliance. 1. A draft policy will be developed by the manager 2. The draft policy will be shared with Authority members in November 3. At the next Authority meeting (12/8/2025) the policy will be formally presented for adoption. 4. The policy will be effective upon completion of the vote at the December meeting.

Federal Procurement Regulations Planned Corrective Action: Heartland Alliance Health developed and implemented a comprehensive Procurement Policy to ensure full compliance with federal Uniform Guidance requirements. The policy outlines required procurement methods, approval thresholds, documentation standards, and procedures for competitive bidding, price analysis, and sole-source justifications. The policy was reviewed and approved by the Board of Directors (October 2025) and is now in effect organization wide. Person Responsible for Corrective Action Plan: Steve Knox, Controller Anticipated Date of Completion: Resolved

The City of Royal City is committed to meeting all federal grant requirements and thanks SAO for providing guidance regarding this matter. We will proceed with developing written procurement procedures for purchases, services and public works contracts. It is our goal to ensure all stipulations are met for solicitation and award of Architectural and Engineering Services and Public Works contracts as required by state and federal granting agencies.

VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the audit finding. The Puerto Rico Department of Education (PRDE) acknowledges that the requested procurement documentation was not fully available at the time of the auditors’ review. However, management made every effort to gather and reconstruct the information for all the selected transactions, and the complete documentation will be available. Furthermore, the PRDE is taking actions to improve the accessibility and organization of procurement files to ensure that all documentation is readily available for review in a timely manner. Internal controls over document retention and filing procedures are being reinforced to prevent recurrence of this situation. It is important to note that the procurement processes followed by the PRDE comply with the applicable requirements established under the Code of Federal Regulations (2 CFR Part 200 – Uniform Guidance). Management remains committed to strengthening its internal controls, ensuring full compliance with federal and state requirements, and maintaining complete and timely documentation to support all procurement activities. IMPLEMENTATION DATE Current Fiscal Year. RESPONSIBLE PERSON María de los A. Lizardi Valdés Office of Federal Affairs Director Edgar Delgado Serrano Office of Federal Affairs Associate Director

Financial leadership of Child Saving Institute Inc. is in the process of developing a new procurement plan that will put the agency in compliance with 2 CFR sections 200.318 and 200.326

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement policies and procedures to ensure that future awards or contracts with expenditures of American Rescue Plan (APRA) funds will follow the procurement guidelines outlined in the US Treasury rules and regulations as well as County procurement policies. Most of the 2024 expenditures were part of contracts that were already in place when the original findings came out in September 2023 so this could not be corrected. Name of the contact person responsible for corrective action: Craig McBrain, Deputy Director of Budget and Finance Planned completion date for corrective action plan: December 31, 2025

Finding Number 2024-002: Uniform Guidance Compliant Procurement Policy (Significant Deficiency, Instance of Noncompliance – Procurement and Suspension and Debarment) Program: Continuum of Care Program Assistance Listing Number: 14.267 Response and Corrective Action Plan: Management agrees with the finding that the agency did not have policies for Procurement or Suspension and Debarment. The agency intends to adopt a procurement policy and procedures that meets the general procurement standards in 2 CFR section 200.318(a) and the State of California. The agency is also creating policies and procedures to ensure vendors are not suspended or debarred from work on federally funded projects. Anticipated Completion Date: by October 31, 2025 Responsible Person: Wanda Lassiter, Controller

Outdoor Recreation Acquisition, Development, and Planning Assistance Listing No. 15.916 Recommendation: City personnel should familiarize themselves with the documentation requirements of the CFR related to procurement. City policies and procedures should be modified to help ensure documentation is maintained on all compliance requirements. The written policies should be expanded to clearly address all five procurement methods allowed under Uniform Guidance. The city should also adopt a written conflict of interest policy. We also recommend that the City review and update policies and procedures to help ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction and that documentation of the status is maintained with the procurement history of each transaction that it is required for. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will adopt a formal conflict of interest policy. The City contracted for bidding and construction management, we will do better in familiarizing ourselves with policies and procedures for federal grants. Name(s) of the contact person(s) responsible for corrective action: Amanda L. Bartz, Clerk/Treasurer 715-453-4040, abartz@tomahawkwi.gov Planned completion date for corrective action plan: 12/31/2026

The District is in the process of reviewing its procurement practices and intends to implement a formal policy in alignment with state and federal requirements. Coordination with Burleigh County will continue to ensure compliance and proper documentation of procurement activities.

The District is in the process of reviewing its procurement practices and intends to implement a formal policy in alignment with state and federal requirements. Coordination with Burleigh County will continue to ensure compliance and proper documentation of procurement activities.

In 2020, Intelligent Transportation Systems (ITS) was the sole bidder for the District’s camera project. The selected camera vendor was Hanwha Vision. In 2023, ITS was sold. At the time of the sale, ITS had only completed a portion of the project. On February 22, 2023, the District extended the GIS contract of Environmental Science Services (ES2) through February 17, 2024, and transferred the remaining scope of the camera project from ITS to ES2. The camera technology was integrated into the GIS environment for the District. The remaining cameras to be installed were purchased under the ES2 2023 contract at a lower price than in the ITS 2020 awarded low bid. In retrospect, the District should have rebid the project because the cameras were funded under the Port Security Grant Program (PSGP). The oversight was mainly caused by the transition of District executive personnel starting in 2023. Though this was an oversight, the camera technology integrated in the GIS environment increases the Port’s safety and security posture. The District now adheres to its newly adopted Procurement Policy to prevent recurrence. Management will ensure the following processes are added to the financial management policies and procedures over federal and state funds to ensure full compliance with federal procurement standards, Louisiana Bid Law, Procurement Code, contract management protocols, and grant administration requirements: • The District is reviewing and updating its procurement policies to ensure alignment with federal procurement regulations, including those outlined in 2 CFR Part 200 (Uniform Guidance). All PSGP-funded procurements will be subject to competitive bidding procedures, proper documentation, and approval protocols to ensure transparency and compliance. • The District has reinforced its procurement procedures to ensure that all purchases exceeding $60,000 are formally advertised and awarded in accordance with Louisiana Revised Statute 38:2212. For purchases between $30,000 and $60,000, staff are required to obtain, document, and retain at least three competitive quotes in the procurement file. No significant purchases will be made without prior approval from the governing authority. • Formal procedures have been implemented to ensure that all PSGP-related contracts are properly executed, monitored, and supported by complete documentation. These procedures will includes verification of scope, deliverables, and performance timelines prior to payment authorization along with any solicitations, bids or quotes, evaluations, approvals, and any supporting documentation required by law and internal policy.• The District has designated a marine inspector to oversee PSGP grant activities, including expenditure review, documentation standards, and reporting requirements. All disbursements will be cross-checked against the approved Investment Justification (IJ) and verified for compliance with the grant’s period of performance. • Management is actively consulting with FEMA to assess the allowability of identified questioned costs. The District will follow FEMA’s guidance to resolve any discrepancies and ensure that all expenditures meet federal standards. • Mandatory training sessions are being scheduled for staff involved in procurement, contract management, and grant administration. These sessions will cover federal compliance requirements, internal control

We have changed the process so all contracts are collected at the SAU central office to ensure completeness.

Finding No.: 2024-002 For procurements using federal funds, GMHA is permitted to use a Simplified Acquisition Threshold up to the federal limit, which is currently set at $250,000 or $7.5 million for commercial goods. The Code of Federal Regulations (CFR) permits a non-federal entity to use a SAT up to the federal limits, without having to follow threshold limitations imposed by state or local law. The set of criteria employed by the Ernst & Young is incomplete, and fails to give proper deference to the legal opinions of licensed attorneys. In determining to follow the federal SAT, GMHA considered the guidance of a memorandum from the Office of the Attorney General indicating substantively the same legal analysis as follows. See Memorandum from Deputy Attorney General, Solicitor Division to Chief Deputy Attorney General, Federal Simplified Acquisition Threshold and Micro-purchase Threshold, Ref: AG 22-0410 (Sept. 14, 2022). When presented with this memorandum, the auditors refused to accept its instructions stating: “We were unable to follow why the Attorney General considered the definition of a non-Federal entity in applying the requirements of §§ 200.318 through 200.327. In reviewing the aforementioned sections, there was no reference to non-Federal entities.” This statement evidences the auditors’ fundamental misunderstanding of the law. The auditors based their analysis on an amended version of the CFR, which became effective only January 2025. According the definitions in the Code of Federal Regulations in effect during the relevant 2023-2024 audit period, Guam is both a “State” and a “Non-Federal entity.” Guam Memorial Hospital Authority also falls within the definition of “Hospital” and “subrecipient.” As relevant here, 2 CFR 200.1 states: State means any State of the United States, the District of Columbia, the Commonwealth of Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and any agency or instrumentality thereof exclusive of local governments. Non-Federal entity (NFE) means a State, local government, Indian Tribe, Institution of Higher Education (IHE), or nonprofit organization that carries out a Federal award as a recipient or subrecipient. Hospital means a facility licensed as a hospital under the law of any State or a facility operated as a hospital by the United States, a State, or a subdivision of a State. Subrecipient means an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a Federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency. As a Non-Federal entity, GMHA also is required to abide by the definition of “simplified acquisition threshold.” According to 2 CFR 200.1: Simplified acquisition threshold means the dollar amount below which a non-Federal entity may purchase property or services using small purchase methods (see § 200.320). Non-Federal entities adopt small purchase procedures in order to expedite the purchase of items at or below the simplified acquisition threshold. The simplified acquisition threshold for procurement activities administered under Federal awards is set by the FAR at 48 CFR part 2, subpart 2.1. The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk, and its documented procurement procedures. However, in no circumstances can this threshold exceed the dollar value established in the FAR (48 CFR part 2, subpart 2.1) for the simplified acquisition threshold. Recipients should determine if local government laws on purchasing apply. (emphasis added). This definition applies to purchasing by all non-federal entities—including GMHA. Title 2 CFR 200.317 provides: When procuring property and services under a Federal award, a State must follow the same policies and procedures it uses for procurements from its non-Federal funds. The State will comply with §§ 200.321, 200.322, and 200.323 and ensure that every purchase order or other contract includes any clauses required by § 200.327. All other non-Federal entities, including subrecipients of a State, must follow the procurement standards in §§ 200.318 through 200.327. (emphasis added). As a subrecipient of Guam, GMHA would also be required to follow 2 CFR 200.320(a)(2)(ii), which reiterates that: “The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR.” The CFR treats the requirement that a state or local entity follow (1) its own “policies and procedures” and (2) its own small purchase “threshold” as separate requirements. The CFR applicable to most federal funds—including ARPA—only requires the hospital to follow the local “policies and procedures.” 2 CFR 200.317. The CFR requires GMHA—as a non-federal entity—to separately make a determination of an appropriate small purchase threshold based on a number of factors specific to GMHA, provided it does not exceed the federal SAT. 2 CFR 200.1; 2 CFR 200.320(a)(2)(ii). Procurement method selection is essentially a two-step process: (1) Make a substantive determination about the monetary cost of a proposed procurement and determine whether it is below or above an applicable threshold. Which side of a threshold a procurement falls on (and some other factors) will determine the method—sole source, RFQ, RFP, IFB—that will be used. (2) After the method is determined, an entity is then pointed to specific policies and procedures applicable to that type of procurement. The relevant factors for determining a recipient-specific SAT include an entity’s “internal controls, an evaluation of risk, and its documented procurement procedures.” 2 CFR 200.1; 2 CFR 200.320(a)(2)(ii). For a portion of the relevant procurement period, the CFR also stated: “When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations.” This section was amended effective approximately October 1, 2024. Now, it no longer requires the recipient or sub-recipient to ascertain whether this entity-specific threshold is “authorized or not prohibited under State, local, or tribal laws or regulations.” But even under the prior version, the entity only needed to consider the authorization or lack of prohibition under state or local law if it was adopting a “lower simplified acquisition threshold” than the federal SAT. 2 CFR 200.320(a)(2)(ii) (effective until Sept. 30, 2024) (emphasis added). GMHA determined that the federal SAT levels were appropriate, and—in any event—local law does not prohibit GMHA from adopting the federal SAT when using federal funds. GMHA’s use of the federal SAT for procurements using federal funds has been a decades long practice of our materials management, so a suggestion that it is unauthorized would be a finding quite inconsistent with GMHA’s internal controls. Highlighting the distinctness or difference between the “policies and procedures” and “threshold” requirements, is the fact that “simplified acquisition procedures” and “simplified acquisition threshold” are defined separately. See 48 CFR 2.101. And the two requirements are discussed separately in the section of the CFR discussing “informal procurement methods.” 2 CFR 200.320. Additionally, the small purchase “procedures” applicable to federal agencies, FAR Part 13, are contemplated in an entire section that is separate from the rules about the controlling SAT or other threshold. Finally, in other portions of the CFR—such as federal highway funds—the government has specifically instructed state entities to follow both the state or local “procedures” and the state or local “threshold. 23 CFR 172.7(a)(2). When the CFR wants the state government to follow state SATs, it will specifically do so. It has not put that instruction in 2 CFR 200.320. Guam law also specifically directs all persons within the Government of Guam to comply with the applicable federal law and regulations that are in conflict with or are not reflected in the Procurement Code. 5 GCA § 5501. In other words: Guam law requires GMHA to follow the federal rules. Specifically, here, the federal requirement that GMHA determine an appropriate SAT is not reflected in the local laws. GMHA, thus, must comply with the federal requirement that GMHA make a recipient-specific determination of an appropriate SAT. Even the Guam Legislature understands that the law operates in the same manner as the Attorney General’s memorandum. During a legislative hearing on June 25, 2024, Senator Sabina Perez recited the same analysis, recognizing that Guam agencies can use the federal simplified acquisition threshold when expending federal funds. See Guam Legislature, Public Hearing Bill No. 134-39 (COR) at *1:46:00-1:46:31 (June 25, 2025), available at https://www.youtube.com/live/ciXo1EEXJZI. In deciding the federal SAT applies, GMHA was also guided by precedent and guidance issued to other government entities. In 2015, when the Guam Department of Education was under a federal third-party fiduciary, it was still employing the lower local small purchase threshold. GDOE was instructed that this was inappropriate because federal law supersedes Guam law on the SAT. The federal fiduciary—consistent with USDOE instructions—required GDOE to follow the federal SAT. See Letter from John E. Hampford, Alvarez & Marsal, to Jon J.P. Fernandez, Superintendent of Guam Department of Education (Dec. 30, 2015); see also Letter from Jon J.P. Fernandez, Superintendent of Guam Department of Education to Attorney General Leevin T. Camacho and Public Auditor Benjamin J.F. Cruz (July 20, 2020). Thus, other Guam agencies have been instructed by the federal government to use the federal SAT. This is also bolstered by the case law. The Guam Supreme Court has ruled that the CARES Act funding was a federal appropriation for a specific purpose, “outside the control of the Guam Legislature.” See Story-Bernardo v. Gov’t of Guam, 2023 Guam 27 ¶ 46. ARPA funding is substantively similar to CARES Act funds, simply with additional permitted uses. Local law cannot dictate how these federal funds are spent. GMHA also considered case law from Texas federal court where a self-styled “whistleblower” sued the City of Burleson, Texas for allegedly spending in excess of their own SAT. Under Burleson’s own regulations, the local SAT was $10,000, see Rule 5.1, City Council Policy 36, City of Burleson Purchasing Policy (adopted July 2, 2018, revised Oct. 16, 2023). However, the lawsuit alleged that the city was spending in excess of this $10,000 SAT. The federal judge in that court stated: “In addition, the regulations show that “formal purchasing methods are not required” for purchases that are less than the “simplified acquisition threshold.” 2 C.F.R. § 200.1(2021). The simplified acquisition threshold is set at $250,000. 48 C.F.R. § 2.101(2021). However, Mr. Eder's complaint incorrectly alleges “upon information and belief” that the simplified acquisition threshold is $10,000. Doc. No. 37 at 12, ¶27(b). Mr. Eder's apparent misreading of the threshold for formal purchasing is central to his claim under the FCA, and it appears this concern may have arisen from simply misreading the rules, rather than any reasonable dispute under the law.” Eder v. City of Burleson, Civil No. 3:23-CV-00948-K, 2024 WL 4771408 at *5 (N.D. Tex., Nov. 13, 2024). Thus, the federal court recognized that the lower local SAT did not control. The only relevant SAT was the federal one. GMHA’s determination to use the maximum SAT allowed by the federal CFR is thus appropriate. The federal CFR rule requiring a recipient-specific SAT determination supersedes the local thresholds. If the procurement is under the federally-allowed $250,000 SAT, GMHA must still follow the local small purchase procedures. See in part 5 GCA § 5213. The auditors’ view of Guam law appears to be a clear outlier, inconsistent with a plain reading of both federal and Guam law, the opinions of both federal and local courts, the memorandum from the Attorney General’s Office, the understanding of the Guam Legislature, and the reasoned opinion of Hospital Legal Counsel. The auditors’ finding is also inconsistent with decades of GMHA procurement practice. The questioned costs based on this finding should be removed. The auditors’ (1) inability to even reference the relevant definitions from the CFR in effect at the time of the relevant audit period and (2) unwillingness to accept the legal opinions from licensed attorneys, should be a finding on the auditors’ peer review.

Personnel Responsible for Corrective Action: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City, Kansas Anticipated Completion Date: July 1, 2025 Views of Responsible Officials and Planned Corrective Action: Unfortunately, due to the late completion of the 2023 Single Audit and the hiring of the grants position in early 2025, many previous findings and contracts were not yet corrected in 2024. In the event of this finding, there were two vendors which had minimal expenditures in 2024 (under $5,000 which does not require competitive bids but in aggregate they exceeded that amount). The procurement department had not been consulted, and debarment checks were not completed when the work began in 2023, and final payments were issued in 2024. In the Grants Manual and training departments have been instructed that these procedures must be complied with for all grants.

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1099 (Year: 2024), 245GA324N1199 (Year: 2024) Questioned Costs: $46,878 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement procedures were followed. Corrective Action Plans: Responsible Parties: Superintendent, School Nutrition Manager, To address this finding and prevent recurrence, the Superintendent and School Nutrition Manager will implement the following corrective measures in accordance with Terrell County Board of Education policy and applicable federal/state guidelines: 1. Staff Training-Provide training for School Nutrition staff on federal procurement requirements, the district's Procurement Plan, and Board policy related to financial management, procurement, and record retention. Training will be documented and updated annually or as requirements or Board policies are revised. 2. Process Monitoring-Establish written procedures aligned with board-approved procurement policies to ensure all required bids and quotes are obtained, documented, and retained. Maintain both electronic and hard-copy procurement files, with oversight responsibilities clearly assigned. 3. Internal Compliance Reviews-Conduct quarterly internal reviews between the Schol Nutrition Department and Finance to verify procurement documentation and adherence to Board policy and the Procurement Plan. Provide review summaries to the Superintendent and report systemic issues to the Board, if necessary. 4. Accountability Measures-Incorporate procurement documentation and retain responsibilities into departmental expectations, evaluations, and supervisory reviews, consistent with Board policies on accountability and internal controls. Noncompliance with documentation procedures will be addressed under established Board personnel and accountability policies. Estimated Completion Date: June 30, 2026 Contact Person: Shereca R. Harvey, Superintendent Telephone: (229) 995-4425 Email: srharvey@terrell.k12.ga.us