Corrective Action Plans

Finding Number: 2023-003 Finding Title: Procurement, Suspension, and Debarment Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Ra Chhoth, Deputy Chief Finance Officer, Finance and Property Services OR Matt Bower, Manager Resource Coordination, Finance and Property Services Corrective Action Planned: Controllers Division staff will work with Procurement Division on further development of enhanced communication and training tools on federal procurement for city contract manager staff. Suspension and debarment subject has been shared with Grants Users Group and will be made a standing annual topic to be covered moving forward. Anticipated Completion Date: 12/31/2024

Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Federal Agency Name: Department of Treasury Pass‐Through Entity: North Dakota Office of Management and Budget Assistance Listing Number: 21.027 Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Finding Summary: In the testing of procurement, suspension, and debarment it was identified that the City did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Corrective Action Plan: The City has adopted a procurement policy satisfying the requirements of 2 CFR sections 200.318 through 200.326 as of January 8, 2024. Responsible Individuals: Dustin Scott, City Administrator Anticipated Completion Date: January 8, 2024

Sufficient Documentation for Noncompetitive Proposals for Pacific Fisheries Data Program, 11.437 Recommendation: CLA recommends increased internal monitoring to ensure that noncompetitive procurements are sufficiently justified and that internal Sole Source Justification Forms are completed correctly and retained for all vendors procured under noncompetitive methods. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will modify its subcontractor request form and PO form to require competitive supporting documents or non-competitive justification documents to be attached with the subcontractor request or PO form. Contract Specialist and Purchasing Specialist will review request package to ensure all required paperwork completed properly before moving forward with the process. In the pipe line, Requisition Module in Navision Software will be designed to put a hard stop if a purchase order of $10,000 or greater is missing supporting document for competitive/non-competitive procurements. Name(s) of the contact person(s) responsible for corrective action: Kathy Ameral and Michael Arredondo. Planned completion date for corrective action plan: October 15, 2023

Corrective Action: CBNHC will implement the following corrective actions: • CBNHC will update its procurement policies and procedures to conform with 2 CFR Part 200. • CBNHC will implement training for all staff who perform program purchases to ensure compliance with its Finance Policies and Procedures. • The Accounting Supervisor, Accounting Technician, and Interim Finance Director/Chief Operations Officer will ensure that all new purchases comply with the CBNHC Finance Policies and Procedures. Person Responsible: The following individuals will be responsible for the above corrective action plan: • Accounting Supervisor (Candyce Guerro) – Is responsible for conducting procurement policy training for all staff who perform program purchases. • Interim Finance Director/Chief Operations Officer (Volelle Zamora) – Is responsible for updating the procurement policies and procedures. • Interim Finance Director/Chief Operations Officer (Volelle Zamora), Accounting Supervisor (Candyce Guerro), and the Accounting Technician (Charlotte Sandoval) – Jointly responsible for ensuring incoming purchase requisitions are in compliance with the purchasing policies and procedures. Completion Date: CBNHC will update its procurement policies and procedures by December 31, 2024. Training over the current procurement protocol will be implemented immediately and will be conducted annually for all program managers. The Finance Department will immediately review all incoming purchase requisitions to assure requests comply with policy standards.

Finding 2023-005 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Finding Summary: The City does not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Steve McFarland, City Administrator Corrective Action Plan: The City will establish controls to follow all applicable procurement requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: December 31, 2024

Update policies and procedures manual.

Procurement Process Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Passed through the Oklahoma State Department of Education (Fund 723) Compliance Requirement: Procurement Material Weakness in Internal Control over Compliance; Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award the provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Effective May 14, 2022, the non-Federal entity must ensure that all applicable programs comply with section 70914 of the Build America, Buy America (BABA) Act, including through incorporation of a Buy America preference in the terms and conditions of each award with an infrastructure project. Condition: A vendor that was funded by the ELC program had not gone through the procurement process as required by applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Cause: The District has previously funded the vendor using state and local funds rather than federal funds for the past several years. The vendor’s service was identified that the use of the funds was an allowable activity and cost but the vendor had not gone through the required procurement process for federally funded programs. Effect: The District is out of compliance with federal requirements regarding procurement and could be contracting with vendors that are not the most practical for the District. Context/Sampling: Both of the two vendors that met this scope in this program was tested so no sampling was necessary. Repeat Finding From Prior Year: No Questioned costs: Funds spent with this vendor in this program were $486,260. Recommendation: Control procedures should be implemented to ensure that all vendors that are paid with federal funds following the required procurement regulations and ensure federal updates are regularly made to ensure continued compliance with procurement requirements.Views of Responsible Officials: The district understands the importance of complying with federal procurement requirements and will ensure all staff involved with federal funds are informed of the procurement rules with the addition of the federal compliance procedures to our Fiscal Management Policy. Responsible Individuals: Cameron Cox, Director of Purchasing Anticipated Completion Date: June 30, 2024

Auditor’s Recommendation: We recommend that the Foundation adopt a formal written procurement policy in the format and with the elements required by 2 CFR Sections 200.318 to 200.326. Action Taken: • As a First Year Single Auditee, the management team will ensure that senior leadership team, finance and accounting team, as well as program manager/directors for federal awards receive some form of training and certify receipt of this training within six-months of these findings. • As a First Year Single Auditee, the management team will ensure that specific policies are created to ensure a procurement process for goods and services expensed from federal funds is established and in alignment with UG (Uniform Guidance) standards for federal awards. • As a First Year Single Auditee, the management team will have an independent audit firm review this policy to ensure they are in alignment and conformance with UG (Uniform Guidance) standards.

The Chief Procurement Officer will follow all federal and state procurement standards. CPO will review and make necessary changes to documentation procedures for procurement to ensure that all federal and state requirements are met. Chief Procurement Officer has reviewed federal and state procurement compliance. He will update changes to documentation of procurement by December 31, 2024

Berrien County BOE FA 2023-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial 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: 225GA324N1199 (Year: 2023), 225GA324N1199 (Year: 2023) Questioned Costs: $3,381 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 expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The new program director will attend training and review compliance requirements to ensure appropriate documentation is maintained. Estimated Completion Date: 30-Jun-24 Contact Person: Jolyn Schultz, Finance Director Telephone: 229-686-2081 Email: jolyn.schultz@berrien.k12.ga.us

FINDING 2023-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Aaron Kaytar Contact Phone Number and Email Address: 317-852-1120 akaytar@brownsburg.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: In 2023 a Purchasing Policy was implemented for all departments to follow. It states: 1. For Purchases Under $50,000 a. Purchases or Contracts of $1,000 or Less i. Shall be reviewed and approved by the designated Purchasing Agent. ii. The Department Head, Procurement Manager and Town Manager reserve the right to deny any Purchase. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. b. Purchases or Contract between $1,000 and $10,000 i. Shall be reviewed and approved via a Requisition Form by the Purchasing Agent/Department Head. ii. The Procurement Manager and Town Manager reserve the right to deny any Purchase. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. iv. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. c. Purchases or Contracts between $10,000 and $50,000 i. Shall be reviewed and approved via a Requisition Form by the Department Head, Procurement Manager and Town Manager. ii. Should have (3) formal quotes from different vendors. iii. The Procurement Manager and Town Manager reserve the right to deny any Purchase. iv. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. v. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. d. Purchases of at Least $50,000 and Less Than $150,000 i. Shall be reviewed and approved by the Department Head, Procurement Manager, Town Manager and Town Council. ii. The information shall be presented to Town Council and should contain (3) formal quotes from different vendors. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. iv. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. e. Purchases of $150,000 or More i. Shall be submitted via a formal bidding process. ii. Shall be reviewed by Department Heads, Procurement Manager, Town Manager and Town Council. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. iv. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. 2. To provide services to the Town of Brownsburg, you must not be debarred, suspended, or otherwise be excluded from or ineligible for participation in federally assisted programs under Executive Order 12549. Anticipated Completion Date: Policy change 2023. Purchase order change 8/31/2024.

Current plan & Actions being taken and developed. 1. Develop and Update Procurement Policies Create Comprehensive Policies: Ensure that the procurement policy covers all aspects of the procurement process, including vendor selection, bidding, contract management, and expenditure approvals. Regular Reviews: Periodically review and update the policies to reflect changes in laws, regulations, or best practices. 2. Establish Clear Procedures Document Procedures: Develop detailed procedures for each step of the procurement process, from requisition to payment. Create a procurement checklist. Standardize Processes: Ensure consistency across departments by standardizing procedures for procurement activities. Provide each department with the procurement check list. 3. Training and Awareness Conduct Training: Provide regular training for all staff involved in procurement to ensure they understand the policies and procedures. Promote Awareness: Increase awareness about the importance of compliance with procurement policies. 4. Implement Controls and Checks Segregation of Duties: Divide procurement responsibilities among different staff to reduce the risk of errors or fraud. Approval Processes: Establish clear approval hierarchies and limits for procurement activities and expenditures. Audit Trails: Maintain detailed records and documentation for all procurement transactions. 5. Monitor and Review Compliance Regular Audits: Conduct regular internal and external audits of procurement activities to ensure adherence to policies. Performance Metrics: Develop metrics to evaluate the effectiveness of procurement processes and identify areas for improvement. 6. Enforce Accountability Responsibility Assignments: Assign clear responsibilities for monitoring and enforcing procurement policies. 7. Utilize Technology Data Analysis: Use data analytics to track spending patterns, vendor performance, and policy compliance. 8. Encourage Transparency Open Bidding Processes: Ensure that procurement opportunities are advertised openly and fairly. 9. Feedback and Continuous Improvement Solicit Feedback: Gather feedback from staff and vendors on the procurement process to identify areas for improvement. Continuous Improvement: Regularly update procedures and policies based on feedback and audit findings. 10. Departmental Integration Cross-Department Coordination: Ensure that all departments are aligned with procurement policies and procedures. Provide each department with the procurement check list. Name(s) of the contact person(s) responsible for corrective action: All Department Directors, in conjunction with the Finance Department, are collectively accountable for the implementation and oversight of this corrective action plan. Requests for Proposals (RFPs) will be reviewed and approved in an open Town Meeting, with decisions made by the Mayor and Commissioners. Planned completion date for corrective action plan: Implementation commenced around June 1, 2024 and is projected to be fully operational within a year June 1, 2025.

The System will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with §200.320. Additionally, the System will enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. The system will implement a review of all contracts to ensure the appropriate language exists regarding suspension and debarment regulations and/or consider an annual review of SAM.gov for all vendors. Interim CFO, Sunnie Hines Timeline 180 days

FINDING 2023-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: The County did not perform procedures to ensure vendors were not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Additionally, the County did not have a formalized procurement policy outlining its processes and procedures with regards to the procurement of goods and services using federal grant funds. Contact Person Responsible for Corrective Action: Brenda J. Furry, County Auditor Contact Phone Number and Email Address: (765) 492-5300 / brenda.furry@vermillioncounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The process of ensuring the vendors that are being used by the County and paid for through Federal Funds, specifically ARPA funds, have been confirmed to be in good standing via Exclusions search on the SAM.gov website. A procurement policy with regards to the procurement of goods and services using federal grant funds is currently being written. Anticipated Completion Date: December 31, 2024

2023-003: Procurement Type of Finding: Noncompliance, Material Weakness Condition: The School did not always follow procurement standards as put forth in 2 CFR §200.318 through §200.326. Context: For ten of 25 vendors within the Simplified Acquisition Threshold reviewed, the School did not maintain documentation that appropriate procurement procedures were performed. Repeat Finding: Similar to prior year finding 2022-003. Action planned in response to finding: Management will implement procedures to ensure that competitive purchasing procedures are performed for all transactions above the micro purchase threshold and documentation is maintained to support the procurement procedures performed. Planned completion date for corrective action plan: June 30, 2024 Name of the contact person responsible for corrective action: Dolores Silva, Chief Financial Officer

CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that 1) competitive bidding was performed for the purchases of goods or services over $22,500 and 2) a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors –– Houghton Mifflin-Harcourt ($509,919), Beaver Valley Intermediate Unit ($419,826), and Smart Solutions ($449,303). CRITERIA: As specified in 2 CFR 200. 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i), 200.320(a)(2)(i) and Section CFR 200.324(a) of the Uniform Guidance regarding the requirement to perform a cost or price analysis for purchases in excess of the Simplified Acquisition Threshold ($250,000), as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group, 2) obtaining quotations from three qualified providers where applicable and documenting those results, and 3) properly document purchases using federal assistance when the vendor meets the criteria as a sole source provider. These three (3) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

CONDITION: During my review of Aliquippa School District’s compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that either 1) three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000 were obtained, 2) competitive bidding was performed for the purchases of goods over $22,500 or 3) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors: Saving Ourselves ($30,000), AGI Repair ($16,216), IXL ($19,218), Learning Systems Associates LLC ($25,425), AGC Education Inc. ($11,644), Apple ($163,505), Germ Solutions LLC ($160,070), Graham Security ($12,025), Curriculum Designers, Inc. ($27,875), RJ Rhodes Transit, Inc. ($24,845). CRITERIA: As specified in 2 CFR 200 318(i) of the Uniform Guidance, the District 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. In addition, small purchase procedures per 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PA Statue 8.807.1, there should be three quotes that are either written or well documented and over $22,500 formal bidding procedures must be utilized. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i) and 200.320(a)(2)(i) of the Uniform Guidance, as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group, 2) obtaining quotations from three qualified providers where applicable and documenting those results, and 3) properly document purchases using federal assistance when the vendor meets the criteria as a sole source provider. These three (3) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

FINDING 2023-002: Procurement Please provide an explanation of how your organization plans to resolve procurement error moving forward The Simple Foundation has implemented a newly developed procurement policy that aligns with the Uniform Guidance procurement standards. Moving forward, this policy will be strictly followed for all agreements and transactions under the Federal procurement requirements within Uniform Guidance. Attached below in the procurement policy and the Purchase Justification Form. Reasonable completion date: 08/04/2024 Responsible Party: D&K Financial, Compliance

The district immediately reviewed and made changes to its procurement procedures. The changes were immediately reviewed with the district Administrators who are responsible for procurement. The district made sure that it’s Local Policy #610 Purchases Subject to Bid/Quotation was revised to the most current numbers and will following it’s Local Policy when purchasing. The district will also follow the Uniform Guidance on procurement. For all future projects, the district has partnered with an Architectural Firm who will prepare bid documents for the district. The district will advertise for seal bids for all projects that exceed the bid limits and award the bid to the lowest responsible bidder. In response to the specific project in question, the district will be reclassifying the Trinity Project from a Federal purchase and will not submit it as an expenditure through the Federal ESSER funding.

CORRECTIVE ACTION PLAN (Concerning Finding 2023-001) Contact Person Responsible for Corrective Action: Luke R Dyer, Town Manager Corrective Action: The Town of Van Buren will take the following actions to address finding 2023-001. The municipality is in the process of developing a Procurement Policy as related to all purchases made by Department Heads, within their department’s appropriated budget, and the Town Manager’s ability to authorize purchases. Additional considerations will be reviewed allowing the Town Council to approve purchases beyond the line items indicated in the yearly budget. Anticipated Completion Date: November 6, 2024 Sincerely, Luke R Dyer, Manager

Inadequate Records Retention Condition: In our procurement testing for CSLFRF funding, the City was unable to provide evidence that demonstrates public notice was published according to (2 CFR § 200.320(b)) for 1 of the 5 projects selected. In conjunction with our FY2023 audit, please see the City’s corrective action plan below: Management Response: The Finance Director is initiating conversations with department heads regarding updating procurement policies and procedures. We are taking steps to ensure all procurement documents are stored centrally in order for these items to be readily available moving forward. Expected completion date: In regards to procurement documents corrective action has already been taken for FY 23-24; regarding updating procurement policies and procedures expected completion date 6.30.25. Party Responsible: Jennifer Watts, Finance Director Contact Information: jwatts@miamiokla.net

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from three (3) vendors - CJAWS, Inc., Edmentum, Inc., and SapphireK12, Inc. This is a repeat finding (2022-007) from the previous fiscal year for CJAWS, Inc. and Edmentum, Inc. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that the School District update their policies to include those most recent related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). In addition, I would recommend that District personnel responsible for expenditures related to federal funding receive updated training related to ‘procurement’ policies and procedures as they relate to federal funding. MANAGEMENT’S PLANNED CORRECTIVE ACTION: Management of the School District will review and update as necessary its ‘federal fiscal compliance policies’ to comply with the requirements of the Uniform Guidance. Particularly as it relates to procurement procedures, for acquisitions of property or services in which the aggregate dollar amount is greater than the micro-purchase threshold but does not exceed the simplified acquisition threshold, the District will obtain and document price or rate quotations from at least three qualified sources. In addition, management of the District will obtain training where available and applicable to enhance their internal controls over the management of federal program funds. The District’s timeframe for implementation is effective immediately.

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCES OF NONCOMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2023-004 Internal Control Over Compliance and Reportable Instances of Noncompliance With Federal Procurement, and Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, and suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the Academy did not have sufficient controls in place resulting in material noncompliance within its child nutrition cluster federal programs to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The Academy will review its policies and procedures relating to procurement, and suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that academy personnel are following the requirements of the Uniform Guidance related to methods of procurement, and suspension and debarment, including maintaining appropriate documentation. Official Responsible – The Academy’s Executive Director, Farhiya Einte. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The Academy agrees with this finding. Plan to Monitor – The Academy’s Executive Director, Farhiya Einte, will assure appropriate internal controls and procedures are in place to ensure compliance with procurement, and suspension and debarment requirements.

CORRECTIVE ACTION PLAN {Concerning Finding 2023-001-RF3-407-3.0) Contact Person Responsible for Corrective Action: Judy L. Hayward Corrective Action: The Royalton Fire District 1 will take the following actions to address finding 2023-01. We will prepare and adopt a Federal Procurement Policy. Anticipated Completion Date: June 30, 2024.

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Associates in Counseling’. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance. MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The District’s timeframe for implementation is effective immediately.