Corrective Action Plans

The County is continuing to implement a county-wide contract clause that will be added to covered transaction contracts to comply with 2 CFR 180, to ensure covered transactions receive verification that the person or entity is not excluded or disqualified. Review and approval of this suspension and debarment verification will be performed during the contract approval process, which will include this standardized clause. The County’s purchasing policy and procedures manual will be updated to include this standard suspension and debarment verification process to ensure this procedure is communicated county-wide and followed. Additionally, the County will develop standard justification forms to document method of procurement to be maintained in the procurement file. The County will also update its contract templates to include applicable suspension and debarment attestation language which meets Federal requirements and update its purchasing policy and procedures manual to reflect these changes.

Title V Grant Procurement Planned Corrective Action: The University will update and implement internal policies such that they align with the federal procurement requirements. Person Responsible for Corrective Action Plan: Jim Gerrish, Director of Facilities Anticipated Date of Completion: April 30, 2024

MW Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 requirements for procurement. The Organization should also provide training to the various individuals involved in the procurement process to ensure they understand the applicable requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will update the procurement policy to add in the other methods of procurement to ensure compliance with the Uniform Guidance and follow proper document retention procedures. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2024

Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The District is actively working to develop written policies that will guide future procurement and selection of firms that participate in these federally-funded projects, including debarment and conflict of interest procedures. We plan to implement new policies by end of F& 23/24. Implementation Date: June 2024 Name of Responsible Person: Hugh Logan, General Manager

Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The District is actively working to develop written policies that will guide future procurement and selection of firms that participate in these federally-funded projects, including debarment and conflict of interest procedures. We plan to implement new policies by end of F& 23/24. Implementation Date: June 2024 Name of Responsible Person: Hugh Logan, General Manager

CONDITION: During my review of The School District of the City of Jeannette’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, or 2) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors – Grade Point Resources ($74,503.17) and VLN Partners, LLP ($52,750.00). CRITERIA: In accordance with 24 PA Statute 8.807.1, the District must obtain/document at least three (3) written or well documented price or rate quotations from a reasonable number of qualified sources for purchases of goods between $10,000 and $$22,500 (threshold established annually). In addition, Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance requires price or rate quotations to be received from an adequate number of qualified sources for purchases above the micro purchase threshold of $10,000 and the simplified acquisition threshold of $250,000. 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 of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626.5), 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, 4) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding.

CONDITION: The School District of the City of Jeannette contracted with a third-party vendor (Smart Solutions Technologies) for technology equipment for the District which exceeded the threshold for competitive procurement. The purchase was procured through a cooperative purchasing group. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. This is a continuing finding from the 2021-2022 fiscal year. CRITERIA: 24 Pa. Statutes 751 of the Public School Code and Section 2 CFR 200.318(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a school district whereby the cost exceeds certain dollar thresholds as adjusted annually for an inflation index. 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. RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, so as to comply with all applicable sections of the Uniform Guidance, in specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. MANAGEMENT’S PLANNED CORRECTIVE ACTION: 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 specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. The timeframe for completion of this process will commence immediately and will continue on an ongoing basis as required by new policy directives from oversight agencies.

CONDITION: The School District of the City of Jeannette contracted with a third-party vendor (ABM Building Solutions LLC) for the performance of an energy savings construction project at the District. The contract with the third-party vendor, which was procured through a cooperative purchasing group, exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. This is a continuing finding from the 2021-2022 fiscal year. CRITERIA: 24 Pa. Statutes 751 of the Public School Code and Section 2 CFR 200.318(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a school district whereby the cost exceeds certain dollar thresholds as adjusted annually for an inflation index. The energy savings construction project exceeded the simplified acquisition threshold of $250,000. 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. RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, in specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. 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 specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. The timeframe for completion of this process will commence immediately and will continue on an ongoing basis as required by new policy directives from oversight agencies.

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 and 2) obtaining quotations from three qualified providers where applicable and documenting those results. These two (2) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

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 and 2) obtaining quotations from three qualified providers where applicable and documenting those results. These two (2) 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 Finding Subject: Child Nutrition Cluster ‐ Procurement and Suspension and Debarment Summary of Finding: Procurement procedures not met – Suspension and Debarment not verified Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: 812-254-5536 calford@wcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Washington Community Schools was under the impression that since Sodexo was the vendor for the purchases, the contract between Washington Community Schools and Sodexo was sufficient. Going forward, WCS will obtain contracts directly from the retailer even when Sodexo is the vendor in WCS files. If Sodexo makes purchases on behalf of WCS, they will obtain quotes from three retailers. WCS will request and maintain the quotes obtained by Sodexo. WCS will also check for any suspension and debarment for any vendor that Sodexo uses to purchase items for WCS. Anticipated Completion Date: 02/01/2024

Somerset County Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Audit Period: July 1, 2022 through June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING- MAJOR FEDERAL AWARD PROGRAM AUDIT U.S Department of Agriculture 2023-001 Paper/Chemical Product Contract Recommendation: The Board should follow its established procedure and policy providing for competitive bids. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Board has entered into a competitively sourced contract with FPC Holding, Inc. as of December 2023 for the purchase of these products. Name of contact person responsible for corrective action: Linda R. Johnson, Director of Finance Planned completion date for corrective action plan: December 1, 2023

FINDING 2023-008 Finding Subject: Special Education Cluster - Procurement and Suspension and Debarment Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. 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. The School Corporation had not designed or implemented a procurement policy for the purchases in the audit period. In addition, the school corporation did not award a contract for a purchase of $75,387. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. The School Corporation had not designed or implemented internal controls, policies, or procedures to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. One covered transaction that equaled or exceeded $25,000 was identified and selected for testing. Transactions to the vendor totaled $75,387; the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 50 Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: Create internal controls (using either SAMS website, certification from vendor, or clause/condition in contract) to ensure that vendors have been vetted and have not been suspended or debarred. Also develop processes to ensure that contracts for purchases over $50,000 are approved by the School Board. Anticipated Completion Date: To begin immediately, March 2024

FINDING 2023-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance for Procurement and Suspension and Debarment. For covered transactions, the School Corporation is required to verify that the person with whom they wish to do business with is not excluded or disqualified. In Fiscal Year 2022, there was one vendor where the School Corporation had one covered transaction in the amount of $55,285, and in Fiscal Year 2023, there were two vendors where the School Corporation had four covered transactions in the amount of $130,257. During testing and inquiry of the School Corporation, it was determined that for all three vendors who had a total of five covered transactions in the amount of $185,542 during the audit period, the School Corporation did not verify if they were excluded or disqualified prior to entering into a covered transaction. In Fiscal Year 2022, the School Corporation purchased a box truck in the amount of $55,285; however, the School Corporation did not award a contract to the vendor per Indiana Code and the School Corporation was unable to provide supporting documentation to support that three quotes were obtained prior to purchasing the box truck. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: Create internal controls (using either SAMS website, certification from vendor, or clause/condition in contract) to ensure that vendors have been vetted and have not been suspended or debarred. Also develop processes to ensure that contracts for purchases over $50,000 are approved by the School Board. Anticipated Completion Date: To begin immediately, March 2024

Finding 2023-002 Procurement Corrective Action: TPOCC has updated its Finance Manual, inclusive of a procurement policy in compliance with Uniform Guidance (2 CFR Part 200). We have also had all management staff who deal with programs funded by Federal Funds attend training on Uniform Guidance. We will continue to have staff attend these training courses to ensure that they are familiar with the requirements of Uniform Guidance. We have also begun implementing a procurement system (Pairsoft Paramount Workplace) and anticipate a go live of April 1st, 2024. This will help ensure our procurement policies are implemented and followed uniformly. Person Responsible: Finance Director, Lacy Meneses and CFO, Will Goodall Timing for Implementation: Currently in progress and procurement software will Go Live on April 1st, 2024. Document ID: b51a2bdf940fc8367245121fabb689a6083edd8e9deb8925c16c8fec9313f6b8 Page 1 Summary Schedule of Prior Year Findings and Questioned Costs Turning Point of Central California, Inc. did not retain procurement records to support its assertion that it is contracting with vendors that provide the best prices. Turning Point of Central California, Inc. has not updated its procurement policy to comply with the Uniform Guidance (2 CFR Part 200). This finding was first reported in the June 30, 2021 audit, issued in June 2022, and Turning Point of Central California, Inc. did not have adequate time to implement its corrective action plan during the year ended June 30, 2023. Questioned Costs: None

2023‐005 Material Weakness in Internal Control over Compliance and Material Noncompliance with Procurement Condi􀆟on: The Organization does not have a written procurement policy. Additionally, there was no documentation to support a price analysis over the transactions tested or documentation supporting that vendors were reviewed for suspension and debarment. There was also no documentation for review of the procurement transactions tested. Cause: The Organization had turnover and limited staffing available. Management’s Response and Corrective Action Plan: Changing the personnel involved has solved much of the problem, also the full awareness of what needs to be retained has also been explained to management. Management intends to add a Director level executive in the spring of 2024 to fully review and revise where necessary all standard operating procedures, including that of procurement. If/when funds from federal sources are used, those expenditures will be reviewed monthly. Specifically, this will mean: -Maintain EIDL‐sourced funds in a separate bank/account - Have single authorization for any movement/usage of funds in EIDL account - If/when funds from EIDL are used, have a written statement for purposes and documentation produced for use at the time of request Responsible Individuals: -Maintain separate account – Marcia Meyer, CEO, in conjunction with Board Finance Committee - Authorization for use of funds – Marcia Meyer - Maintenance of records for use – Jennie Myers - Confirmation with use of funds per allowable uses per national guidelines – Jennie Myers - Reporting on monthly finance report – Jennie Myers Anticipated Completion Date: This process is underway and will be visible at the fiscal year‐end audit in June 2024

Finding Number: 2023‐001, 2022‐001, 2021‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager / Angelena Tabaha, Human Resources Manager Anticipated Completion Date: June 30, 2024 Planned Corrective Action: School did not have an HR Manager for school year 2022‐23 and the School recently hired an HR Manager. The Business Manager, with the help of the HR Manager, will ensure that School policies with sealed bids will be followed. The Business Manager will maintain all quotes  and  documentation  from  vendors.  The  School’s  current  policy  will  be  reviewed,  and  language will be added to address quotes and thresholds.

Assistance Listings number and program name: 10.691 Good Neighbor Authority Contact persons: Lucinda Andreani, Deputy County Manager and Flood Control District Administrator Anticipated completion date: June 30, 2025 Concur. The Coconino County Flood Control District (FCD) acknowledges price was not considered as a factor for contractor selection in the procurement of construction services for the Good Neighbor Authority program in accordance with 2 CFR 200 Subpart D Procurement Standards. A procurement was completed for construction-manager at-risk (CMAR) services, authorized by A.R.S. 28-7366, because the FCD believed at that time that the method would also satisfy the federal standards. The CMAR method bases selection on qualification and competence, does not allow for pricing to be requested or considered before making the selection, and transfers the risk of budget overages to the contractor by agreement to a Guaranteed Maximum Price (GMP). After selecting the contractor for Good Neighbor Authority construction projects, the FCD worked closely with the County’s contracted engineering firm to ensure that the GMP was reasonable and cost efficiencies were identified and implemented throughout all stages of the project. The County believes the prices paid as a result of the procurement are reasonable and no excess federal expenditures were made due to the non-federal procurement method that was used in error. FCD fiscal and management staff will receive formal training on 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, also known as the Uniform Guidance, to ensure its requirements are understood. Additionally, the FCD will implement written internal procurement procedures to be used for future procurements so that they are made in accordance with all applicable laws, regulations and policies. The County Finance Department has a designated grant accounting team specializing in compliance with Federal award requirements. The FCD will request technical assistance from this team prior to initiating any procurement with Federal funds to help make sure Federal regulations are considered and met. The Finance Department will provide training to all departments on Uniform Guidance requirements. Training will also be provided on the County’s procurement policies and procedures to help departments gain a complete understanding of the requirements for acquiring goods and services with federal funds. In line with the County’s decentralized finance model in which financial management staff are located within the departments, the responsibility to meet requirements specific to certain federal awards rests with the department that manages the award. The Finance Department will identify the source of funding for procurements requested by departments. Staff who are knowledgeable about Federal procurement requirements and the County’s procurement policies and procedures will review and approve the procurements involving federal awards.

OHA Procurement staff will verify all federal funded vendors are not suspended or debarred or otherwise excluded from participating in a transaction with OHA by checking the System for Award Management (SAM) Exclusions maintained by the General Servies Administration and available at SAM.gov. This procedure was implemented on a go forward basis on March 13, 2024.

Views of Responsible Officials and Planned Corrective Actions: The Organization will review procurement policies and procedures to address the recommendation noted. The Organization will also ensure that all documentation for procurement is saved in a central location digitally to ensure documentation is complete in the Organization’s records for all procurement decisions made.

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.

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 during the start of the 2023-2024 fiscal year and continuing forward. The District has contracted J. Martin & Associates, LLC (JMA) to provide business office accounting services. Representatives from JMA and the rest of the business office staff will monitor the implementation of noncompetitive procurement procedures to ensure that they are followed appropriately.

Finding Number: 2023‐002 Program Names/Assistance Listing Titles: Indian School Equalization, Indian Schools Student Transportation Assistance Listing Numbers: 15.042, 15.046 Contact Person: Aurelia Tapaha, Business Manager/Human Resource Manager; Stephanie Woody, Business Technician Anticipated Completion Date: July 2024 Planned Corrective Action: The School will revisit financial policies and procedures and strictly comply with procurement processes. There are specific requirements for different amounts of purchases. The School will review requisitions and ask for required documents before processing.

Recommendation: We recommend that the School review their Procurement policy and ensure that all missing federal requirements are included in their written policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Options Schools, Inc. will update the Procurement policy to include federal requirements. Name(s) of the contact person(s) responsible for corrective action: Jack Colwell Planned completion date for corrective action plan: July 1, 2023 If the U.S. Department of Education has questions regarding this plan, please call Jack Colwell, CFO at 463-238-1414. 18077 River Road, Suite 106 I Noblesville, IN 46062 I phone: 317.565.4350 www.optionsschools.

Finding 2023-001-Procurement, Suspension and Debarment Finding: The Foundation does not have a formal procurement policy under requirements of 2 CFR 200.317 through 200.327. The Foundation established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. We noted as part of our testing that there was no documentation that these policies and procedures were being followed. Corrective Actions Taken or Planned: The Foundation is in the process of developing a formal procurement policy to conform to 2 CFR 200.317 through 200.327. Further, the National Association of Social Workers, the supported affiliate of the Foundation has posted a position to hire a senior grants accountant who will be assisting in the development and implementation of policies and procedures around grants. The position will be reporting to the Accounting Manager and ultimately the Chief Financial Officer. Sekou Murphy, Chief Financial Officer, will be responsible for the corrective action plan that is anticipated to be completed by October 2024.