Corrective Action Plans

September 27, 2024 Borough of Sharpsville State Single Audit Corrective Action Plan For the Fiscal Year Ended 2023 Federal Audit Clearinghouse Re: Corrective Action Plan for Borough of Sharpsville To whom it may concern: AUDIT FINDINGS Finding Reference Number: 2023-001 Description of Finding: No documented procurement procedures Statement of Concurrence or Nonconcurrence: The Borough of Sharpsville agrees with the finding in Borough of Sharpsville 2023 Single Audit Report Schedule of Findings. Corrective Action: The borough will revise its outdated procurement policy to comply with all state and federal programs which meet uniform guidance. Name of Contact Person: Kenneth P. Robertson, Borough Manager-Secretary/Treasurer (724) 962-7896 krobertson@sharpsville.org Projected Completion Date: Borough of Sharpsville anticipates resolving the audit finding by resolution of borough council at its November 2024 meeting. Any questions or concerns should be directed to Kenneth Robertson at (724) 962-7896. Sincerely yours, Kenneth P. Robertson Borough Manager-Secretary/Treasurer

FINDING 2023-001 Finding Subject: Special Education Cluster – Procurement, Suspension, and Debarment Summary of Finding: The School Corporation did not obtain price or rate quotes for the four vendors tested that was less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. There was no evidence of the School Corporation verifying two vendors tested for Suspension and Debarment that these vendors were not excluded or disqualified from participation in federal assistance programs or activities. Contact Person Responsible for Corrective Action: Matt Miles Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This is a repeat finding due to the immediate timing of the prior audit and a lag for new controls to take effect. The School District will obtain 3 quotes or do a bid process in the future. If there is limited availability, we will document the reason 3 quotes are not possible. Additionally, the District will check for suspension and debarment, create a write-up of our findings, and obtain Board approval for the contract. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should follow established written policies and procedures regarding procurement and properly document the process for each procurement made. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments and the following actions have been taken to improve the situation. We hired a Contracts & Compliance Manager in 2024 who is now responsible for ensuring the procurement process is properly documented for each procurement made. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Cho Heide, Contracts & Compliance Manager Plan completion date for corrective action plan: September 30, 2024

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review and modify the procurement policy and conflict of interest policy and make all necessary changes for compliance. Name of the contact person responsible for corrective action: Michael Riso, CFO Planned completion date for corrective action plan: June 30, 2024

Finding Number: 2023-001 Finding Title: Procurement, Suspension and Debarment Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) (Journey to Independence) Name of Contact Person Responsible for Corrective Action: Jolene Lambert, Finance and Benefits Coordinator Corrective Action Planned: To ensure consistency in managing sponsored projects, PACT for Families Collaborative implemented a procurement policy effective June 25, 2024, per Uniform Guidance Procurement Standards. In October 2023, we transitioned to an updated expenditure authorization process that includes a revised Expenditure Authorization Form (EAF) that requires pricing from multiple suppliers to document and secure the most reasonable purchase. While suspensions and debarments have been checked through SAM.gov for several years, printouts of the verification process were not retained. As of August 29, 2023, printouts are now kept as official documentation. The one micro-purchase identified during the audit occurred before this date. Anticipated Completion Date: August 29, 2023

FINDING 2023-004 Finding Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Summary of Finding: The County did not have documented procurement procedures or policies reflecting applicable State or Federal laws and regulations for procuring goods and services paid with Federal funds. One vendor was identified that fell within the small purchase threshold, with total purchases of $33,100. Price or rate quotations were not obtained, nor was full and open competition provided for the vendor. Additionally, there was no documentation available to support the rationale to limit competition. One vendor was identified that fell within the Simplified Acquisition Threshold, with total purchases of $213,734. Sealed bids or competitive proposals were not obtained, nor was a circumstance met that would have allowed for a noncompetitive procurement for the purchases. The County did not have any policies or procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded. A population of six covered transactions, totaling $470,435, that equaled or exceeded $25,000 paid from SLFRF funds was identified. Four of the six covered transactions, totaling $312,745, were selected for testing. For each of the four transactions, the County did not verify the vendors' suspension or debarment status prior to payment due to the County not having any policies or procedures in place to verify that contractors were neither suspended nor debarred, or otherwise excluded or disqualified, from participating in federal assistance programs or activities. Contact Person Responsible for Corrective Action: Janet Chadwell Contact Phone Number and Email Address: 812-663-2570 jchadwell@decaturcounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have begun a procurement policy discussion with our county attorney who is working us on that. We will include in this procurement policy requirements to all entities requesting grant funds to provide documentation of requests for proposals, quotes and or sealed bids and explanations on why vendor was chosen. A procedure for proof of a vendors’ no suspensions or debarments from receiving federal funds will be also be added to this “policy in progress”. We will implement internal controls to ensure that the established procurement procedures are followed to ensure open competition. Anticipated Completion Date: December 31, 2024

FINDING 2023-003 Finding Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Summary of Finding: The County did not have documented procurement procedures or policies reflecting applicable State or Federal laws and regulations for procuring goods and services paid with Federal funds. One vendor was identified that fell within the small purchase threshold, with total purchases of $117,144.20, of which $7,144.20 was paid from the State and Local Fiscal Recovery Funds received from the Indiana Department of Homeland Security. Price or rate quotations were not obtained, nor was full and open competition provided for the vendor. Additionally, there was no documentation available to support the rationale to limit competition. Contact Person Responsible for Corrective Action: Janet Chadwell Contact Phone Number and Email Address: 812-663-2570 jchadwell@decaturcounty.in.gov INDIANA STATE BOARD OF ACCOUNTS 29 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have discussed a procurement policy with our county attorney who is working us on that. We will present a draft policy to the Commissioners hopefully by mid- November. We will implement internal controls to ensure that the established procurement procedures are followed to ensure open competition. Anticipated Completion Date: December 31, 2024

A tracking procedure has been developed and a written procurement policy will be approved prior to the end of fiscal 2024 to further define procurement processes to align with Federal program standards and Village ordinance to address this deficiency.

Schedule of Corrective Action Plan For the Year Ended June 30, 2023 Finding 2023-003: Significant deficiency over Procurement and Suspension and Debarment Responsible Official’s Response and Corrective Action Plan We concur with the finding. BCI has an informal process of reviewing vendors and determining if they have been suspended or debarred. However, there is not a formal process where proper documentation such as screenshots of the search are saved. Due to the transition in the accounting department, we were not aware of these specific criteria at the time. We were notified of these requirements after the end of fiscal year 2024. To address these issues, we will implement a comprehensive process during fiscal year 2025 to ensure proper documentation and compliance with procurement regulations. This process will include: 1. Ensuring that all sole source vendor selections are properly documented and justified. 2. Verifying and maintaining records that confirm vendors are not debarred or suspended from doing business with the Federal Government before entering into contractual agreements. We are committed to improving our procedures and ensuring compliance with all applicable regulations moving forward. Planned Implementation Date of Corrective Action Plan September 1, 2024 Person Responsible for Corrective Action Plan Caryn York, Executive Director

Finding 2023-001: Significant deficiency over Procurement and Suspension and Debarment Responsible Official’s Response and Corrective Action Plan We concur with the finding. Due to the transition in the accounting department, we were not aware of these specific criteria at the time. We were notified of these requirements after the end of fiscal year 2023. To address this issue, WE in the World implemented a procurement policy as of March 2024. We will continue to use this comprehensive process during fiscal year 2024 and beyond to ensure proper documentation and compliance with procurement regulations. This process will include: 1. Ensuring that all sole source vendor selections are properly documented and justified. 2. Verifying and maintaining records that confirm vendors are not debarred or suspended from doing business with the Federal Government before entering into contractual agreements. We are committed to improving our procedures and ensuring compliance with all applicable regulations moving forward. Planned Implementation Date of Corrective Action Plan Instituted March 2024 Person Responsible for Corrective Action Plan Marta Bustos Kuperwasser Finance Director

Finding Number: 2023-003 Finding Title: Procurement Policy Program: 20.205 Highway Planning and Construction Name of Contact Person Responsible for Corrective Action: Kit Johnson, County Auditor/Treasurer Corrective Action Planned: Traverse County has updated their procurement policy to comply with the latest changes in the law. Anticipated Completion Date: Completed, May 21, 2024

The Board acknowledges the finding related to the evaluation of potential contractors for debarment and suspension under Finding 2023-002. We understand the importance of ensuring that contractors paid with federal dollars are not suspended or debarred to maintain compliance with federal requirement. We will establish a procedure to review the System for Award Management (sam.gov) for debarment, suspension, or exclusion status for all potential contractors before entering into contract. The Board will train relevant procurement staff on the new procedure to ensure consistent application and understanding of the debarment verification process.

The Board acknowledges the finding related to procurement practices under Finding 2023-001. We recognize the importance of adhering to federal procurement requirements, specifically those outlined in 2 CFR 200.319(d), to ensure compliance and maintain the integrity of federal funds. Management will review and update policies to ensure they align with federal regulations specified in 2 CFR 200.319(d) and will provide training to relevant personnel on federal procurement requirements.

Management’s response and corrective action is as follows: Purchasing Department has implemented the following corrective actions to avoid this in the future: requisition checklist outlining guideline for compliance; creating standard operating procedure for purchase of vehicles for City-Parish Agencies; conduct routine departmental training; ensure that supervisor approvals prior to bid release. Expected Implementation Date: June 2024 Contact person: Paul Narcisse, Purchasing Director, Office of Purchasing

Management agrees with the auditors’ comments, and the March of Dimes (MOD) has taken the following steps to strengthen the related internal controls. Due to transitions in personnel and decentralized filing systems the supporting documentation for the competitive bid process/sole source justification related to two procurement transactions and the suspension and debarment check related to one procurement item were not maintained. To address the document retention concerns MOD stood up Asana, a grant tracking system, during 2023 for project management and implemented a 7-step checklist for grant funded procurement that includes a centralized housing location for documentation. Asana and the complementary process were fully implemented in October 2023 with compliance overseen by the Office of Sponsored Projects (OSP) with regular support, guidance, and periodic validation from the Finance Office through weekly meetings with the Director of Grants Accounting. To further expand MOD staff knowledge and expertise regarding federal grant management, by the end of October 2023, all key finance and program personnel using grant funds for salary or other expenses and/or fulfilling grant goals and deliverables received a certificate for completing the Center for Disease Control Foundation’s Federal Grants Management training. By December 2024, MOD will host a virtual Federal Grant Management staff training for all key finance and program personnel that use federal grant funds. This training will include the recent revisions to 2 CFR 200. Beginning in January 2024, MOD also implemented grant on-boarding for staff using grant funds as new grant awards are received.

Contact Person – Lisa Prachar, VP/CFO Corrective Action Plan – East Central Energy and Subsidiaries is currently developing a written procurement plan that adheres to minimum standards. Completion Date – December 31, 2024

Corrective Action Planned: The Organization will draft, adopt, and implement a procurement policy. Anticipated Completion Date: September 17, 2024 Responsible Parties: Board of Directors

Management will strengthen its processes and internal control to ensure that report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. In addition, Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards and that all relevant documentation will be retained. Christopher Caulfield, Executive Director of Financial Operations, will effectuate the corrective action plan, which is anticipated to be completed by December 31, 2024. caulfieldc@sjhmc.org 973-754-2016

FINDING 2023-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: The City did not obtain price or rate quotes for the one vendor tested that was less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. The micro-purchase threshold may be increased, but the City did not provide documentation that the threshold had been increased. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. A population of 9 covered transactions for goods or services were paid from Coronavirus State and Local Fiscal Recovery Fund funds during the audit period. A sample of 3 transactions were selected for testing. Of the 3 transactions tested, 1 vendor was not verified to not suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. Contact Person Responsible for Corrective Action: Craig Wright - Controller Contact Phone Number and Email Address: 765-747-4828 cwright@muncie.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Correcting the audit findings is ongoing. The city has implemented monitoring procedures to review and prevent reoccurring errors. Anticipated Completion Date: The internal control monitoring and checks and balances will be implemented immediately and continue going forward.

Title of result and comment:: Frankton FINDING 2023‐003 Contact person Responsible for Corrective Action: First Name: Timothy Last Name: Detrick Contact’s Phone Number:: (765) 754‐7285 Contact’s Email Address:: tdetrickct@gmail.com Views of Responsible Official:: We concur with the finding. Description of Corrective Action Plan:: All contract we make will start going through, Checking SAM Exclusions; or Collecting a certification from that person; or Adding a clause or condition to the covered transaction with that person". We will also add a clause that any Federal Government Grant will buy America Preference Material. Anticipated Completion Date: Year: 2024 Month: 5 Day: 14 If applicable: Document reason issue will NOT be corrected within 6 months:: INDIANA STATE BOARD OF ACCOUNTS 32 Unit Name: Town of Frankton County: Madison Report period beginning date: Year: 2023 Month: 1 Day: 1 Report period ending date: Year: 2023 Month: 12 Day: 31

FINDING 2023-05 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: No procurement policy is in place and vendors were not confirmed to not be suspended or debarred. Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will start checking all vendors paid from grants for suspension, debarred or excluded from being able to enter into contracts. Additionally, a procurement policy will be put into place. Anticipated Completion Date: August 30, 2024

Contact Person - Pattie Solberg, Auditor; Corrective Action Plan - The City will implement a written procurement policy that follows Uniform Guidance and will review vendors for suspension and debarment before entering into covered transactions. Completion Date - December 1, 2024.

Management Response The Garden followed the procurement requirements of the OMB and Uniform Guidance but did not codify its policy in writing. Corrective Action Plan: The procurement policy is now written. Education of and reverification of the federal procurement processes will be provided to all Principal Investigators and others involved in Grant Management by August 31, 2024. Contact person(s) responsible for the corrective action: Diane Wondolowski, Director of Finance, dwondolowski@sbbotanicgarden.org Anticipated Completion Date: The policy is in writing. Education will be complete by August 31, 2024.

FINDING 2023-003 Finding Subject: COVID 19 Procurement Suspension and Debarment Summary of Finding: We did not have a policy for procurement and debarment for federal funds Contact Person Responsible for Corrective Action: Amy Roberts Contact Phone Number and Email Address: ARoberts@dalevilleindiana.org 765-378-6288 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will create a policy for future federal fund expenditures Anticipated Completion Date: March 1, 2025

Corrective action plan: Management believes that the procurement process has improved during the last year. The threshold for obtaining quotes was raised to $10,000 from $2,000, so there are significantly fewer transactions to monitor for compliance. The program managers are practicing more price comparison and obtaining quotes for purchases over $10,000, but not in every instance. The Finance Manager and the Accounts Payable Clerk will continue to monitor the documents submitted with purchase requests. Finance will not issue a check for payment to a vendor over $10,000, unless an adequate number of quotes and/or a sole source justification for the purchase has been submitted to document compliance with procurement standards For purchase requests over $10,000, the Finance Manager will perform a search of the database records on Sam.gov to determine if a vendor has been suspended or debarred. The Finance Manager will note on the purchase request the status of the organization according to Sam.gov and the date of the search. For those entities that are determined to be suspended or debarred, the purchase will not be approved. Personnel responsible for corrective action: Lisa Donham (Finance Manager), Deidre Moyer (Accounts Payable), and Program Managers Estimated corrective action completion date: December 31, 2024