Corrective Action Plans

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 10.553, 10.555, AND 10.559 2023-004 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension, and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including procurement, suspension, and debarment requirements applicable to the child nutrition cluster federal program. During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its child nutrition cluster federal program 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 District is in the process of reviewing and updating its policies and procedures relating to procurement, 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 district personnel are following the requirements of the Uniform Guidance related to methods of procurement and maintaining appropriate documentation. Official Responsible – Sara Bratsch, Director of Finance. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Sara Bratsch, Director of Finance, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with procurement, suspension, and debarment requirements.

Suggested Actions: 2.1 Perform a review of Supplier Master Records for completeness. The validation of completeness will include but will not be limited to the initial suspension and debarment validation report on Supplier Master Record file, in accordance with CRS Supplier Master Record Management policies and procedures. Responsible Officials: Director of Global Procurement, DRD Operations, SCM RTAs, Head of Operations, Supply Chain Managers Completion Date: September 30th, 2024

Name of Contact Person - Mr. Michael Turek, Interim Superintendent Corrective Action - We will follow our policy for federal purchases subject to quotation/bid/sole source requirements moving forward. The district will follow the policy for obtaining three quotation/bid requirements for federal purchases. In the event purchases are made through cooperative purchasing programs, three quotes will be documented when federal purchases are disbursed. We also implemented processes to improve documentation relating to the “reason” and “cost analysis” of sole source noncompetitive procurement. Anticipated Completion Date - The District will implement the above procedure immediately.

Finding Summary: In connection with the audit procedures performed, it was noted that the Organization did not adequately maintain complete procurement file documentation (as required by 2 CFR 200.318) related to one vendor that was selected for testing. Responsible Individuals: Christa Beauchat, Chief Financial Officer Corrective Action Plan: Management is implementing processes to maintain adequate and required documentation (under the CFR) for the selection of existing vendors and all vendors selected in the future to evidence adherence to general procurement standards and to evidence that vendors have been verified as not suspended or debarred. Specifically, management will maintain a vendor file (with required documentation) for any vendors that meet the criteria under the CFR. Anticipated Completion Date: Ongoing

FIDING NO. 2023-003 PROCUREMENT SUSPENSION AND DEBARMENT CONDITION We examined one hundred percent (100%) of the disbursed made and charged to HEERF Institutional Aid for the fiscal year 2022-2023 and noted the following: 1) UPM did not have documentation related Schools are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 2) UPM made five (5) payments for $100,406.71 in advance for goods or services not received at the disbursement date. RECOMMENDATION The Institution should reinforce the established procedures and adhere to them before any payment is made for goods or services. The amount of $100,406.71 should be reimbursed to the U.S. Department of Education. In addition, UPM should be included in its procedures steps to adopting regulations, to verify that the vendor entity is not suspended or debarred or otherwise excluded from participating in the transaction. Corrective Action Plan: The UPM requested the documents from potential vendors that authorized them to do business in Puerto Rico. The selected company, Vitaltek, provided documents showing that it was established and compliant with the law, precisely the evidence that they were not debarred or suspended. The UPM has a procurement process titled " Reglamento para la Adquisici6n de Equipos, Materiales y Servicios No Personales de la Universidad Pentecostal MIZPA" that states the process for verifying debarment and suspension. Prepayments The UPM has analyzed each prepayment, and we have evidence that the services, equipment. and materials have been received. In addition to having the purchase orders, contract, and invoices, we have the equipment in our facilities in good condition and inspected per our internal procedures, titled "Reglamento para la Administraci6n de Propiedad Mueble (Equipo) de la Universidad Pentecostal Mizpa." Vitaltek was the only company that provided a quote and was selected due to the COVID-19 emergency. Their purchase condition required a prepayment for ordering and obtaining products. Regarding the Service Contract for the photocopiers, we recognize that it was paid in advance; however, to date, all services related to this contract that we have required have been offered in compliance with each of the clauses and agreements signed. The acquisition of this type of equipment comes with a multiyear plan and maintenance services included in the package, which is the industry standard and necessary for the institution's administrative and academic operations. Understanding the seriousness of the correct administration of these funds, the Dean of Administration will periodically evaluate compliance with any contract. If it is not complied with, we will proceed through legal action to quickly recover these funds. The UPM understands that it should not reimburse this money to the United States Department of Education because there is sufficient evidence to demonstrate that the funds have been used within legal parameters, that they have strengthened the University in academic and administrative and that from now on we will observe the following to comply with such an essential and necessary reservation. Corrective action plan to follow: All employees. including those in the office of the presidency, have been finally and firmly alerted that advance payments should be avoided or only considered in emergency situations. All employees authorized to reach contractual agreements will be trained on this topic, and the internal procedures will be reviewed and edited to address prepayments and emergency processes. We will appoint an employee in charge of managing all compliance documentation so that, together with the Dean of Administration and Finance, they can locate and group all the relevant standards and regulatory procedures and have the power to guide so that each of its recommendations is willingly observed. This will be supported by the requirements that always accompany each award. In addition, these officers will have the power to make external consultations with professionals familiar with these matters.

Management states there was a procurement policy in place during this time but will now document that policy consistent with the federal laws and regulations.

Finding Number 2023-003 • Significant deficiency in internal controls over compliance related to procurement. Federal Agency: U.S. Department of Commerce Program Title: Pacific Fisheries Data Program Assistance Listing Number: 11.437 Award Numbers: NOAA-NMFS-AK-2023-2007663 Award Period: October 1, 2022 to September 30, 2027 Criteria • 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Procurement Standards require that awardees use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. Condition/Context for Evaluation • IPHC's internal controls over procurement do not include the controls and procedures required by 2 CFR 200. Questioned Costs • Not applicable. Cause • IPHC has not yet modified its procurement policies with the requirements of the 2 CFR Part 200 Procurement Standards. Effect or Potential Effect • As a result, IPHC cannot be certain that procurements were conducted in accordance with the 2 CFR Part 200 Procurement Standards. Repeat Finding • Not applicable. Recommendation • We recommend that IPHC update its procurement policy to include all procurement requirements of 2 CFR Part 200. - Procurement standards 2 CFR 200 Subpart D or 200.318-200.327 - Requirement for documented policies consistent with standards 200.318(a) Contact Person(s): • Executive Director: David Wilson (david.wilson@iphc.int); • Assistant Director: Andrea Keikkala (andrea.keikkala@iphc.int) Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable. Corrective action planned: As this was the IPHC’s first full GAAP Audit, Single Audit of federal grant funds, and also our first year transitioned from a Cash-basis of accounting to an Accrual-basis of accounting, there are a number of policies and procedures that are in the process of being amended. It will take the Secretariat several months to bring our written process guides into alignment with “2 U.S. Code of Federal Regulations (CFR) Part 200”, as well as our Financial Regulations (2021) that will be considered for amendment at the upcoming 100th Session of the IPHC Finance and Administration Committee (FAC100) and subsequent 100th Session of the IPHC Annual Meeting (AM100) in late January 2024. During the 2nd quarter of FY2024 (1 January – 31 March 2024) the IPHC will undertake a thorough review of “2 U.S. Code of Federal Regulations (CFR) PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS” and update our procurement policies and processes accordingly. Anticipated completion date: Deadline: 1 April 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 internal controls over procurement and suspension and debarment Contact Person Responsible for Corrective Action: Dr. Tracy Lorey, Monica Young, April Hopf Contact Phone Number and Email Address: tlorey@gjcs.k12.in.us myoung@gjcs.k12.in.us ahopf@gjcs.k12.in.us 812-482-1801 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The school corporation will follow our Procurement policy in the future. Anticipation Completion Date: August 2024—Beginning of New School Year

Finding 2023-005 – Special Education Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Laura Hubinger, CFO-Greater Clark County Schools lhubinger@gccschools.com Jennifer Cato, Deputy Treasurer-Greater Clark County Schools jcato@gccschools.com Brooke Lannan, Director of Special Education blannan@gccschools.com Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: When service contractors are needed for these types of services, the district will solicit from additional vendors to see if types of services can be provided to meet the needs of our students in our district. Quotes will be obtained if vendors are capable of meeting requirements. If vendors are not available to meet the requirements for the services requested the attempt and contact information will be noted via memorandum to the CFO of the research of various providers and the results of the research and the reasons why a vendor is selected; additionally, notes will be provided as to why others did not qualify. There is a procedure already in place for checking for Suspension, Disbarment for selected vendor. Anticipated Completion Date: Immediately

Department of the Treasury, Passed through Utah Department of Workforce Services Federal Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award, including procurement, suspension, and debarment requirements. Condition: The Organization’s written procurement policies did not include all of the elements required by the Code of Federal Regulations 2 CFR 200.318-200. Cause: The Organization did not have internal controls in place to review the procurement policy and ensure it complies with federal requirements. Effect: The risk is increased that a procurement noncompliance could occur. Questioned Costs: None reported. Context/Sampling: Nonstatistical sampling was used. Sample size was three of seven procurement transactions above the micro-purchase threshold and included contracts totaling $5,707,820 of federal awards. Repeat Finding from Prior Year(s): Yes, Finding 2022-002 Recommendation: We recommend the Organization implement internal controls to review the procurement policy periodically to ensure it is consistent with federal requirements. Views of Responsible Officials: Management agrees with this finding.

Department of the Treasury, Passed through Utah Department of Workforce Services Federal Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Reporting Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Organization’s internal controls over reporting did not include documentation of a review of quarterly reports submitted to the awarding agency. Cause: The Organization did not have internal controls in place to document review of the quarterly reports, including review of the amounts reported.Effect: The risk is increased that reported amounts could be misstated. Questioned Costs: None reported. Context/Sampling: Nonstatistical sampling was used. Sample size was three of the four quarterly reports and three of the nine monthly reports. Repeat Finding from Prior Year(s): Yes, Finding 2022-001. Recommendation: We recommend the Organization implement additional internal controls over review, approval, and monitoring of reporting requirements under federal awards. Views of Responsible Officials: Management agrees with this finding.

Finding 2023-001 – Special Educa􀆟on Cluster – Procurement and Suspension and Debarment Subject: Special Education Cluster (IDEA) Audit Findings: Material Weakness, Other Matters Condition and Context: The School Corporation is a member of the Delaware-Blackford Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education preschool program and spent the federal money on behalf of six of its seven members. As the grant agreements were between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. Two vendors exceeded the small purchase threshold during the audit period. The Cooperative provided evidence of a quote being obtained for the first vendor, however, evidence of obtaining multiple quotes was not retained for audit. The chosen quote was attached to the accounts payable vouchers and provided for audit; however, the other quotes obtained for the purchase were not maintained. For the second vendor, the Cooperative determined psychological services were to be provided by a single source provider, however, they did not have a documented rationale or support for the decision. Documentation detailing the history of procurement, which must include the reason for the procurement method used, selection of the vendor, and the basis for the price, was not available for audit for either purchase. Suspension and Debarment The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As such, the Cooperative entered into a contract totaling $32,388, which exceeded $25,000, for psychological services. The Cooperative did not perform procedures to ensure that the vendor was not suspended or debarred from participation in federal programs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Official: We concur with the finding. Descrip􀆟on of Correc􀆟ve Ac􀆟on Plan: As a member of the Delaware-Blackford Special Educa􀆟on Coopera􀆟ve (DBSEC), Yorktown Community Schools will obtain in wri􀆟ng from Muncie Community Schools that their correc􀆟ve ac􀆟on plans for procurement and suspension and debarment have been implemented. Responsible Party and Timeline for Comple􀆟on: Greg Hinshaw, Superintendent of Yorktown Community Schools and DBSEC Board Member. Timeline for comple􀆟on March 31, 2024

Finding 2023-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2023-002. Washakie County is currently working on implementing a more thorough tracking procedure in order to document all of the significant processes for our federal awards. Also, in order to further track funds disbursed, a sams.gov account has been set up and is currently utilized in order to determine if an entity is eligible for disbursement of federal funds. An amendment to implement sams.gov utilization will be produced in order to add it to our current Procurement Policy.

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Procurement, Suspension, and Debarment Summary of Finding: Material Weakness, Other Matters The School Corporation had not properly designed or implemented an effective system of internal controls to prevent, or detect and correct, noncompliance. Procurement: A School Nutrition Cooperative (Co-ops, Education Service Center, Group Purchasing Organization, etc.) that would like to be classified as a School Food Authority (SFA) Cooperative must complete a questionnaire and submit it to the Indiana Department of Education (IDOE). Once a questionnaire is received IDOE will review the answers to determine a Cooperative’s classification. Only Cooperatives that submit the questionnaire and receive a SFA-only Cooperative classification from IDOE in writing will be considered a SFA only Cooperative for the purposes of the procurement process and procurement reviews. When the value of goods or services exceeds the simplified acquisition threshold, the proper purchasing method would be the bidding process, unless the purchase meets certain other qualifications. Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The School Corporation purchased milk through Region 8 Education Service Center (Region 8). However, Region 8 had not received the SFAonly Cooperative classification from IDOE for fiscal years 2021–2022 and 2022-2023. As such, the School Corporation could not rely on the procurement done by Region 8. Region 8 could be considered one quote for procurement; however, the School Corporation did not obtain any other quotes related to the purchase of milk, therefore, an adequate number of quotes from qualified sources was not obtained. 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. INDIANA STATE BOARD OF ACCOUNTS 47 MADISON-GRANT UNITED SCHOOL CORPORATION Steve Vore., Superintendent Ben Mann, Chief Financial Officer Kristy Drewitz, Transportation Allison McGuire, Payroll/Benefits Anna Richards, Corp Secretary/Deputy Treasurer Inspire, Cultivate, and Promote excellence in every Argyll. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation noted that vendor’s were checked against Sam. Gove and verified to not be suspended or debarred. Four covered transactions that equaled or exceeded $25,000 were identified. All for transactions, totaling $213,795, were selected for testing. For three of the four vendors, the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The total amount spent with the three vendors was $162,733. Contact Person Responsible for Corrective Action: Kathy Bernaix Contact Phone Number and Email Address: 765-536-0008 kbernaix@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement: Three quotes will be requested for “small purchases” and the process will be reviewed to ensure it is performed. Suspension and Debarment: Before purchasing goods that total $25,000 or more from a vendor, the Food Service Director will look up the vendor on SAM.gov for debarment activity. Anticipated Completion Date: February 2024

Management’s Response and Planned Corrective Actions: 1. The corrective action planned: a. Internal control document and procedure that is consistent with the compliance requirement for: i. CFR §200.318, General procurement standards identify all requirements which the offerors must fulfill and all other factors to be used in evaluating bids or proposals i. §200.319, Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements ii. §200.320 Methods of procurement to be followed. 2. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Sr. Director of Finance, ShelterCare 3. The anticipated completion date: a. The written policies will be updated by 05/01/2024.

Planned Corrective Action: This item was included in the 6/30/22 Report on Compliance for Major Federal Programs which was finalized in February 2023. The G/L Vendor List was found to contain many inactive vendors and was modified. Beginning in October 2023, management began sending the Vendor List to EPStaffCheck on a monthly basis. Each vendor is run through OIG {Office of Inspector General for Excluded Individuals/Entities); OIG_Most_Wanted (Fugitives); SAM (System for Award Management for excluded parties); SON.Office of Foreign Assets Control (Specially Designated Nationals) and NY_Medicaid (Exclusion List).

Finding 2023-002 – Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Sandy Denny – Food Service Director Contact Phone Number: 812-952-2555 ext. 250 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all procurements obtain the required number of quotes and a debarment/ suspension check is performed as required. Anticipated Completion Date: July 2024 (new school year)

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.

2023-004 – Procurement, Suspension and Debarment Cluster: Research and Development Sponsoring Agency: NASA, National Science Foundation (NSF), Department of Energy (DOE), National Institutes of Health (NIH), Department of Health and Human Services (DHHS) Award Names: Various Award Numbers: NNX17AB45G, 2137984, 2230861, DE-SC0010064, DE-SC0022559, R01MH115979-05, 1R01DA054967-01A1, 1R01DK132735-01, 3UM1AI068636-15S3, 5R01HL155905-03, 5R01GM143536-03, 2RF1AG048120-06R, 5UM1AI106701-10R2 Assistance Listing Titles: Science, Mathematical and Physical Sciences, Biological Sciences, Office of Science Financial Assistance Program, Mental Health Research Grants, Drug Abuse and Addiction Research Programs, COVID-19 - Trans-NIH Research Support, COVID-19 - Allergy and Infectious Diseases Research, Allergy and Infectious Diseases Research, Biomedical Research and Training, Aging Research Assistance Listing Numbers: 43.001, 47.049, 47.074, 81.049, 93.242, 93.279, 93.310, 93.855, 93.859, 93.866 Award Year: 2022-2023 Pass-through entity: N/A all are direct awards On January 2, 2024, the University's Procurement system, BruinBuy Plus, was updated to incorporate additional controls. When purchase requests are made, the system will identify any transactions over $10,000 involving federal sources and send them to the central Purchasing unit for review. Before these transactions are approved, the central Procurement Buyer must ensure that all necessary documentation and checks are completed. Spot checks are also performed by managers as an additional level of review. All relevant documentation, including quotes, price reasonableness, and Statements of Work, are now stored within BruinBuy Plus along with the transaction. In conjunction with the new system, Central Buyers received training from November 27, 2023, to December 22, 2023, for two hours daily.The Chief Procurement Officer has acknowledged that additional training is necessary and will be scheduled this spring. For inquiries regarding this finding, please contact Selina Martin at selinamartin@finance.ucla.edu who is responsible for the corrective action.

COVID 19 Coronavirus State and Local Fiscal Recovery Funds/ ALN 21.027 - Significant Deficiency - Internal Controls over Procurement Prior to purchase, Sarasota County worked with the State of Florida Medical Examiner to create and document procurement policies in conformance with the Uniform Guidance, to include sourcing of quotes, issuance of purchase orders, and certifications by vendors on acknowledgment and adherence to applicable 2 CFR requirements. The County acknowledges that the State of Florida Medical Examiner conformed with these requirements prior to purchase to include noncompetitive purchases which was further supported in a dated letter provided by the Chief Medical Examiner. The Program Division Manager, Steve Hyatt shall require and retain such additional documentation within its procurement files and will conform to sourcing this documented information for these instances prior to any future purchases. Implementation date for this process - Immediately

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micropurchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The Cooperative did not adhere to the requirements necessary for them to be in compliance with the procurement of small purchases during the audit period. Suspension and Debarment The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As such, the Cooperative never entered into a contract, although their payments to the vendor exceeded $50,000. The INDIANA STATE BOARD OF ACCOUNTS 30 Cooperative did not perform procedures to ensure that the vendor was not suspended or debarred from participation in federal programs. Contact Person Responsible for Corrective Action: Lana M. Miller Contact Phone Number and Email Address: Phone Number-812-689-6282 Email- lmiller@sripley.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ROD Special Education Cooperative will make notes in the Board Minutes regarding the fact that only one vendor can provide specific services prior to entering into a contract or purchasing said services. Each company providing services will be checked on the SAM.gov website to ensure that the vendor has not been suspended or debarred. This documentation will be provided to the ROD board for review, and our Superintendent is a member of that board. Anticipated Completion Date: February 1, 2024

2023-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is in the process of enhancing the federal procurement policy to include sections 200.318 through 200.326. Name of the contact person responsible for corrective action: Shannon Marimón Planned completion date for corrective action plan: February 29, 2024

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 2022-003 Noncompliance – Procurement and Suspension and Debarment (Repeat Finding 2022-003) Significant Deficiency Recommendation: The Auditor recommended the Organization develop a system of internal controls aligned with the applicable compliance requirements to sufficiently document procurements and to ensure suspension and debarment is considered prior to entering into future covered transactions. Planned Corrective Action: While procurement requirements are followed, management concurs that the documentation of procurement activities does not always occur. The Accounts Payable will gather all procurement documentation with the purchase order request. Michelle Krauter, the Director of Accounting & Finance, will approve all purchase order requests. This documentation will be retained with the approved purchase order and invoices. Michelle will ensure all compliance requirements are followed and appropriately documented. If the U.S. Department of Education has questions regarding this plan, please call Michelle Krauter, Director of Accounting & Finance at 317.231.0010

Finding 2023-003 – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Michelle Babcock Contact Phone Number: 317-392-2505 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We have already established an improved internal controls procedures for procurement. We have established a checklist process to ensure the Suspension and Debarment Check has been completed for all federal purchases over the threshold. Anticipated Completion Date: October 2022

Corrective Action Planned: When the District decides to utilize cooperative purchasing programs on noncompetitive purchasing arrangements when spending federal funds, it will ensure that it complies with its procurement policy. The District will document its process and how it complies with the procurement standards and keep such documentation with federal award budget/procurement documents. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding for the year ending June 30, 2024. Contact Person Responsible: Eric S. Petery, Business Manager