Corrective Action Plans

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.

CONDITION: The Moniteau School District contracted with a third-party vendor (Smart Solutions Technologies) for technology equipment (Smart Boards and Mobile Carts) for the District which 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. 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. In addition, I am recommending that management contact the PA Department of Education, and explain the circumstances and oversight, and seek direction as to the allowability of this program cost in writing for their permanent files. 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 be finalized during the District’s 2024-2025 fiscal year and will be revised on an ongoing basis as required by new policy directives from oversight agencies.

Management has already been working with legal counsel and the board to develop a formal policy to put in place, with a planned implementation date of July 25, 2024.

Finding 2023-003 - Procurement, Suspension and Debarment (COVID-19 American Rescue Plan Act Local Fiscal Recovery) Significant Deficiency – Internal Control over Compliance Other Matters (Noncompliance) Description of Finding - The City’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or NonConcurrence - Management agrees with this finding. Corrective Action - The City has implemented a revised procurement policy which addresses the essential elements of uniform guidance, including suspension and debarment. However, the policy was not in place for all of the current year. Name of Contact Person - John Monks, Comptroller Projected Completion Date - June 30, 2024

1) Management will review procurement policies with staff 2) Timely action will be taken to solicit bids for contracts that exceed District thresholds. 3) To ensure full and open competition takes place, management will routinely review current contracts and spending reports to identify expenditures that exceed the dollar amount threshold to individual vendors. Anticipated completion date: June 30, 2024 Responsible contact person: Emily Johnson

2023-005 – Procurement Material Weakness in Internal Control over Compliance; Other Matters Procurement documentation has been developed and shared with all Department Heads along with directives of utilizing documentation to properly vet in procurement practices for any expenses over the $25,000.00 threshold. Person responsible for correction action plan: County Board Administrator Date corrective action plan is being implemented: Tuesday, June 25, 2024

Corrective Action Plan: Testing of procurement, suspension, and debarment was accomplished timely in most cases and leadership will continue to engage and teach agency staff to follow existing procurement policies to assure compliance. No further policy is necessary. Staff training will be strengthened. Responsible Individuals: Dr. Kenneth D. Varble – Vice President of Accounting Anticipated Completion Date: December 2024

Management agrees with the finding. Our current federal project is substantially completed, however, should the Township receive additional federal construction grants, the Township will implement controls to ensure verification of debarment, suspension, or exclusion takes place before entering into a covered transaction and that documentation is maintained. The anticipated date of completion is prior to receiving another federal construction grant award.

Management agrees with the finding. Our current federal project is substantially completed, however, should the Township receive additional federal grants, the Township will adopt the required written procedures. The anticipated completion date is prior to receiving another federal award.

Management thought the bidding for the Township engineer a number of years ago, met the bidding requirements. In the future, if the Township obtains any federal grant that requires engineering services, the Township will make sure that we bid engineering services. The anticpated completion date is prior to receiving another federal grant award requiring engineering services.

Finding 2023-002 U.S. Department of Education Condition: Two vendors were awarded a contract through a sole source procurement without a written determination that only one practicable source existed and the reasoning for such a determination. Corrective Action Planned: The School will implement procedures to include in its procurement files a written determination for all sole source procurements. Anticipated Completion Date: Immediately Contact: Gilbert Lefort III, Director of Finance, North Attleborough Public Schools

Views of Responsible Officials:This instance was largely due to staff turnover. ASCB will train all grant-related and all finance staff in proper processes and procedures based on contract price thresholds. This will create awareness throughout both departments which will result in everyone taking ownership of the process and not being reliant on any one staff member.