Corrective Action Plans

COVID-19 State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the City reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will work with their departments utilizing federal dollars to ensure the proper procurement method is utilized for all procurements and that documentation of that process is retained so it’s clear what considerations were made in the procurement decision. Name of the contact person responsible for corrective action: Pa Thao Planned completion date for corrective action plan: December 31, 2024.

Views of Responsible Officials: New audit procedures were established for the FY 2023 audit related to federal procurement testing that generated these findings. Management is aligned with the findings from the audit firm. We have the following takeaways. Vendor Screenings: Vendor screening procedures are part of our current procedures, but we will make process improvements:  In accordance with the Suspension and Debarment compliance requirements (section M-12 & M-14) of the USAID Cooperative Agreement, JGI-USA and JGI-Tanzania will process and retain vendor screenings before payment to vendors.  The following sources will be used for screenings:  SAM.gov  OFAC sanctions list  UN List  We will retain the evidence of the screenings, including the dates of the screenings, within our files and these will be available for subsequent audit procedures.  Our Procurement Policy in Tanzania and the USA will be updated to include these required procedures. Procurement Documentation: JGI-USA and JGI-Tanzania have procurement procedures and policies in place, but our procedures need to be updated to include some specific considerations:  When a partner or vendor is included in a proposal by name, we must prepare documentation that supports sole source procurement or a bid analysis to justify the selection of this partner. Alternatively, we may work with the donor to obtain written approval to proceed with the vendor used in proposal.  We will update our procurement manuals to include templates for sole source justifications and bid analysis to justify vendor selection and fully comply with §200.320.  Our Procurement Policies will be updated to fully comply with §200.320 and §200.213

Finding 2023-004 – Procurement Policy Criteria: In accordance with Uniform Guidance 2 CFR, Part §200.318 "General Procurement Standards", the non-federal entity must have and use documented procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a federal award or subaward. The non-federal entity's document procedures must conform to the procurement standards identified in 2 CFR, Part §200.317 - §200.327. Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327 Questioned Costs: None Cause: The Coalition was unaware of the changes in General Procurement Standards within Uniform Guidance and therefore does not have sufficiently established control policies and procedures to comply with 2 CFR, Part §200.317 - §200.327. Effect: The Coalition does not have the ability to determine if disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327. Recommendation: We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.317 - §200.327. and establishes appropriate internal control policies and procedures related to procurement and that all staff be trained in those policies and procedures, so they are familiar with the requirements. We further recommend no contract or agreement be awarded by the Coalition in which appropriate procurement policies have not been followed Corrective Action: In response to the finding regarding non-compliance with procurement policies as outlined in 2 CFR, Part §200.317 - §200.327, the Coalition will take the following corrective actions: 1. Review and Update Procurement Policies: o The Coalition will conduct a comprehensive review of its current procurement policies and procedures. We will update these policies to ensure full compliance with Uniform Guidance 2 CFR, Part §200.317 - §200.327, as well as any relevant state, local, and tribal laws and regulations. o We will review and update detailed procedures. These procedures will be clearly aligned with the standards identified in 2 CFR, Part §200.317 - §200.327. 2. Training and Education: o All staff involved in the procurement process will receive training on the updated procurement policies and procedures. This training will ensure that all relevant personnel are familiar with the requirements of Uniform Guidance 2 CFR, Part §200.317 - §200.327, and understand their responsibilities in adhering to these standards. 3. Implementation of Internal Controls: o The Coalition will implement internal controls to ensure compliance with the updated procurement policies and procedures. This will include establishing a review and approval process for all procurements to verify adherence to the new standards. 4. Monitoring and Compliance Checks: o We will establish a system for ongoing monitoring and compliance checks to ensure that all disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327. Quarterly audits will be conducted to identify and address any deviations from the established policies and procedures. Timeline for Implementation: The corrective actions outlined above will be implemented within the next 30 days. The review and update of procurement policies and procedures will be completed within this period, and training sessions for relevant staff will be conducted immediately following the implementation of these changes. Internal controls and monitoring systems will be established concurrently. Contact Information: For further information or questions regarding this corrective action plan, please contact: Carlett Gregory, CFO, Email: cgregory@nuihc.com, 402-346-0902 x 204. Carlett Gregory Carlett Gregory CFO

Criteria: According to 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16, an entity should have written standards of conduct to cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. According to 2 CFR section 200.214, an entity is subject to the non-procurement debarment and suspension regulations. Condition: During our testing of federal award expenditures, it was noted that there were no formal written policies in place for standards of conducts covering conflict of interests for employees engaged in the selection, award, and administration of contracts nor to determine if a vendor is suspended or disbarred. Recommendation: The City should create policies and procedures for applicable requirements in order to comply with Federal regulations including procedures that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts and for procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions and maintain documentation supporting this verification View of Responsible Officials and Planned Corrective Action: 1. Develop Comprehensive Policies and Procedures:  Policy Development: Create policies that align with federal, state, and municipal regulations governing conflicts of interest and employee conduct in contract selection, award, and administration.  Conflicts of Interest Policy: Define clear guidelines and procedures for identifying, disclosing, managing, and mitigating conflicts of interest among employees involved in contracting activities.  Contract Administration Procedures: Establish detailed procedures that encompass the entire contract lifecycle, ensuring compliance with federal, state, and municipal requirements at every stage.  Training and Awareness: Conduct training sessions for employees involved in contracting to ensure understanding and adherence to the newly developed policies, procedures and current bid law regulations set forth by the State of Alabama. 2. Implement Procedures for Vendor Evaluation and Debarment Checks:  Vendor Evaluation Process: Develop standardized procedures for evaluating vendors before entering into contracts, including criteria for assessing qualifications, capabilities, and compliance with regulatory requirements.  Debarment Check Procedure: Establish a systematic procedure to verify whether potential vendors have been suspended or debarred by federal, state, or municipal authorities prior to initiating contract negotiations.  Documentation Requirements: Specify the documentation that must be collected and maintained to demonstrate compliance with vendor evaluation and debarment check procedures. 3. Maintain Comprehensive Documentation:  Document Retention Policy: Create a policy outlining requirements for retaining all documentation related to contracts, including vendor evaluations, debarment checks, contract awards, modifications, and performance records.  Centralized Documentation Management: Implement a centralized system or repository for storing and managing contract-related documentation, ensuring accessibility, security, and compliance with retention policies.  Audit Trail: Maintain a clear audit trail for all contract-related activities, documenting decisionmaking processes and actions taken to ensure accountability and compliance. 4. Monitoring and Compliance Oversight:  Monitoring Mechanisms: Establish mechanisms for ongoing monitoring of compliance with federal, state, and municipal regulations, as well as internal policies related to conflicts of interest, contract administration, and vendor debarment checks.  Regular Audits: Conduct regular audits of contract management practices and documentation to identify any deviations from established procedures and regulatory requirements.  Reporting and Accountability: Implement a reporting structure that provides regular updates to management and stakeholders on compliance status, audit findings, and corrective actions taken to address deficiencies. 5. Continuous Improvement and Adaptation:  Feedback and Review: Encourage feedback from employees involved in contract management to identify opportunities for improving policies, procedures, and compliance practices.  Benchmarking: Benchmark contract management practices against industry standards, best practices, and regulatory changes to continuously enhance processes and ensure alignment with evolving requirements.  Adaptation to Changes: Stay informed about updates and changes in federal, state, and municipal regulations impacting conflicts of interest, contract administration, and vendor management, and update policies and procedures accordingly.

2CFR 320, Methods of Procurement Standards are to be followed by each department requesting federal award. The County Auditor has instructed our employees and admin people of the changes made to our system to be followed for methods of procurements. County Auditors have provided an easy sheet to be followed and dated to be turned into the auditor's office to be approved prior to purchases as to see all steps have been completed of the procurement policy prior of purchasing items on any federal award. All items by County Auditor will be processed and looked at again prior to a check written.

Action Plan: Upon learning of this finding during the FY2022 audit, we worked with our external consultant, our Council auditors and our external auditor to reperform and review the base year and subsequent year calculations of revenue, using financial information in our final audit reports. These corrected calculations of lost revenue have been clearly documented and will be reported going forward. We will continue to work to ensure that all controls for grants be documented with written procedures. The procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, reperformable manner including the name of each responsible individual, the specific control they performed over compliance for the grant and the date(s) the controls were performed. Contact Names responsible for the plan – Marcia Saulo Anticipated completion date of the plan – September 30, 2024

Finding 2023-001 – I. Procurement, Suspension and Debarment Information on the federal program: Grantor: Department of Treasury Program Name: COVID-19 – Coronavirus State and Local Recovery Funds Assistance Listing No.: 21.027 Views of responsible officials and planned corrective actions: Management concurs with this finding and is currently drafting a procurement policy to incorporate the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. Name of responsible official: Devin Murphy AVP, Accounting & Strategic Projects Email: Devin.Murphy@nuvancehealth.org Projected completion date: March 31, 2025

Corrective Action Plan: Management has implemented controls to support the requirement to receive multiple number of price quotes for any purchases over the required threshold. Anticipated Corrective Action Plan Completion Date: Ongoing. Contact Information: For additional information regarding this finding please contact Jodi Bauer, Chief Financial Officer, at 414-316-5028.

National Health Foundation and Subsidiary Corrective Action Plan For the Fiscal Year Ended December 31, 2023 U.S. Department of Housing and Urban Development Federal Awards Finding Item 2023-001 – Procurement and Suspension and Debarment – Significant Deficiency over Internal Controls over Compliance Conditions – The auditors selected two out of a universe of three vendors that had covered transactions over the covered transactions threshold. National Health Foundation and Subsidiary was unable to provide supporting evidence documenting that it had verified either entity was not excluded or disqualified before National Health Foundation and Subsidiary went under contract with those vendors. However, a subsequent review did show both vendors were not on the excluded or disqualified listing. The written policies at National Health Foundation and Subsidiary include the requirement to attach evidence of the debarment verification when submitting an invoice for payment. The procurement policy effective during the audit period did not include the required written ethics and conflicts of interest standard to avoid actual or apparent conflict of interest involving expenditures of federal grant awards. National Health Foundation and Subsidiary has a conflict-of-interest policy for employees to adhere to however, the specific consideration for anyone who participates in the selection, awarding, or administration of a contract with federal funding was not included. Corrective Action Plan: National Health Foundation will update the existing procurement policy and conflict-of-interest policy to strengthen compliance with federal funding guidelines. A checklist will be created and kept on file for vendors over $25,000. Checklist to include the following: 1) list of vendors and their proposal/quotes, 2) list of employees involved in the decision process and verified that no conflict of interest between employees and vendors under consideration, 3) document vendor selected, and 4) check federal site that the selected vendor is not suspended or debarred from federal contract. Name of Contact Person: Dr. Felita Jones, CEO/President (FJones@nhfca.org) Kristina Tran, CFO/Sr. Vice President Finance (ktran@hasc.org) Projected Completion Date: June 30, 2024

FINDING NO 2023-001 Significant deficiency in Internal Control Over Compliance – Improve Control and Documentation over Procurement Detail of Finding and Planned Corrective Action Plan During the single audit it was discovered that a summary of bid quotes for one of the items selected for procurement testing was not available. The project selected had initially begun in FY2017 before the Town implemented its procurement tracking system. The individual in charge of the project had resigned and although the Technology Department tried to do a search of the employee’s email, the documentation was not found. The Town maintains an online procurement folder (by fiscal year) available to all departments to store all procurement information by project. The Town views this particular finding as an unfortunate exception to the procedures and policies that it has put into place to procure everything properly during FY2020. The Town will continue to follow all procurement guidelines and store all procurement documentation in a centralized location so that this finding does not happen again. Contact Dan O’Donnell – Finance Director Jesse Beyer – Town Accountant Completion Date (expected) These procedures and policies mentioned above related to procurement are expected to be implemented before the completion of June 30, 2024.

Failure to Follow Procurement Policy Finding 2023-003 Auditor Description of Condition and Effect: The Authority did not comply with the current procurement policy as procedures were not fully followed and required forms were not completed. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, Responsibility Determination (sam.gov debarred verification), and Cost/Price Analysis. Also, as stated in the prior finding, the procurement policy needs to be updated. As a result, the Authority is noncompliant with 2 CFR 200 and its own procurement policy. Auditor Recommendation: We direct the Authority to implement procedures to ensure that the fiscal year 2022 is certified within the required nine-month deadline. Corrective Action Plan: The Authority will review and update its procurement policy to comply with federal requirements. The Authority’s management, consultant, and finance director will review the procedures in the policy to ensure they are being acted upon accordingly going forward. Responsible Official: Contact person is Rufus Adams, Executive Director,275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. Due Date: September 30, 2024

Federal Aid Policies Finding 2023-002 Auditor Description of Condition and Effect: The Authority’s management has completely turned over and been restructured. However, the Authority’s policies for federal aid approved in 2021 have not been revised to update for the current management structure. The policies have also not been updated for changes in the 2 CFR 200 that have occurred. As a result, the Authority is noncompliant with 2 CFR 200. Auditor Recommendation: We direct the Authority review and update all federal aid policies and implement procedures to ensure that they are being reviewed at least once a year for changes in the Authority’s management structure or changes that occur in the 2 CFR 200. Corrective Action Plan: The Authority will update their federal policies to comply with 2 CFR 200 and will review all policies on an annual basis going forward. Responsible Official: Contact person is Rufus Adams, Executive Director,275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. Due Date: September 30, 2024

American Diabetes Association (ADA) is committed to ensuring the appropriate documentation is in place to adhere to federal regulations regarding procurement, suspension, and debarment. In response to the audit finding, ADA is taking the following corrective actions to address the audit recommendations: 1) Financial Services will communicate annual reminders of the existing policy relating to procurement policies including the requirement to evaluate a firms status relating to federal suspension and debarment. 2) Federal grant program management will develop and utilize a checklist to ensure that all procurement steps are completed prior to forming a relationship with a potential vendor.

Views of Responsible Officials: NFHA will review and update its current Procurement Policies to ensure that they meet all current Federal and Uniform Guidance requirements. This will include documentation of contractor selection and single source vendor criteria. NFHA will provide additional training to all staff on the revised policies and procedures.

2023-006 - Internal Control Over Compliance and Compliance – Procurement, Suspension and Debarment Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: July 2024 Management’s Corrective Action Plan NGA has always mandated that all vendors paid using federal funds be checked on SAM.gov for debarment or other issues. NGA believes this finding reflects a single isolated incident in which this check was completed, but records were not saved as a PDF within our vendor records. NGA has reiterated and retrained staff on the importance of documentation retention and ensuring that accounting staff consistently retrain these records. NGA expects this issue to have been fully addressed as of July 2024.

Introduction United Health Centers of the San Joaquin Valley (the "Organization") vigorously protests this finding. The Organization rigorously complies with not only federal and state procurement regulations, but also WIC regulations and the requirements found in the contract between the Organization and WIC. Additionally, numerous audits have been conducted by various entities (including audits by both WIC and the Health Resources and Services Administration (HRSA)) without any findings related to the Organization’s procurement. Finally, the Organization trains all individuals participating in the procurement process and provides guidance on procurement rules. Compliance with Regulations and WIC Program Contract The Organization’s compliance efforts are top tier. It uses many checks and balances to ensure compliance across the board with not only federal and state procurement regulations, but also WIC regulations and the requirements found in the contract between the Organization and WIC. It maintains written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts, intentionally avoids acquisition of unnecessary or duplicative items and uses surplus items instead of purchasing items when feasible. It uses full and open competition and obtains prior written authorization from the appropriate CDPH Program Contract Manager as required. The Organization maintains a narrative description of the procurement system, guidelines, rules, or regulations that is used to make purchases, which is audited by WIC for compliance. The Organization’s contract with WIC even goes above and beyond the requirements of 2 CFR § 180.220 and §§ 200.318 through 200.327. For example, the contract requires the reporting, tagging and annual inventorying of all equipment and/or property that is furnished by CDPH or purchased/reimbursed with funds provided through the contract. Upon receipt of equipment and/or property, the Organization reports the receipt to the CDPH Program Contract Manager and receives property tags for the items, then tags and logs them. For all purchases, the Organization maintains copies of all paid vendor invoices, documents, bids and other information used in vendor selection, for inspection or audit. Justifications supporting the absence of bidding (i.e., sole source purchases) are also maintained on file by the Organization for inspection or audit. Finally, although training is not required under 2 CFR § 180.220 or §§ 200.318 through 200.327, the Organization trains all pertinent staff related to procurement, the Organization’s procurement policies and procedures, the WIC contract requirements, WIC’s regulations and Uniform Guidance. This is done to ensure compliance with the principles and requirements of each of these requirements. No Prior Audit Findings Most recently, in January 2024 the Organization’s procurement policies and procedures were comprehensively audited by the federal HRSA through an Operational Site Visit to verify the status of UHC’s compliance with the relevant statutory and regulatory requirements. The HRSA audit specifically reviewed the Organization’s procurement policies and procedures, as well as reviewed documentation related to procurements during the prior three years by evaluating ten elements. This assessment evaluated written procurement procedures to ensure compliance with federal procurement standards, including a process for ensuring that all procurement costs are allowable, consistent with federal cost principles found in 45 CFR 75 Subpart E: Cost Principles. Additionally, the audit reviewed records for procurement actions paid for in whole or in part under the federal award that include the rationale for method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. This review involved documentation related to noncompetitive procurements. The audit also included evaluating the Organization’s retention of final contracts and related procurement records, consistent with federal document maintenance requirements, for procurement actions paid for in whole or in part under the federal award. Another element of the audit was to ensure that all activities and reporting requirements are being carried out in accordance with the provisions and timelines of the related contract and UHC’s own policies and procedures. Following completion of the expansive audit, HRSA’s evaluation resulted in no findings related to procurement. UHC successfully met all six elements of the Operational Site Visit audit conducted by HRSA. Conclusion In conclusion, the Organization vehemently disputes the findings presented, underscoring its unwavering commitment to stringent compliance with federal and state procurement regulations, as well as the stipulations outlined in its contract with WIC. The Organization's robust compliance mechanisms, encompassing meticulous checks and balances, written standards of conduct, and adherence to full and open competition, exemplify its dedication to procurement integrity. Furthermore, the Organization's proactive measures, such as reporting, tagging, and inventorying equipment, surpass the mandated requirements, ensuring transparency and accountability. Notably, recent audits by both WIC and the Health Resources and Services Administration (HRSA) have yielded no findings pertaining to procurement, validating the efficacy of the Organization's practices. The Organization's unwavering commitment to compliance, coupled with its comprehensive procurement protocols and ongoing training efforts, unequivocally refute any assertions of impropriety. UHC will reevaluate the audit findings and may or may not adopt a Corrective Action Plan.

Going forward, the board will vet any grant offers that require a specific vendor with our legal counsel before accepting funds.

Finding 2023-002 Issue: For the procurement samples tested, Management did not provide adequate supporting documentation for the procurement including ensuring proper suspension and debarment checks were performed. Recommendation: We recommend that the Organization establish written procurement policies and procedures to ensure that Organization is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Action Taken: Current MGHPCC policy states that criteria for approval of Purchase Orders above $25,000 include a check to ensure that the vendors are not suspended disbarred, or otherwise excluded from participating in a covered transaction as defined in 2CFR 180.220 and 2CFR 180.300. Policy has been updated to require that the check be documented by capturing a copy of the entity information database entry at www.sam.gov as part of the Purchase Order approval process for vendors who exceed the threshold defined in 2CFR 180.220 and 2CFR 180.300. The entity information database report includes a time stamp, which serves as an indication of when the database entry was checked. Completion date: The MGHPCC Controls for Federal program document was updated on March 15, 2024, and documentation has been retained for all relevant Purchase Orders subsequent to that date. If the National Science Foundation has questions regarding this plan, please contact John Goodhue by telephone at 413-552-4900 or by email at jtgoodhue@mghpcc.org.

The Organization plans to use their procurement policy to ensure they are in compliance with the procurement standards.

U.S. Department of Health and Human Services National Indigenous Women's Resource Center respectfully submits the following corrective action plan for the year ended September 30, 2023: Audit Period: October 1, 2022 to September 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 PROGRAMS SIGNIFICANT DEFICIENCY 2023-001 Suspension & Debarment Recommendation: We recommend the Organization increase training for those individuals involved in procurement and contract approval to ensure suspension and debarment checks are performed on all covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We have informed all individuals involved in procurement and contract approval of the requirement to perform suspension and debarment checks on hotel venues. Additionally, we will provide additional training to provide a better understanding of the procurement and contracting requirements. Name of the contact person responsible for corrective action: Lora Helman Planned completion date for corrective action plan: September 30, 2024 If the U.S. Department of Health and Human Services has questions regarding this plan, please contact Lora Helman at lhelman@niwrc.org.

Finding # 2023-002 Assistance Listing: 10.937 Partnerships for Climate-Smart Commodities Immaterial noncompliance over procurement The Organization’s fiscal policies and procedures does not meet the required federal standards for procurement. Corrective Action: The Organization agrees with and independently identified this issue and proactively procured services of a national non-profit focused CPA firm and has begun methodically rewriting all financial policies to ensure compliance with the Uniform Guidance. The procurement policy was updated and compliant with all Uniform Guidance requirements as of January 2024, all other policies will be updated by the end of 2024. Anticipated Completion Date: January 2024

The Organization is in the process of developing a procurement policy and suspension and debarment policies that aligns with Uniform Guidance.

Finding 2023-007: Procurement Finding: The District did not maintain adequate records for procurement transactions in the IDEA and Child Nutrition Clusters. Corrective Actions Planned: The District will train its employees on the documentation trail needed for procurement actions and review its policies and procedures for any needed updates. Expected Implementation Date: June 30, 2024 Contact Person: Dr. Frank Williams

Views of Responsible Officials: The Organization will complete and implement a formal, written procurement policy.

FA 2023-002 Improve Controls over Procurement Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.027 - Special Education Grants to States COVID-19-84.027 - Special Education Grants to States 84.173 - Special Education Preschool Grants COVID-19-84.173 - Special Education Preschool Grants Federal Award Number: H027A210073 (Year: 2022), H027A220073 (Year: 2023), H027X220073 (Year: 2023), H173A210081 (Year: 2022), H173A220081 (Year: 2022), H173X220081 (Year: 2023) Questioned Costs: $88,074 Prior Year Finding: FA 2022-001 Description: A review of expenditures charged to the Special Education Cluster (Assistance Listing Numbers 84.027 and 84.173) revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement procedures were followed. Corrective Action Plans: We concur with this finding and as noted it is a repeat finding from the previous year (2022). We have updated our federal purchasing policy with the following verbiage to address micro purchases. "For purchases less that $10,000, no competitive quotations will be required (micro purchase procedures). As defined by FAR 2.101, as in acquisition of supplies or services, the aggregate amount of which does not exceed the micro-purchase threshold ($10,000). For purchases between $10,000 and $250,000, price quotes from at least three qualified." Internal Controls procedures have been reviewed and will be followed to ensure that required procurement methods are being applied to each transaction and that proper documentation is maintained in the expenditure field. Transactions will be reviewed by the Program Directors to ensure that the internal control procedures are operating appropriately and in accordance with Federal Programs Uniform Guidance. Estimated Completion Date: Fiscal Year 2024 Contact Person: Trey Wood, Finance Director Telephone: 706-795-2191 ext. 1023 Email: trey.wood@madison.k12.ga.us