Corrective Action Plans

Views of the Responsible Officials and Planned Corrective Actions: The Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money.

The District will monitor vendors to ensure they are able to accept federal monies. By Ashley Simmons, Accounts Payable clerk by 6/30/2024.

U.S. Department of Education Wisconsin Family Assistance Center For Education, Training And Support, Inc. (FACETS) respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 – June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDIT 2023-002 Parent Training and Information Technical Assistance Centers– Assistance Listings No. 84.328M and 84.328R Recommendation: It is recommended that FACETS supplement its procurement policy to address requirements specific to federal awards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will supplement our procurement policy to address requirements specific to federal awards. Name of the contact person responsible for corrective action: Courtney Salzer Planned completion date for corrective action plan: January 2024

Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. Name and Title of Responsible Official: Rouba Anka, Chief Financial Officer Planned Completion Date: Immediately

2023-003 Material weakness in internal control over compliance and compliance for procurement Recommendation: We recommend that the District review 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 District 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 its clear what considerations were made in the procurement decision. Name(s) of the contact person(s) responsible for corrective action: Paul Bourgeois, Executive Director of Finance and Operations. Planned completion date for corrective action plan: June 30, 2024.

Finding 2023-001 Information on the federal program: Federal Program Name: COVID-19 Higher Education Emergency Relief Fund (HEERF) – COVID-19 HEERF Minority Serving Institutions (MSIs) Federal Agency: U.S. Department of Education Federal Assistance Listing Number: 84.425L Award Year: July 6, 2020 – June 30, 2023 Criteria or Specific Requirement: Procurement, Suspension and Debarment Condition: The University’s procurement policy does not contain adequate documentation to demonstrate compliance with federal procurement regulations. (Deficiency) Corrective Action Planned: The University will review the federal procurement requirements and revise procurement policies to incorporate all required elements of the federal procurement regulations. Contact Person Responsible for Corrective Action: Sharon Maxwell, Senior Vice President for Business and Finance Anticipated Completion Date: October 31, 2023

Finding 2023-001: Procurement and Suspension and Debarment 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: The City concurs. Corrective Action: The City will enhance their existing policies for procurement to be in accordance with Uniform Guidance Procurement Standards and plans to be adopted by June 30, 2024. Name of Contact Person: Henry Dachowitz, Chief Financial Officer Projected Completion Date: June 30, 2024

2023-001 PROCUREMENT Recommendation: We recommend that the Authority implement controls to ensure that entities are not debarred, suspended, or otherwise excluded and that adequate supporting documentation is maintained. Action Taken: The Authority has implemented proper controls and procedures to ensure that entities that the Authority plans to enter a covered transaction with are not debarred, suspended, or other otherwise excluded. This includes performing the necessary due diligence to verify the particular vendor in question is not debarred, suspended, or other excluded. Additionally, the Authority plans to adopt additional policies and procedures to ensure that all procurement policies and procedures within the Authority's procurement manual are being followed, and that adequate documentation of these procedures is being maintained.

December 14, 2023 Donovan CPAs 9292 N. Meridian Street, Suite 150 Indianapolis, IN 46260 To Whom It May Concern, Liberty Grove Schools will take the following corrective action to address the FY2023 Single Audit Report finding: We will take corrective action to ensure our procurement policy is updated and in line with the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements forFederal Awards (“Uniform Guidance”), specifically 2023-001. In addition, Morrise Harbour, Founder & Executive Director of Liberty Grove Schools, will ensure this updated procurement policy is implemented and approved by our Board of Directors. Sincerely, Morrise Harbour Founder & Executive Director

Finding 2023-005 Department of Health and Human Services Federal Financial Assistance Listing #93.697 COVID-19 Testing and Mitigation for Rural Health Clinics Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: The Health System did not obtain quotes from multiple vendors as it relates to the procurement and purchasing of flooring which was over the micro-purchase threshold. In addition, the Health System did not have a written procurement policy or written standards of conduct policy related to procurement. Responsible Individuals: Diana Swindler, CFO Corrective Action Plan: Tri Valley Health System will implement a procurement policy and standards of conduct policy related to procurement, implement internal control processes to ensure compliance with their procurement policy, and retain documentation to support procurement, suspension and debarment procedures performed. Anticipated Completion Date: 01/31/2024

United States Department of the Education 2023-002 Special Education Cluster – AL No. 84.027/84.173 Recommendation: We recommend that the BOE review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with this finding. Management will update their purchasing policy to ensure compliance with Uniform Guidance. The of the contact person responsible for corrective action: Elio Longo

County Judge/Executive’s Response: Staff will use purchase orders for all funds including disbursements from the American Rescue Plan Fund. However, it should be noted that the information included on a purchase order including date, approval, general ledger account number, and amount were listed on each invoice included in this finding. The only item not included was the title “purchase order.” In addition, a separate ledger is maintained for this fund to monitor expenditures and appropriations. The current controls in place over federal funds provide the same assurance that expenditures will not exceed budget appropriations. This alternative procedure serves as an effective compensating control.

U.S Department of Education 2023-002 Special Education Cluster – Assistance Listing No. 84.027 and 84.173 Recommendation: CLA recommends the District puts in place the proper procedures for sufficiently documenting all procurements and methodology used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work to revise its procedures as necessary to ensure that all procurements which are charged to federal programs are fully documented, including support for noncompetitive proposals. Name(s) of the contact person(s) responsible for corrective action: Marie Schrul, Executive Director of Finance Planned completion date for corrective action plan: January 31, 2024

Program: Choice Neighborhoods Implementation Grants Federal Agency: Department of Housing and Urban Development AL #: 14.889 Federal Award Identification Number and Year: Various - See SEFA Pass-through Entity: N/A Type of Compliance Finding: I - Procurement, Suspension, & Debarment Internal Control Impact: Material Weakness Finding: The City did not provide evidence supporting the City's compliance with this requirement. Status: Resolved Corrective Action Plan: Since the CNI grant has ended, the corrective action plan will apply to future grants. When the City obtains future grants utilizing and/or funding projects in multiple City Departments, operating procedures will be in place to comply with 2 CFR sections 200.318 through 200.326 to ensure compliance and the required grant documentation will be centrally located and filed. Person(s) Responsible for Implementation: Jeffrey Williams, Director of City Planning, Telephone: (816) 513-8803; Email: Jeffrey.Williams@kcmo.org

Landesa will revise it’s Procurement Policy to meet the standards of the United States Federal Government and all components of 2 CFR Section 200.320. Landesa will revise the Procurement Policy to include clear thresholds for small purchases and simplified acquisitions and clearly address the topics of sealed bids, price analysis, and acquisition costs. Landesa will revise existing procurement forms, such as the third-party due diligence form, to ensure compliance with the revised policy. Landesa will provide training to all relevant staff on the revisions to the Procurement Policy by March 2024. The Director of Program Effectiveness will monitor staff implementation of the revised policy and procedures to ensure compliance with revised policy. Contact person: Director of Program Effectiveness and Anticipated completion date: March 2024

The district will create a checklist that will include a review of vendors on Sam.gov and print the findings so we may provide necessary documentation. We do have in policy that prospective bidders to contracts are to certify they are not suspended or debarred. Policy EFAB-E. We will review our current policies to ensure this requirement is met going forward.

Dover Area School District respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule of findings and questioned costs. Finding 2023-001 – Procurement Federal Agency: Department of Education Pass-through Agency: Pennsylvania Department of Education Assistance Listing Number: COVID-19 – Education Stabilization Fund – 84.425 Corrective Action Planned: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of this finding. Contact Person Responsible: Miranda Weaver, Chief Financial & Operations Officer

Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Substance Abuse and Mental Health Services Projects of Regional and National Significance – Assistance Listing No. 93.243 Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The conflict-of-interest policy has been added to the fiscal policies. Management is in the process of enhancing the federal procurement policy to include sections 200.318 – 200.326. Name of the contact person responsible for corrective action: Lisa Maraia, CFO Planned completion date for corrective action plan: December 1, 2023

Finding number: 2023-003; Finding: While testing the procurement requirement, we were able to test compensating controls, but noted that internal controls were not properly designed over the procurement requirement. Prior to receiving federal funding beginning in August 2022, the program conducted a request for proposal (RFP) process and began contracting with a vendor. When federal funding was obtained, the vendor was not reevaluated in accordance with the Uniform Guidance to ensure the procurement requirements were being met. In addition, we noted UW Health – Madison’s procurement policy documents do not include all of the information that is required by the Uniform Guidance. Correction actions taken or planned: UW Health will develop processes and procedures to ensure compliance with the Uniform Guidance. Vendors will be reevaluated for compliance with the Uniform Guidance prior to being charged to any grant. Anticipated completion Date: June 2024; UW Health employees responsible for Corrective Action Plan: James Hood, Director of Procurement Services, and Sara Schiek, Manager of Procurement Services

As a result of the deficiency noted, the Business Services and Procurement Departments have revoked all purchasing privileges from the Magnet Program Office for a period of 90 days. All purchases, including school level purchases, must be approved by Business Services or Procurement directly. During this time, the MSAP program office personnel will undergo specific training related to federal compliance including procurement, suspension and debarment. Following this 90-Day period, the District will implement additional monitoring procedures to ensure transactions that do not qualify as “small-purchases” be performed by the District Procurement Department.

Action taken: The district entered into a shared services agreement with Capital Region BOCES in March of 2022 for management of the School Nutrition program. It was assumed that this was a procedure they followed; however, documentation was not provided and the external auditors inciuded it as a finding. The School Nutrition Director resigned and was replaced by a new School Nutrition Director with BOCES (Greg Nalewjka) and he was unaware that this was necessary. He is working with his supervisors to provide documentation to the district that due diligence has been done to meet this requirement. Anticipated completion date: 11/10/2023

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 AND – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – FEDERAL ALN 21.027 2023-001 Internal Control Over Compliance and Material Noncompliance With Federal Procurement, Suspension, and Debarment Requirements Finding Summary 2 CFR § 180.425-430 and 2 CFR § 200.318-327 requires Independent School District No. 12 (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 special education cluster and coronavirus state and local fiscal recovery funds federal programs. During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its special education cluster and coronavirus state and local fiscal recovery funds 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 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 – The District’s Executive Director of Business Services, Patrick Chaffey. Planned Completion Date – December 31, 2023. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Business Services, Patrick Chaffey, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with procurement, suspension, and debarment requirements.

Name of Contact Person: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The District did identify in late spring/early summer that the existing relationship with US Foods had not been bid in the prior year. In order to address this issue, the District Administration identified, recommended and received Board of Education approval to access a US Foods State of Alaska Contract with the State of Alaska Department of Corrections. This action, coupled with the one-year extension of an existing agreement with Alaskan & Proud Markets for the purchase of milk, will bring the District into compliance with procurement procedures as outlined by the National School Lunch Program and DEED. Proposed Completion Date: December 2023.

Views of Responsible Officials and Planned Corrective Action: The University agrees with the finding, a revised policy has been drafted and was approved in September 2023.

CORRECTIVE ACTION PLAN October 2023 Section III: Federal Award Findings and Questioned Costs Findings and questioned costs related to Federal awards which are required to be reported in accordance with the Uniform Guidance 2 CFR 200.516(a): Significant Deficiency 2023-001 Child Nutrition Cluster - Procurement Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the “Excluded Entity” filter on the “Exclusions” search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1. Select “Search” from the header menu from any page on SAM.gov 2. In the filters, under “Select Domain”, select “Entity Information”, then select Exclusions 3. Use the filters or keyword box to enter the search criteria and view the results 4. Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Matt Leon, Assistant Superintendent for Business & Operations and Michael DeSantis, Purchasing Agent Deadline for Completion: On or before 12/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 10/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 11/1/23.