Corrective Action Plans

Management will create a reviewed and current procurement policy that covers all major areas of the Uniform Guidance requirements for procurement, suspension & debarment and ensures procedures are clear, accessible, and easily understandable by all sta􀆯 involved in procurement activities.

Condition/Context: For this program for our sample of one (representing the entire population), there was no documentation of policies and procedures for procurement of equipment, real property and other services funded by federal funds. We determined for this program that rate quotations and rationale for limited competition was not retained for the vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for the vendor. Corrective Action Planned: • Management will update existing procurement policies in accordance with the Uniform Guidance and implement a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. Anticipated Completion Date: April 15, 2024 Name of Contact Person Responsible for the Plan: Elizabeth Sergel

2023-002 U.S. Department of Transportation, National Infrastructure Investments: Better Utilizing Investments to Leverage Development (BUILD) Grant Assistance Listing Number 20.933; Procurement Material Weakness in Internal Control over Compliance Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award the provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. The Port Authority’s formally documented policy pre-dates Uniform Guidance and does not include many of the necessary procurement provisions. Corrective Action Plan: An updated Procurement Policy is being drafted to meet the standards set forth in 2 CFR 200.317 to 220.237, then reviewed and approved by our Board at the next appointed board Meeting. Expected Completion Date: March 2024 Responsible Individuals: Kimbra Scott

Corrective Action Planned: The Board will ensure compliance with the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.318 and CFR 200.320 and the Code of Alabama 1975, Title 39. Anticipated Completion Date: The completion date is March 15, 2024 Contact Person(s): Cindy W. Parker; Chief School Financial Officer; cparker@blountboe.net

Views of Responsible Officials: IW will initiate a thorough review and revision of our procurement policy to ensure full compliance with the Uniform Guidance. This revision process includes adding documentation of the procurement process. In addition, it will address how we incorporate specific procedures for conducting and documenting checks against the System for Award Management (SAM) to verify the status of vendors prior to engaging in covered transactions. We will implement a standardized documentation process to maintain evidence of SAM checks within our vendor files. This includes a detailed log of each check performed, the date, the name of the entity checked, and the outcome. These records will be retained as part of our procurement files for audit and review purposes.

Special Education Cluster – Assistance Listing No. 84.027 & 84.173 Recommendation: We recommend the District 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 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 of the contact person responsible for corrective action: Shari Thompson Planned completion date for corrective action plan: June 30, 2024.

Finding 2023-002: Significant Deficiency in Internal Control over Compliance and Noncompliance – Procurement, Suspension, and Debarment Standards. Name of Contact Person: Angela J. Vanderpool, Executive Director. Corrective Action: The finance department will create and implement a checklist that reflects the finance procurement policy to ensure the policy is followed before a procurement is awarded to a vendor. Proposed Completion Date: June 2024

NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30 2023 Name of contact person: Kristen Galbraith, GPC Corrective Action: The Grants Department will develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Proposed Completion Date: Immediately

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; GRANT No. Direct and AM-23-0287 Name of contact person: Kelly Strecker Corrective Action: The City commits to ensuring that a procurement policy be put in place that will allow it to comply with procurement standards outlined in the Uniform Guidance. Proposed Completion Date: December 1, 2024

Initial Fiscal Year Finding Occurred: 2023 Federal Agency Name: U.S. Dept of Housing and Urban Development Program Name: Continuum of Care CFDA #: 14.267 Finding Summary: Significant Deficiency over Internal Controls over Compliance. Procurement, Suspension, and Debarment During testing, it was identified that the Organization was not following its procurement policy. Responsible Individual: Theresa Perkins, Chief Financial Officer Corrective Action Plan: The NAC leadership team is responsible for the following and will report on the following for FYE 2024: Provide a final Procurement Plan that has been reviewed and updated and approved by the Board. Anticipated Completion Date: June 30, 2024

2023-004 - Procurement, Suspension, and Debarment – Internal Control over Procurement and Verification Against the System for Award Management (“SAM”) (Significant Deficiency) Condition: Community Development Block Grants-Entitlement Grants Cluster Based on the City’s formal purchasing policy, purchase orders are required to initiate purchases from procured vendors for transactions above $5,000. During our audit, we noted that seven (7) out of forty (40) samples did have purchase order approval made subsequent to invoice approval. The aforementioned circumstance suggests that the method of procurement was not in line with the City’s adopted policy established in line with the uniform guidance. Coronavirus State and Local Fiscal Recovery Funds We determined that seven (7) out of forty (40) samples did have purchase order approval made subsequent to invoice approval. The aforementioned circumstance suggests that the method of procurement was not in line with the City’s adopted policy established in line with the uniform guidance. During our audit, we also noted that there was no supporting document to indicate that the City verified the vendor against the SAM to ensure the vendor was not suspended or debarred from federally-funded programs before the contract was entered into. Management concurs. Corrective Actions: The City has an existing purchasing policy and procedures that require documentation for all purchases. Finance department has sent to all department heads reminder and the importance of compliance with the policy and procedures. The reminder also emphasizes the necessity of preparing a purchase order before procuring products or services from a vendor. There may be certain circumstances preventing the preparation of a purchase order prior to procurement, such as the nature of the services or the urgency of acquiring materials and supplies, departments may proceed with the procurement as long as the services or purchases are within adopted budget. City Council approved the Federal Award Management Policy & Procedures on agenda item #4 on December 6, 2023. Finance staff has also updated the requisition form to include a verification of SAM.gov clearance, requiring any backup indicating the vendors status if it is federally funded. City staff has been diligently verifying the suspension or debarment for all federally funded expenditures. Implemented Name of Responsible Person: Robert A. López, Chief of Police Manuel Carrillo Jr., Director of Recreation & Community Services Ron Garcia, Director of Community Development Sam Gutierrez, Director of Public Works Rose Tam, Director of Finance Albert Trinh, Accounting Manager Projected Implementation Date: All actions needed have been Immediately implemented.

2023-002 Child Nutrition Cluster – Assistance Listing No. 10.553 and 10.555 Recommendation: It is recommend the District should review and update as necessary the procurement policies to ensure they fully comply with Uniform Guidance and any other applicable requirements. The District should design and implement control process to ensure grant transactions comply with Uniform Guidance requirements and proper documentation is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will review procurement and purchasing policies and implement polices and controls to ensure that District policies and controls comply with Uniform Guidance requirements. Name(s) of the contact person(s) responsible for corrective action: Brenda Arnett Planned completion date for corrective action plan: June 30, 2024

Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-008 The College did not have a formal procurement policy in place documenting procedures that conform to the procurement standards in the Uniform Guidance. Corrective Action Plan: The College obtained multiple quotes for a Wi-Fi refresh project. The Chief Information Officer, under the guidance of the Vice President of Finance and Administration, analyzed these quotes and determined that one of them most closely met the needs of the College. This quote was submitted to Laurens County as part of the ARP Infrastructure Application, prepared by the College’s Corporate & Foundation Relations Officer. After Laurens County granted the funding for the Wi-Fi project to the College, the College moved forward with the vendor and scope of work laid out in the quote. However, the College does recognize that it did not adhere to all aspects of the Federal Procurement Policy. The Vice President of Finance and Administration, along with the Controller, will both implement a procurement policy for any purchases made with Federal funds that satisfies the requirements laid out in the Federal Procurement Policy and also educate any faculty/staff involved in purchasing products/services involving Federal funds.

Finding – Internal control deficiencies over procurement requirements Name of contact person: Lane Millar, Finance Director Corrective action: The City will ensure that employees receive comprehensive training on procurement requirements as a prerequisite before undertaking those responsibilities. Proposed completion date: March 1, 2024

The County is continuing to implement a county-wide contract clause that will be added to covered transaction contracts to comply with 2 CFR 180, to ensure covered transactions receive verification that the person or entity is not excluded or disqualified. Review and approval of this suspension and debarment verification will be performed during the contract approval process, which will include this standardized clause. The County’s purchasing policy and procedures manual will be updated to include this standard suspension and debarment verification process to ensure this procedure is communicated county-wide and followed. Additionally, the County will develop standard justification forms to document method of procurement to be maintained in the procurement file. The County will also update its contract templates to include applicable suspension and debarment attestation language which meets Federal requirements and update its purchasing policy and procedures manual to reflect these changes.

Title V Grant Procurement Planned Corrective Action: The University will update and implement internal policies such that they align with the federal procurement requirements. Person Responsible for Corrective Action Plan: Jim Gerrish, Director of Facilities Anticipated Date of Completion: April 30, 2024

MW Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 requirements for procurement. The Organization should also provide training to the various individuals involved in the procurement process to ensure they understand the applicable requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will update the procurement policy to add in the other methods of procurement to ensure compliance with the Uniform Guidance and follow proper document retention procedures. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2024

Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The District is actively working to develop written policies that will guide future procurement and selection of firms that participate in these federally-funded projects, including debarment and conflict of interest procedures. We plan to implement new policies by end of F& 23/24. Implementation Date: June 2024 Name of Responsible Person: Hugh Logan, General Manager

Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The District is actively working to develop written policies that will guide future procurement and selection of firms that participate in these federally-funded projects, including debarment and conflict of interest procedures. We plan to implement new policies by end of F& 23/24. Implementation Date: June 2024 Name of Responsible Person: Hugh Logan, General Manager

CONDITION: During my review of The School District of the City of Jeannette’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, or 2) the vendor met the requirements of a ‘sole source provider’ with documentation to support such designation, for the following vendors – Grade Point Resources ($74,503.17) and VLN Partners, LLP ($52,750.00). CRITERIA: In accordance with 24 PA Statute 8.807.1, the District must obtain/document at least three (3) written or well documented price or rate quotations from a reasonable number of qualified sources for purchases of goods between $10,000 and $$22,500 (threshold established annually). In addition, Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance requires price or rate quotations to be received from an adequate number of qualified sources for purchases above the micro purchase threshold of $10,000 and the simplified acquisition threshold of $250,000. 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 of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626.5), 2) the 24 PA Statute 8.807.1, 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, and as applicable, 4) Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement using federal funding.

CONDITION: The School District of the City of Jeannette contracted with a third-party vendor (Smart Solutions Technologies) for technology equipment for the District which exceeded the threshold for competitive procurement. The purchase was procured through a cooperative purchasing group. 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. This is a continuing finding from the 2021-2022 fiscal year. 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. MANAGEMENT’S PLANNED CORRECTIVE ACTION: 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 commence immediately and will continue on an ongoing basis as required by new policy directives from oversight agencies.

CONDITION: The School District of the City of Jeannette contracted with a third-party vendor (ABM Building Solutions LLC) for the performance of an energy savings construction project at the District. The contract with the third-party vendor, which was procured through a cooperative purchasing group, 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. This is a continuing finding from the 2021-2022 fiscal year. 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. The energy savings construction project exceeded the simplified acquisition threshold of $250,000. 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, including such instances whereby the District is using a contract vehicle from a cooperative purchase network so as to comply with all applicable sections of the Uniform Guidance, in specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. 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 commence immediately and will continue on an ongoing basis as required by new policy directives from oversight agencies.

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 and 2) obtaining quotations from three qualified providers where applicable and documenting those results. These two (2) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

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 and 2) obtaining quotations from three qualified providers where applicable and documenting those results. These two (2) 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 Finding Subject: Child Nutrition Cluster ‐ Procurement and Suspension and Debarment Summary of Finding: Procurement procedures not met – Suspension and Debarment not verified Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: 812-254-5536 calford@wcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Washington Community Schools was under the impression that since Sodexo was the vendor for the purchases, the contract between Washington Community Schools and Sodexo was sufficient. Going forward, WCS will obtain contracts directly from the retailer even when Sodexo is the vendor in WCS files. If Sodexo makes purchases on behalf of WCS, they will obtain quotes from three retailers. WCS will request and maintain the quotes obtained by Sodexo. WCS will also check for any suspension and debarment for any vendor that Sodexo uses to purchase items for WCS. Anticipated Completion Date: 02/01/2024