Corrective Action Plans

Somerset County Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Audit Period: July 1, 2022 through June 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 AWARD PROGRAM AUDIT U.S Department of Agriculture 2023-001 Paper/Chemical Product Contract Recommendation: The Board should follow its established procedure and policy providing for competitive bids. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Board has entered into a competitively sourced contract with FPC Holding, Inc. as of December 2023 for the purchase of these products. Name of contact person responsible for corrective action: Linda R. Johnson, Director of Finance Planned completion date for corrective action plan: December 1, 2023

FINDING 2023-008 Finding Subject: Special Education Cluster - Procurement and Suspension and Debarment Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation had not designed or implemented a procurement policy for the purchases in the audit period. In addition, the school corporation did not award a contract for a purchase of $75,387. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. The School Corporation had not designed or implemented internal controls, policies, or procedures to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. One covered transaction that equaled or exceeded $25,000 was identified and selected for testing. Transactions to the vendor totaled $75,387; the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 50 Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: Create internal controls (using either SAMS website, certification from vendor, or clause/condition in contract) to ensure that vendors have been vetted and have not been suspended or debarred. Also develop processes to ensure that contracts for purchases over $50,000 are approved by the School Board. Anticipated Completion Date: To begin immediately, March 2024

FINDING 2023-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance for Procurement and Suspension and Debarment. For covered transactions, the School Corporation is required to verify that the person with whom they wish to do business with is not excluded or disqualified. In Fiscal Year 2022, there was one vendor where the School Corporation had one covered transaction in the amount of $55,285, and in Fiscal Year 2023, there were two vendors where the School Corporation had four covered transactions in the amount of $130,257. During testing and inquiry of the School Corporation, it was determined that for all three vendors who had a total of five covered transactions in the amount of $185,542 during the audit period, the School Corporation did not verify if they were excluded or disqualified prior to entering into a covered transaction. In Fiscal Year 2022, the School Corporation purchased a box truck in the amount of $55,285; however, the School Corporation did not award a contract to the vendor per Indiana Code and the School Corporation was unable to provide supporting documentation to support that three quotes were obtained prior to purchasing the box truck. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: Create internal controls (using either SAMS website, certification from vendor, or clause/condition in contract) to ensure that vendors have been vetted and have not been suspended or debarred. Also develop processes to ensure that contracts for purchases over $50,000 are approved by the School Board. Anticipated Completion Date: To begin immediately, March 2024

Finding 2023-002 Procurement Corrective Action: TPOCC has updated its Finance Manual, inclusive of a procurement policy in compliance with Uniform Guidance (2 CFR Part 200). We have also had all management staff who deal with programs funded by Federal Funds attend training on Uniform Guidance. We will continue to have staff attend these training courses to ensure that they are familiar with the requirements of Uniform Guidance. We have also begun implementing a procurement system (Pairsoft Paramount Workplace) and anticipate a go live of April 1st, 2024. This will help ensure our procurement policies are implemented and followed uniformly. Person Responsible: Finance Director, Lacy Meneses and CFO, Will Goodall Timing for Implementation: Currently in progress and procurement software will Go Live on April 1st, 2024. Document ID: b51a2bdf940fc8367245121fabb689a6083edd8e9deb8925c16c8fec9313f6b8 Page 1 Summary Schedule of Prior Year Findings and Questioned Costs Turning Point of Central California, Inc. did not retain procurement records to support its assertion that it is contracting with vendors that provide the best prices. Turning Point of Central California, Inc. has not updated its procurement policy to comply with the Uniform Guidance (2 CFR Part 200). This finding was first reported in the June 30, 2021 audit, issued in June 2022, and Turning Point of Central California, Inc. did not have adequate time to implement its corrective action plan during the year ended June 30, 2023. Questioned Costs: None

2023‐005 Material Weakness in Internal Control over Compliance and Material Noncompliance with Procurement Condi􀆟on: The Organization does not have a written procurement policy. Additionally, there was no documentation to support a price analysis over the transactions tested or documentation supporting that vendors were reviewed for suspension and debarment. There was also no documentation for review of the procurement transactions tested. Cause: The Organization had turnover and limited staffing available. Management’s Response and Corrective Action Plan: Changing the personnel involved has solved much of the problem, also the full awareness of what needs to be retained has also been explained to management. Management intends to add a Director level executive in the spring of 2024 to fully review and revise where necessary all standard operating procedures, including that of procurement. If/when funds from federal sources are used, those expenditures will be reviewed monthly. Specifically, this will mean: -Maintain EIDL‐sourced funds in a separate bank/account - Have single authorization for any movement/usage of funds in EIDL account - If/when funds from EIDL are used, have a written statement for purposes and documentation produced for use at the time of request Responsible Individuals: -Maintain separate account – Marcia Meyer, CEO, in conjunction with Board Finance Committee - Authorization for use of funds – Marcia Meyer - Maintenance of records for use – Jennie Myers - Confirmation with use of funds per allowable uses per national guidelines – Jennie Myers - Reporting on monthly finance report – Jennie Myers Anticipated Completion Date: This process is underway and will be visible at the fiscal year‐end audit in June 2024

Finding Number: 2023‐001, 2022‐001, 2021‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Faron Logan, Business Manager / Angelena Tabaha, Human Resources Manager Anticipated Completion Date: June 30, 2024 Planned Corrective Action: School did not have an HR Manager for school year 2022‐23 and the School recently hired an HR Manager. The Business Manager, with the help of the HR Manager, will ensure that School policies with sealed bids will be followed. The Business Manager will maintain all quotes  and  documentation  from  vendors.  The  School’s  current  policy  will  be  reviewed,  and  language will be added to address quotes and thresholds.

Assistance Listings number and program name: 10.691 Good Neighbor Authority Contact persons: Lucinda Andreani, Deputy County Manager and Flood Control District Administrator Anticipated completion date: June 30, 2025 Concur. The Coconino County Flood Control District (FCD) acknowledges price was not considered as a factor for contractor selection in the procurement of construction services for the Good Neighbor Authority program in accordance with 2 CFR 200 Subpart D Procurement Standards. A procurement was completed for construction-manager at-risk (CMAR) services, authorized by A.R.S. 28-7366, because the FCD believed at that time that the method would also satisfy the federal standards. The CMAR method bases selection on qualification and competence, does not allow for pricing to be requested or considered before making the selection, and transfers the risk of budget overages to the contractor by agreement to a Guaranteed Maximum Price (GMP). After selecting the contractor for Good Neighbor Authority construction projects, the FCD worked closely with the County’s contracted engineering firm to ensure that the GMP was reasonable and cost efficiencies were identified and implemented throughout all stages of the project. The County believes the prices paid as a result of the procurement are reasonable and no excess federal expenditures were made due to the non-federal procurement method that was used in error. FCD fiscal and management staff will receive formal training on 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, also known as the Uniform Guidance, to ensure its requirements are understood. Additionally, the FCD will implement written internal procurement procedures to be used for future procurements so that they are made in accordance with all applicable laws, regulations and policies. The County Finance Department has a designated grant accounting team specializing in compliance with Federal award requirements. The FCD will request technical assistance from this team prior to initiating any procurement with Federal funds to help make sure Federal regulations are considered and met. The Finance Department will provide training to all departments on Uniform Guidance requirements. Training will also be provided on the County’s procurement policies and procedures to help departments gain a complete understanding of the requirements for acquiring goods and services with federal funds. In line with the County’s decentralized finance model in which financial management staff are located within the departments, the responsibility to meet requirements specific to certain federal awards rests with the department that manages the award. The Finance Department will identify the source of funding for procurements requested by departments. Staff who are knowledgeable about Federal procurement requirements and the County’s procurement policies and procedures will review and approve the procurements involving federal awards.

OHA Procurement staff will verify all federal funded vendors are not suspended or debarred or otherwise excluded from participating in a transaction with OHA by checking the System for Award Management (SAM) Exclusions maintained by the General Servies Administration and available at SAM.gov. This procedure was implemented on a go forward basis on March 13, 2024.

Views of Responsible Officials and Planned Corrective Actions: The Organization will review procurement policies and procedures to address the recommendation noted. The Organization will also ensure that all documentation for procurement is saved in a central location digitally to ensure documentation is complete in the Organization’s records for all procurement decisions made.

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.

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 during the start of the 2023-2024 fiscal year and continuing forward. The District has contracted J. Martin & Associates, LLC (JMA) to provide business office accounting services. Representatives from JMA and the rest of the business office staff will monitor the implementation of noncompetitive procurement procedures to ensure that they are followed appropriately.

Finding Number: 2023‐002 Program Names/Assistance Listing Titles: Indian School Equalization, Indian Schools Student Transportation Assistance Listing Numbers: 15.042, 15.046 Contact Person: Aurelia Tapaha, Business Manager/Human Resource Manager; Stephanie Woody, Business Technician Anticipated Completion Date: July 2024 Planned Corrective Action: The School will revisit financial policies and procedures and strictly comply with procurement processes. There are specific requirements for different amounts of purchases. The School will review requisitions and ask for required documents before processing.

Recommendation: We recommend that the School review their Procurement policy and ensure that all missing federal requirements are included in their written policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Options Schools, Inc. will update the Procurement policy to include federal requirements. Name(s) of the contact person(s) responsible for corrective action: Jack Colwell Planned completion date for corrective action plan: July 1, 2023 If the U.S. Department of Education has questions regarding this plan, please call Jack Colwell, CFO at 463-238-1414. 18077 River Road, Suite 106 I Noblesville, IN 46062 I phone: 317.565.4350 www.optionsschools.

Finding 2023-001-Procurement, Suspension and Debarment Finding: The Foundation does not have a formal procurement policy under requirements of 2 CFR 200.317 through 200.327. The Foundation established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. We noted as part of our testing that there was no documentation that these policies and procedures were being followed. Corrective Actions Taken or Planned: The Foundation is in the process of developing a formal procurement policy to conform to 2 CFR 200.317 through 200.327. Further, the National Association of Social Workers, the supported affiliate of the Foundation has posted a position to hire a senior grants accountant who will be assisting in the development and implementation of policies and procedures around grants. The position will be reporting to the Accounting Manager and ultimately the Chief Financial Officer. Sekou Murphy, Chief Financial Officer, will be responsible for the corrective action plan that is anticipated to be completed by October 2024.

2023-002 Family Violence Prevention and Services/Discretionary – Assistance Listing No. 93.592 Recommendation: Update procurement policy to be compliant with Uniform Guidance.. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our audit identified a weakness in our policy surrounding procurement. CFR 200.318 states the non-Federal entity's documented procurement procedures must conform to the procurement standards identified in Uniform Guidance CFR sections 200.317 through 200.327. We will align our spending thresholds and policy language with that Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Richard Seymour, Finance Director Planned completion date for corrective action plan: By May 10, 2024

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION AND MINNESOTA DEPARTMENT OF HUMAN SERVICES, 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 and 2 CFR § 200.318-327 requires Northeast Metropolitan Intermediate School District No. 916 (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 coronavirus state and local fiscal recovery funds federal program. During our audit, we noted the District did not have sufficient controls in place resulting in material noncompliance within its coronavirus state and local fiscal recovery funds federal program to ensure compliance with federal procurement requirements related to methods of procurement and to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District is in the process of reviewing and updating its policies and procedures relating to procurement, 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 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 Finance and Operations, Mark Kumlien. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – The District’s Executive Director of Finance and Operations, Mark Kumlien, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with procurement, and suspension and debarment requirements.

FINDING 2023-005 Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (Or Other Identifying Number): 19611-067-PN01, 20611-070-PN01, 21611-070-PN01, 22611-02-CEIS, 22611-070-PN01, 22611-070-ARP, 23611-067-PN01, 21619-070-PN01, 22619-070-ARP, 22619-070-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreements and Procurement and Suspension and Debarment compliance requirements. Context: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $50,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2022, the School Corporation had one vendor, with disbursements totaling $199,713 for the fiscal year, which exceeds the simplified acquisition threshold of $150,000. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. For fiscal year 2022, three vendors, totaling $228,079, were identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $50,000 micro-purchase threshold. One of the three vendors was selected for testing. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. For fiscal year 2023, one vendor, totaling $65,861, was identified as being less than the simplified acquisition threshold of $150,000, but exceeding the $50,000 micro-purchase threshold and was selected for testing. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. During the audit period, there were six vendors identified which exceeded $25,000 in disbursements on an annual basis. Two vendors were selected for testing. In both instances, the School Corporation’s contract with the vendor did not include any suspension and debarment clause and the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The lack of internal controls and noncompliance was systemic issues throughout the audit period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Specifically, regarding Suspension and Debarment, for contracts over $25,000, MSD of Pike Township will obtain a Certification or include a Suspension and Debarment clause in the contract. Absent Certification, the Director of Grants will review for “Suspension and debarment” and maintain documentation. The Special Education Department will work with the Grant Manager and will review contracts over $50,000 to follow the appropriate procurement policy to obtain quotes. Where specialized services are being solicited, we will maintain a procurement file memo documenting the process and the reasons for vendor selection. Responsible Party and Timeline for Completion: Greg A. Foster, Chief Financial Officer, will oversee the corrective action plan. Plan will be implemented by June 30, 2024.

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

1. Person responsible: Director, Department of Public Health 2. Corrective action plan: DPH agrees with this finding and recommendation and will discuss, and document sensitive legal matters funded by federal funds with respective grantors to obtain guidance and direction on addressing audit requests. DPH will implement a protocol wherein the program executing any contract using federal funds will collect and maintain sufficient records which detail the history of the procurement. The program will also verify that compliance with procurement requirements is maintained for all federally funded contracts, including sufficient documentation to demonstrate compliance with suspension or debarment. To confirm this, the program will check the SAM exclusions prior to entering into a contract and will maintain documentation of that verification. These will ensure DPH’s ability to provide documentation when requested by auditors. 3. Anticipated implementation date: July 1, 2024

1. Person responsible: Director, Department of Public Health 2. Corrective action plan: DPH, Acute Communicable Disease Control (ACDC) agrees with the finding and recommendation. Before entering into contract, DPH will check for SAM exclusions with date indicating verification before contract execution and keep this documentation on file. DPH, Administrative Services Division (ASD) - Procurement agrees with the finding and recommendation. DPH’s Administrative Services Division Manager will email Procurement staff to remind staff/manager to ensure SAM.GOV verification documents are included in all federally funded purchases before finalizing/approving those transactions. 3. Anticipated implementation date: March 11, 2024 and April 30, 2024

Finding # 2023-001 Condition: Ampla Health did not have adequate procurement policies in place that meet the minimum federal requirements for procurement standards. We examined the procurement records for nine vendors where Ampla Health expended federal funds. For all four sole source procurement records reviewed, Ampla Health did not retain documentation of the sole source determination or have an approved sole source vendor list. For two of three vendors selected in the small acquisition threshold, Ampla Health could not provide competing quotes or sufficient evidence to demonstrate procurement was performed. For one of three vendors selected in the small acquisition threshold, Ampla Health was only able to provide procurement support for a portion of the funds expended. Response: Management will review the procurement policy and make all necessary changes to ensure we are in compliance with all federal requirements Responsible Party: Kathy Walker, CFO Estimated Completion Date: May 1, 2024

Description of Corrective Action Plan: Prior to the completion of this audit, EmployIndy already made a number of changes to its financial operations. It parted ways with its Chief Financial Officer and procured the services of an outside Certified Public Accounting firm to begin the process of reviewing and updating its financial operations. In addition, it hired an Executive Vice President of Finance and Operations to lead the final development and implementation of updated financial processes. The Executive Vice President of Finance and Operations has worked with EmployIndy’s Board of Directors and Finance Committee to document a plan for improving EmployIndy’s financial operations across the board by the 2nd quarter of Calendar Year 2024. To ensure compliance with competitive procurement documentation requirements, EmployIndy will review and update, as necessary, its procurement processes, reflecting that in cases where competitive procurement of a vendor is performed by a partner organization that EmployIndy receive and retain all necessary documentary support. In addition, Grants and Contracts staff will complete retraining on competitive procurement requirements. Responsible Party and Timeline for Completion: Corrective Activity Responsible Party Timeline for Completion Review and update competitive procurement procedures to ensure documentary requirements for competitive procurements performed by partners are well-defined. Associate Director of Grants & Contracts 2nd Quarter of Calendar Year 2024 Complete updated training on competitive procurement documentation requirements Associate Director of Grants & Contracts and Grants & Contracts Manager By 3rd Quarter of Calendar Year 2024 Hold Grants and Contracts staff are accountable for collecting and retaining required documents in scenarios where a partner completes competitive procurement of vendor(s) used by EmployIndy Executive Vice President of Finance and Operations Ongoing

Department: Administrative and Financial Services Title: Internal control over conflict of interest requirements needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will add updated verbiage to the service contract and IT service contract templates. The Department will notify agencies of the updated contract and transition timeline to accommodate contract negotiations in process. The Department will require the mandatory use of new contract templates. The Department will revise the NOI-PJF to include statutory reference and departmental attestation to conflict of interest. The Department will revise PJF guidance documents to include direction regarding conflict of interest acknowledgement/attestation. The Department will require the mandatory use of the revised NOI-PJF form. Completion Date: March 31, 2024 (first, second and fourth items), April 15, 2024 (fifth item) and July 31, 2024 (third and sixth items) Agency Contact: David Morris, Acting Chief Procurement Officer, DAFS, 207-624-7335

Finding Summary: There was no observable control documentation to directly indicate that a search for price comparisons or suspension and debarment was performed on vendors. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: Our Associate Director, Business Director and Operations Director will attend procurement, suspension, and debarment training to better learn the 2 CFR sections 200.318 through 200.326. Upon completion of training, the team will provide the Finance Committee of the Board of Directors with suggested updates to our current policy. Anticipated Completion Date: March 31, 2024

Reference Number: 2023-001 Prior year Finding: No Federal Agency: U.S. Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency in Internal control, Noncompliance Recommendation: The Town should review and enhance controls and procedures to ensure that it follows the applicable procurement policy and Federal suspension and debarment regulations for all goods and services charged to the program. Explanation: There is no disagreement with the audit finding. Action taken in response to finding: The Town of Camden, Delaware will review the State’s procurement process to satisfy the compliance requirements for the program. The Town of Camden, Delaware will also put procedures in place to check and review each bidder as part of the Federal suspension and debarment policies. Name(s) of the contact person(s) responsible for corrective action: Harold Scott Jr., Town Manager Malori Lewis, Account Specialist Planned completion date for corrective action plan: Procurement training and monitoring, ongoing Suspension and debarment training and monitoring, ongoing