Corrective Action Plans

Condition: We noted during testing that the City had omitted a subrecipient from its search to ensure that the subrecipient was not suspended, debarred, or otherwise excluded pursuant to 2 CFR section 180.300. Planned Corrective Action: Procedures have already been put into place to ensure that each new contractor is not on the Federal list of suspended and/or debarred contractors. Furthermore, all vendors previously paid have been searched for in the Federal list and none were suspended and/or debarred. Contact person responsible for corrective action: Lee Ward, Director of Finance. Anticipated Completion Date: 12/15/2023

Sheila Nolan, Child Nutrition Supervisor, acknowledges the finding regarding the purchase of produce products for SY 2022-23. There is only one regional produce distributor that successfully delivers to the Franklin Parish area with accurate invoices and timely deliveries based on past history. Due to staff changes and re-assignment of essential job functions, the produce bid was overlooked for this this year only. Moving forward, the CNP Supervisor has established a procurement schedule for developing and revising necessary formal bids in compliance with Federal and State requirements and all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition Program experienced multiple shortages of canned and frozen vegetables and fruits. This made it essential to fill in with fresh produce to meet meal pattern requirements. This created a marked increase in the cost of the fresh produce available to us and increased our reliance on fresh produce.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, the auditors recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Planned corrective actions: The university puts measures in place to guarantee that every employee who makes federal purchases on the university's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts. Name of Responsible Party: 1. Aaron Krantz, IT Director 2. Jeffrey Beehler, Physical Plant Director 3. Yolanda Maltos, Grant Accountant 4. Melissa Hill, Provost 5. Alysia Stevens, Controller 6. VP of Administration/CFO 7. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

2023-001: Special Education Cluster – Procurement Context/Condition - Of the four procurement transactions subjected to testing, there were two professional service contracts that the District did not have documentation supporting the sole source procurement method. Corrective Action Plan – Laramie County School District No. 1 (LCSD1) appreciates the thorough review conducted by the auditing team, identifying the lack of documentation for two sole source contracts for special education trainers hired in response to the Wyoming Department of Education’s monitoring review. In response, LCSD1 has undertaken a comprehensive corrective action plan to rectify the identified issues and prevent future occurrences. Immediate steps include a detailed review of the existing contract, identification of missing documentation, engagement with legal counsel to ensure compliance, and the development of clear procedures for documenting sole source justifications. To address potential gaps in staff understanding, LCSD1 has implemented additional training programs and reviews by procurement staff. LCSD1 will also evaluate federal, state and district procurement policies and initiate additional internal monitoring requirements for special education contracts. LCSD1 does not dispute the finding and will continue to improve processes and procedures with a focus on periodic reviews to enhance procurement practices. Contact Person – Jed Cicarelli, Chief Financial Officer Anticipated Completion Date – Immediately

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Diana Fitzpatrick, Director of Finance Anticipated Completion Date: April 30, 2024 Planned Corrective Action: When notified by the audit firm of the error in procurement procedures, district employees were notified of the correct procedures. This information has been and will continue to be made known to district employees who are delegated authority to procure goods and services during monthly leadership meetings. During this spring’s annual budget workshop with district staff, a brief training session will be held on Federal, State, and Board procurement policies and procedures. Also, a record of vetting vendors has been implemented this current fiscal year via the Sam.gov website.

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.