Corrective Action Plans

FINDING 2022-005Subject: Child Nutrition Cluster - Procurement and Suspension and DebarmentFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 ? School Breakfast Program, National SchoolLunch Program, COVID-19 ? National School Lunch Program, Summer Food Service Program, COVID-19 ?Summer Food Service ProgramALN Numbers: 10.553, 10.555, 10.559Federal Award Numbers and Years (or Other Identifying Numbers): FY21, FY22Pass-Through Entity: Indiana Department of EducationCompliance Requirements: Procurement and Suspension and DebarmentAudit Findings: Material Weakness, Other MattersContact Person Responsible for Corrective Action: Chad Yencer - SuperintendentContact Phone Number: 765-348-7550Views of Responsible Official: We concur with this findingDescription of Corrective Action Plan:BCS has established the following internal controls to ensure compliance:1. Internal Control: When a purchase is made at $10,000 or more using Federal Funds, thesuperintendent will require that any vendors selected are in compliance with theProcurement and Suspension and Debarment compliance requirement by completing one ofthe following quality checks with each vendor prior to purchase:a. Checking the federal System for Award Management (SAM) database athttps://sam.gov/content/exclusions and maintain a screenshot of the search results.b. Collect a certification from the vendor directlyc. Add a clause or condition to the covered transaction with the vendorAnticipated Completion Date:This corrective action will be implemented and completed immediately with any purchase made that meets theabove threshold.

Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of TreasuryFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersRecommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retainedfor audit purposes.Explanation of disagreement with audit finding: There is no disagreement with the auditfinding.Action taken in response to finding This finding was a result of only one vendor being availableat the time. The Office of Purchasing and Grants staff will comply with the requirement forobtaining quotes and document any exceptions if two quotes cannot obtained.Name(s) of the contact person(s) responsible for corrective action: BCPS Office ofPurchasing staff, grant accountants/fiscal staff.Planned completion date for corrective action plan: For immediate implementation andongoing.

Finding 2022-002 - Procurement, Suspension and DebarmentMaterial Weakness in Internal Control over ComplianceFinding Summary: As part of the audit, Eide Bailly LLP identified that the formally documented policy didnot include many of the necessary procurement provisions. Provisions include a consistent control in placeto check applicable vendors for potential suspension and/or debarment for covered transactions. Inaddition, current controls are to be documented to provide for a proper audit trail.Responsible lndividual(s): Chief Financial OfficerCorrective Action Plan: The policy has been updated to include all federal requirements regardingprocurement controls and suspension and debarment controls as proposed by the auditors. Managementwill retain documentation to support that the control process was followed.Anticipated Completion Date: Ongoing

Recommendation: We recommend that the College ensure its policies and procedures over procurement are being enforced to ensure reasonable prices and rates. Specifically, the College should consider training employees that regulations do apply when a single vendor is being used for a good or service, yet the charges are split amongst various funding sources.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action in Response to Finding: The College will implement training and procedural changes during the grant budgeting process and in the post-award process to ensure documentation of reasonable prices and rates to include training related to handling vendors who may be used across multiple funding sources.Name of the contact person responsible for corrective action: Tess Powers, Director of Faculty Research Support (719) 389-6318Planned completion date for corrective action plan: May 1, 2023

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, they 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 Action: Heritage University agrees to put procedures in place to make certain that every employee making federal purchases on the University's behalf is aware of the University's written procurement policy, which complies with 2 CFR Part 200. Additionally, the University is to formalize its code of conduct, which addresses conflicts of interest and establishes expectations for staff members involved in contract administration, selection, and award.Name of Responsible Party:1. Dr. Andrew Sund, President2. Thomas Richter, VP of Administration/CFO3. Melissa Hill, Interim Provost4. Corey Hodge, Interim VP of Academic AffairsAnticipated Completion Date: June 30, 2023

Federal Agency Name: Department of State ? Bureau of Population, Refugees, and MigrationProgram Name: Oversees Refugee Assistance Programs for AfricaCFDA #19.517Federal Agency Name: Agency for International DevelopmentDepartment of StateProgram Name: USAID Foreign Assistance for Programs OverseasCFDA #98.001Finding Summary: CVT has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, CVT was not testing vendors for suspension and debarment.Responsible Individuals: James Behnke, CFO and Mary Kinder, ControllerCorrective Action Plan: Management will maintain adequate supporting documentation and records to document history, methods of procurement, and documentation to support check for suspension and debarment. This will be maintained for all formal written vendor contracts.Anticipated Completion Date: July 2023

FINDING 2022-001Contact Person Responsible for Corrective Action: Mayor Terry AmickContact Phone Number: 812-752-3169Views of Responsible Official: I concur with the findings.Description of Corrective Action Plan: The City plans to review existing policies and procedures andmake any needed changes to endure that they are in compliance with the federal compliancerequirements for procurement as well as suspension and debarment. Furthermore, controls will beestablished to ensure that the City?s policies related to compliance with the federal compliancerequirements for procurement as well as suspension and debarment are followed.Anticipated Completion Date: December 31, 2023

Contact Person Responsible for Corrective Action: Brenda Grider, Clerk TreasurerContact Phone Number: 765-521-6803Views of Responsible Official: We Concur with this findingDescription of Corrective Action Plan:Internal controls have been put into place and the segregation of duties has been implemented.A policy has been approved on moving forward for the procurement, suspension and disbarment.Anticipated Completion Date: Immediately

Policies will be placed and adopted by the agency that meet the UG code. These policies will be placed in the fiscal manual. The fiscal manual will be created by using federal guidelines and by using the DDAP fiscal manual as guidance.

Finding Number: 2022-006 Finding Title: Procurement and Suspension and Debarment Programs: Highway Planning and Construction 20.205 COVID-19 — Coronavirus State and Local Fiscal Recovery Funds 21.027 Name of Contact Person Responsible for Corrective Action: Colleen Robeck, Finance Director Corrective Action Planned: McLeod County recognizes the importance of internal controls over Federal funding to be compliant with the Title 2 U.S. Code of Federal Regulations and is working on a procurement policy to address these issues. There are no misuse of funds, issues with allocation, nor concerns with any handling of funds; however, internal controls assist to assure compliance and will be implemented once complete. Anticipated Completion Date: McLeod County is finishing up the procurement policy and will have the State Auditor’s Office review it for compliance before it is taken to the County Board for approval in 2024.

The District concurs with the recommendation to adopt a written procurement policy and is in the process of writing the policy.

The District concurs with the recommendation to adopt a written conflict of interest policy and is in the process of adopting a policy.

Corrective Action Plan: We have taken proactive measures within the Purchasing Department to enhance training and awareness among our staff. Additionally, the Grant division has been reinforcing the importance of adhering to Federal grant guidelines regarding procurement. We will continue to monitor and improve our processes to ensure compliance with established guidelines. Anticipated Completion Date: December 2024

Plan of Action: Provide policy F2.0 Materials Management, F2.01 Vendor Selection & Discount, and F2.03 Inventory and Supplies, which were not provided to the auditor due to the organization’s operational error in financial policy classification. Additionally, the F2.02 Capital and Equipment policy was drafted in 2021 but needs to be signed by the organizational board on May 24, 2024. The organization acknowledges that the procurement policy was not followed for one vendor procurement in 2022 due to an administrative error. Going forward this policy will be strictly followed. Date of implementation: F2 policies was implemented on 6/1/21 and updated on 6/1/2024

Views of Responsible Officials and Planned Corrective Actions: Astraea created a best practice procurement policy in December 2021 that was implemented in February 2022 (i.e. Q3 of FY2022). Prior to December 2021, procurement practices were not standardized across the organization. Since implementation of the current procurement policy, all staff members have been trained on the procurement policy, and the Finance and Operation teams have developed internal processes to ensure that all procurement flows through the organization are documented and in compliance with 2 CFR 200. With the policy in place, we recognize that implementation across teams is critical and are actively training people managers to improve oversight and improve implementation. Anticipated Completion Date: January 31, 2024 Responsible Official: Associate Director, Grants Management and Compliance; Director of Program Operations

US Department of the Treasury - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. Action Taken: The City does follow Uniform Guidance procurement standards. In this instance, a vendor was selected under an emergency contract basis utilizing our waiver of bids policy. The entire country was awarded ARPA funds with water and sewer lining replacement being an allowable use of these funds. Due to the fact that there are a very limited number of vendors who provide this service, and the fact that there would be a significant number of municipalities seeking this service with the influx of ARPA dollars, as well as the fact that due to supply and demand, the cost for these services were escalating rapidly, the City wanted to be one of the first to engage with a contractor in order to secure a vendor in a timely manner before we would be unable to do so since the projects are long term projects and there was a time limit on when this money would need to be spent. Therefore, we knew it would not be possible to conduct our own bid. We choose a vendor off the COSTARS contract. I have attached a copy of the ordinance where we explained to Council our concern for our securing a vendor and our need to act quickly, which is why we originally initiated the purchase from City funds, before ARPA funds were distributed, and then replaced the City funds with ARPA funds once they were received.

Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation. Corrective Action Plan: The City will continue to address this finding through updating of policies and procedures for City-wide use. Update: in November 2023 the City updated the policies and procedures manual that was accepted by the DOJ in December 2023. Planned Implementation Date: June 30, 2024 Responsible Person: Finance Department

Action Taken: The Organization is generally identified and approached by Federal agencies, or prime contractors having or considering federal agencies, to utilize grant funding for NFFCMH contracts. The Organization works with trusted partners, each having a unique or specialized forte within the grant requirements, to assemble a joint team of providers. Many of these partners are, due to repeated utilization and unique recognition within their field, uniquely qualified, or the true only option, for their areas of expertise. The Organization has revised the procurement policy to comply with Uniform Guidance, as opposed to the Federal Acquisition Regulations.

a. Name of Contact Person Responsible for Corrective Action: Christy Harbin, City Clerk, and Ken Sunseri, Mayor. Phone Number: (205) 486-3121 b. Corrective Action Planned: The City of Haleyville will maintain a written policy for conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. c. Anticipated Completion Date: Immediately

Planned Corrective Action: Team Rubicon will institute policies and procedures to ensure compliance with applicable procurement guidelines when accepting federal awards. These will include prohibition against contracts which could be influenced by a perceived or actual conflict of interest, documentation of a search for suspended and debarred parties, and guidelines for approved methods of procurement (including specific situations where noncompetitive procurement may be appropriate, and documentation to be required if so).

2022-005 a. Name of Contact Person Responsible for Corrective Action: Jeff Burks, General Manager, and Cynthia Fowler, Office Manager & Comptroller Phone Number: (256) 356-8622 b. Corrective Action Planned: The Water Works and Gas Board of the City of Red Bay will maintain a written policy for conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. c. Anticipated Completion Date: Immediately

Correction Action Plan (Concerning Finding 2022-002) (Procurement, Suspension & Debarment): Contact Person Responsible for Corrective Action: Beverly White, Chairman of the Selectboard. Corrective Action: The Town of Brownington will take the following actions to address finding 2022-002. The Town of Brownington has added the changes that Kimberly Wall and Cathy Markavich suggested in their email dated March 26, 2024, to the Procurement Policy to have it meet FEMA guidelines. The Town of Brownington has drafted our policy to include the changes and this was adopted at the April 10, 2024 Selectboard Meeting. Anticipated Completion Date: April 30, 2024.

The County will develop written policies and procedures for procurement, including the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions. Management will evaluate the need to contract with local government consultants to perform control procedures where County personnel are not available or qualified to perform.

The County has identified federal grants subject to the Uniform Guidance and will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.

The County will develop written standards of conduct in that satisfy the requirements of 2 CFR § 200.318(c)(1).