Corrective Action Plans

Easterseals Southeast Wisconsin has a policy which clearly outlines approval authorities. While we follow that policy properly, we understand that the policy lacks some elements required by the Uniform Guidance. None of our purchases made during the year under audit would have violated Uniform Guidance, but we are committed to compliance and therefore have already started to draft policies which will adhere to Uniform Guidance. We will finalize, communicate, and follow our updated Policies and Procedures to ensure that Uniform Guidance is followed and to resolve the finding from this audit.

Finding: 2022-003 Federal Agency Name: Department of Health and Human Services Program Name: National Bioterrorism Hospital Preparedness Program Federal Financial Assistance Listing #93.889 Compliance Requirement: Procurement, Suspension and Debarment Finding Summary: No independent secondary level of review or approval is performed relating to compliance. One employee is involved in preparing, reviewing and approving information. Additionally, 15 instances identified in our sample of expenditures in which the transaction exceeded the Coalition?s micro-purchase threshold, requiring a price analysis, however, the price analysis was not documented or completed. Further, the Coalition?s procurement policy does not include all the required elements as outlined in the Uniform Guidance. Lastly, five vendors were not verified against the central contractor registry prior to the expenses being incurred to ensure that the vendor was not suspended or debarred. Responsible Individuals: Greg Santa Maria, Executive Director Corrective Action Plan: The SDHCC Executive Director is currently revising the Coalition procurement policy to ensure that it appropriately reflects all elements required by the Uniform Guidance. The SDHCC Executive Director is updating the current review process to ensure that moving forward, all transactions that will exceed the Coalition?s micro purchase threshold include a documented price analysis. This will be reflected in the revised procurement policy. In an effort to ensure full compliance with vendor regulations. All outside vendors will be verified against the central contractor database before the SDHCC enters into any purchase agreements. This will be reflected in the revised SDHCC procurement policy. Anticipated Completion Date: Projected completion of procurement policy revision first draft to Board is Friday April 7, 2023

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? ALL FEDERAL PROGRAMS AWARDED UNDER THE UNIFORM GUIDANCE 2022-001 Internal Controls Over Compliance With Cash Management, Allowable Costs, Standards for Financial Management, and Procurement Finding Summary During our audit, we noted that Universal Academy?s (the Academy) written internal control policies over compliance with the U.S. Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) did not include adequate written controls over compliance with cash management, allowable costs, financial management standards, and procurement. Corrective Action Plan Actions Planned ? The Academy has implemented an updated version of its written policies and procedures relating to cash management, allowable costs, financial management standards, and procurement for its federal programs to ensure compliance with the Uniform Guidance effective for fiscal year 2023. Official Responsible ? The Academy?s Executive Director, Farhiya Einte. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The Academy agrees with this finding. Plan to Monitor ? The Academy?s Executive Director, Farhiya Einte, will ensure appropriate written internal controls and procedures are updated and in place for future federal grants.

Rural eConnectivity Pilot Program ? Assistance Listing No. 10.752 Recommendation: We recommend the Commission establish and document procurement policies and procedures in conformity with the Federal requirements ?? 200.317 through 200.327. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will adopt a written procurement policy in accordance with the federal requirements. Since the inception of the Rural eConnectivity program, the Commission has followed the Town of Easton Charter Article IV, Section 2(e) when contracting with third party vendors. The Commission now recognizes compliance with the Charter does not satisfy the necessity for a separate procurement policy to fulfill federal requirements. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: April 30, 2023

Finding 2022-01 Federal Program Title: Education Stabilization Fund ?Higher Education Emergency Relief Fund Compliance Requirement: Procurement, Suspension and Debarment Name of Contact Person: Lynn Feeken, Financial Controller Corrective Action: The College developed and implemented a procurement policy which addressed Uniform Guidance Procurement, Suspension and Debarment requirements. Date of Completion: January 5, 2023

2022-001 Higher Education Emergency Relief Funds (Procurement/Suspension and Debarment) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any 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: Crown College will review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. The Chief Operating Officer and the Controller will collaborate in this effort. Name(s) of the contact person(s) responsible for corrective action: Ron Straka Planned completion date for corrective action plan: May 31, 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Sue Hart Contact Phone Number: 812-752-8921 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Each vendor who has received payment from the school district from federal Child Nutrition funds, or is expected to in the future, shall be required to have at least one of the following filed with the school district each year: 1) SAM Exclusions without the vendor being listed as excluded or disqualified; or, 2) Certification of the vendor not being excluded or disqualified; or, 3) Including a clause or condition on any and all contracts or invoices confirming the vendor is not excluded or disqualified. The Director of Food Services shall maintain files with evidence of the above documentation and it shall be updated at least annually and no fewer than once per calendar year. In addition, the Director shall ensure price or rate quotes are acquired from all vendors the Director reasonably expects to pay more than the micro-purchase threshold and contracts shall be executed with vendors when purchases are between $50,000 and $150,000. Such contracts shall also be Board approved with copies uploaded to the Gateway system for ease of access by SBOA or the district in the future. Anticipated Completion Date: June 2023

REFERENCE # 2022-001 PROCUREMENT SUSPENSION AND DEBARMENT ? MATERIAL WEAKNESS- NON-COMPLIANCE Program Name/ALN Emergency Solutions Grant Program (ALN # 14.231) Criteria: As per ? 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. (d) The Non-Federal entity 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. Condition/Context: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR ? 200.318 General procurement standards. We selected two (2) vendors for procurement Suspension and Debarment compliance testing of total population of 2 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: ? To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. ? To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Questioned Costs: Cannot be determined Recommendation: We recommend that the Division must: (1) document procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. (2) The Division?s documented procurement procedures must conform to the procurement standards identified in ?? 200.318 through 200.327. . Corrective Action Plan: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. Step 1 Action Date: Ongoing Final Implementation Date: 9/30/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

FINDING 2022-002 Contact Person Responsible for Corrective Action: Greg Hopkins Contact Phone Number: 812-967-3926 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Small Purchases The Food Service Director of the local School Food Authority will work with the Food Service Management Company to ensure all items purchased are procured properly using the correct thresholds set by the state and federal government. Suspension and Debarment The Corporation is now contracted with a Food Service Management Company (Aramark). The Food Service Director reviews all agreements/contracts related to Food Service to ensure that they meet the requirements related to suspension and debarment. Once contracts/agreements are reviewed, the Food Service Director signs off. Anticipated Completion Date: Effective Immediately

FINDING 2022-001 Contact Person Responsible for Corrective Action: Stacie Light, Director of FNS Daniele Raber, Corporation Treasurer Contact Phone Number: 574-371-5098 ext. 2408 574-371-5098 ext. 2451 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: WCS was fully operating during a pandemic and had to do whatever it took to get products for our students and families. Although we feel we followed the proper procedures for these purchases, we will take your recommendations to make sure we're following protocol. During the pandemic, due to supply chain issues, we had to utilize vendors outside of the co-op in order to meet these needs which resulted in higher total expenditure costs for these vendors. Supply chain issues are not as prevalent as the pandemic has lessened. These purchases to outside co-op vendors are decreasing. We will do payment history checks on the vendors our Child and Nutrition program is utilizing throughout the year to ensure they are under the small purchase threshold and will receive contracts with vendors should they exceed this threshold. We will continue to follow our already established process of checking SAM.gov when new vendors are entered into our system for use. We will begin to do an annual check of vendors that our Child and Nutrition program utilizes to ensure that previously established vendors are not on the suspension or debarment listing. Anticipated Completion Date: We will begin these corrections immediately for the remainder of the school year and will more fully implement these corrections as of the beginning of the 2023-2024 school year.

Finding 2022-004 ? Special Education Cluster ? Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Michael Huber Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: When our current contract is nearing its end we will follow procurement bid procedures. Anticipated Completion Date: 2029

U.S Department of Housing and Urban Development Columbus House, Inc. and Subsidiaries (the Organization) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 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 AUDITS U.S DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-001 Emergency Solutions Grant Program ? Assistance Listing No. 14.231 Recommendation: We recommend that the Organization review its formal procurement policies and make necessary changes to comply with the terminology requirements 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 is in the process of updating its procurement policies to ensure that all necessary language is included so that it will comply with all of the requirements listed in sections 200.315 through 200.326 of the Uniform Guidance. Name of the contact person responsible for corrective action: Margaret Middleton, CEO Planned completion date for corrective action plan: February 2023 If the U.S Department of Housing and Urban Development has questions regarding this plan, please call Margaret Middleton at 203-401-4400.

Proposed Completion Date: June 30, 2023

2022-002: DOCUMENTATION OF PROCUREMENT, SUSPENSION, AND DEBARMENT PROCEDURES (CODE 50000) Name of contact person: Beth Anderson Corrective Action: The district has a procurement policy with sample forms. The district will use the forms to document review of multiple vendor quotes and to document verification that vendors have not been suspended or disbarred for all federal programs/funding. Proposed Completion Date: Ongoing

Corrective Action Plan - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S45U210012 (Year: 2021) Questioned Costs: $221,797 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Newton County Board of Education will amend contracts with appropriate vendors to ensure that the proper verbiage is contained for us of federal funds. The School District will monitor contracts to ensure that all expenditures meet compliance requirements for the ESSER federal program. Estimated Completion Date: June 30, 2023 Contact Person: Erica Robinson Telephone: 770-787-1330 Email: robinson.erica@newton.k12.ga.us

2022-005 Contact Person Neil Breidenbach Planned Corrective Action The District will create and approve a procurement policy that adheres to state and local regulations as well as 2 CFR Part 200.317 through 200.327. Planned Completion Date December 31, 2023

Finding 2022-004 Finding Summary: Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance During the course of the engagement, Eide Bailly identified that the District did not have a procurement policy in compliance with Uniform Guidance. Responsible Individuals: Rhandi Knutson, Director Corrective Action Plan: A procurement policy in compliance with Uniform Guidance will be approved and implemented. Anticipated Completion Date: June 30, 2023

2022-002 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: Mel Nettesheim Planned completion date for corrective action plan: June 30, 2023

FINDING 2022-002, 2021-001 ? Repeat finding: Corrective Action Plan: Based on the prior year recommendation to the FY21 finding, dated December 15, 2021, in April, 2022, CPS revised the policies in the Procurement Manual to reflect the current standard. The Oracle procurement module was tested and upgraded to implement further controls to require the collection of three quotes for any purchase using federal grant funds between $2,000.01 and $25,000 in value. In addition, communication and reenforcement of the procurement policies in the CPS Procurement Manual at the program and school level has been completed through the mandatory training and district wide announcement. On May 9, 2022, US department of Education issued the determination letter concluding this finding resolved and closed. Contact person: Patrick T. Alforque, Controller

Finding Number: 2022-011 Federal Program, Assistance Listing Number and Name: ALN 14.231, Department of Housing and Urban Development, Emergency Solutions Grant Program, including COVID-19 ALN 20.507 and 20.526, Department of Transportation, Federal Transit Cluster, including COVID-19 Condition: Original Finding Description: During procurement testing, we noted two contracts for which the City did not review sam.gov to ensure the entity was not suspended or debarred. Additionally, we noted one contract for which the City did not perform the required cost-price analysis. Contact Person Responsible for Corrective Action: Sandra Yu Stahl Anticipated completion date: June 2023 Planned Corrective Action: The city will review its current procurement policy and implement additional controls as needed to help ensure verification is performed as required and the required processes are followed.

Finding No.: 2022-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Guam Housing and Urban Development Authority AL Program: 14.231 Emergency Solutions Grants Program Area: Procurement and Suspension and Debarment Criteria: In accordance with applicable procurement and suspension and debarment requirements, the non-Federal entity must have and use documented procurement procedures, consistent with the Procurement Standards in 2 CFR ? 200.318-327, which require formal procurement methods when the procurement of goods or services exceeds the simplified acquisition threshold (i.e., $250,000). Condition: For one (or 20%) of five procurement transactions tested, aggregating $1,512K out of $1,519K in total non-payroll program expenditures, the small purchases method was used to procure rental of 40 rooms to be used as emergency shelters with an annual contract amount of $1,095K. Based on the contract amount, a formal procurement method should have been used in performing the procurement. Cause: Catholic Social Service (CSS) lacks controls over compliance with applicable procurement requirements. The procurement policy of CSS is not prepared in accordance with the Procurement Standards in 2 CFR 200.318-327, as it does not require formal procurement procedures for any transactions. Effect: CSS is in noncompliance with applicable procurement and suspension and debarment requirements. The total questioned cost is $1,095,000. Recommendation: CSS should establish and implement controls over compliance with applicable procurement and suspension and debarment requirements. CSS management should revisit its procurement policy for alignment with the Procurement Standards in 2 CFR 200.318-327. Views of Responsible Officials: CSS disagrees with the finding that CSS is in noncompliance with applicable procurement requirements cited in 2 CFR 200.318-327, resulting in a questioned cost of $1,095,000. The federal ESG-CV grant awarded to Guam Housing and Urban Renewal Authority (GHURA) to respond to the impact of COVID-19 pandemic provided waivers and alternative requirements, including greater flexibility, to establish expedited response actions to mitigate the spread of the coronavirus. Exhibit D of the sub-recipient agreement (SRA) provides for this reference of waivers and alternative requirements. Specifically, page 18 of Section III.F.8 of Exhibit D of the SRA states the following: ?8. Procurement. As provided by the CARES Act, the recipient may deviate from the applicable procurement standards (e.g., 24 CFR 576.407(c) and (f) and 2 CFR 200.317-200.326) when procuring goods and services to prevent, prepare for, and respond to coronavirus. If the recipient deviates from its procurement standards, then the recipient must establish alternative written procurement standards, and maintain documentation on the alternative procurement standards used to safeguard against fraud, waste, and abuse in the procurement of goods and services to prevent, prepare for, and respond to coronavirus. This alternative requirement is necessary to ensure the funds are used efficiently and effectively to prevent, prepare for, and respond to coronavirus. Notwithstanding this flexibility, the debarment and suspension regulations at 2 CFR part 180 and 2 CFR part 2424 apply as written.? The opening of a temporary emergency shelter for families and individuals who are homeless was deemed an emergency response to the coronavirus. CSS emphasizes that the focus of GHURA was to identify readily available units and obtain price quotations to stand up an emergency homeless shelter, and the ?small purchase method? would provide that information to expedite the procurement process. This process was communicated to GHURA, as well as outcome of surveys of available units, and recommendation for selection of site. CSS agrees on the recommendation to revisit CSS? procurement policy overall that would assure objectivity and cost efficiency in the purchase of goods and services, including aligning and/or adopting verbatim procurement requirements outlined in 2 CFR 200.318-327. Contact Person: Diana Calvo, Executive Director Expected Completion Date: September 30, 2023 for policy/procedure development.

Finding 2022-002 Federal Agency Name: Department of Treasury, State of South Dakota Governor?s Office of Economic Development Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing: 21.027 Finding Summary: The Company has not documented their internal controls for compliance with the procurement, suspension and debarment compliance requirement of Uniform Guidance as outlined above. The Company does not have a written policy related to procurement or written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurement, as well as, established procedures in place related to suspension and debarment. The Company did not follow the procurement method required based on the dollar amount and conditions specified in 2 CFR 200.320. For contracted vendors with expenditures in excess of $25,000, the Company did not verify vendors were not suspended or debarred prior to entering into transaction with the vendor. Responsible Individuals: James Groft, CEO Corrective Action Plan: The Company will draft and adopt policies that implement internal controls consistent with the compliance requirements for procurement, suspension and debarment. The Company will follow the new documented policies and retain documentation to support compliance with the requirements. Anticipated Completion Date: June 1st, 2023

"See Corrective Action Plan for chart/table"

Program: 66.958 Water Infrastructure Finance and Innovation Federal Agency: U.S. Environmental Protection Agency Award No: WIFIA-N18147WI Award Year: 2022 This finding is a repeat finding of 2021-001 Criteria: 2 CFR section 200.318 ? General Procurement Standards, requires non-Federal entity to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition: We reviewed the water utility's procurement policy and service contracts with costs reimbursed during 2022, noting they did not contain necessary federal language related to conflicts of interest and debarment and suspension. Cause: The water utility has not received federal funding in the past and did not update their procurement policy when they sought federal funding for the Great Lakes Water Supply project. Additionally, service contracts were entered into prior to receiving federal funds. Effect: Without adequate control of contract language the water utility could enter into contracts related to the Great Lakes Water Supply project that do not qualify for federal reimbursement. Questioned Costs: None noted. Recommendation: We recommend the water utility review its procurement policy and make necessary updates to be in compliance with federal standards. Additionally, we recommend the utility enter into contract addendums related to contracts previously executed without required federal language. Management Response: Waukesha Water utility management has worked closely with WIFIA to craft contracts that include all necessary language prior to releasing RFPs for construction contracts. WIFIA was presented all service contracts to review prior to reimbursements received in fiscal year 2022. The finance department is working to update the procurement policy to ensure necessary federal language is included. The finance department will also work with service contractors to execute contract addendums.

FINDINGS?FEDERAL AWARD PROGRAMS AUDITS Procurement 2022-001 All Federal Agencies and Programs Recommendation: The Town should 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: The Town had an unapproved policy that complies with the procurement criteria at the time of the audit. This policy will be approved by the First Selectwoman to comply with the requirements of Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Dawn Norton Planned completion date for corrective action plan: 3/31/23 If the Office of Policy and Management has questions regarding this plan, please call Dawn Norton 203-563-0128.