Corrective Action Plans

Finding 2023-001 – Special Educa􀆟on Cluster – Procurement and Suspension and Debarment Subject: Special Education Cluster (IDEA) Audit Findings: Material Weakness, Other Matters Condition and Context: The School Corporation is a member of the Delaware-Blackford Special Education Cooperative (Cooperative). During fiscal year 2022-2023, the Cooperative operated the special education preschool program and spent the federal money on behalf of six of its seven members. As the grant agreements were between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. 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 micropurchase 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. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. Two vendors exceeded the small purchase threshold during the audit period. The Cooperative provided evidence of a quote being obtained for the first vendor, however, evidence of obtaining multiple quotes was not retained for audit. The chosen quote was attached to the accounts payable vouchers and provided for audit; however, the other quotes obtained for the purchase were not maintained. For the second vendor, the Cooperative determined psychological services were to be provided by a single source provider, however, they did not have a documented rationale or support for the decision. Documentation detailing the history of procurement, which must include the reason for the procurement method used, selection of the vendor, and the basis for the price, was not available for audit for either purchase. Suspension and Debarment The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As such, the Cooperative entered into a contract totaling $32,388, which exceeded $25,000, for psychological services. The Cooperative did not perform procedures to ensure that the vendor was not suspended or debarred from participation in federal programs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Official: We concur with the finding. Descrip􀆟on of Correc􀆟ve Ac􀆟on Plan: As a member of the Delaware-Blackford Special Educa􀆟on Coopera􀆟ve (DBSEC), Yorktown Community Schools will obtain in wri􀆟ng from Muncie Community Schools that their correc􀆟ve ac􀆟on plans for procurement and suspension and debarment have been implemented. Responsible Party and Timeline for Comple􀆟on: Greg Hinshaw, Superintendent of Yorktown Community Schools and DBSEC Board Member. Timeline for comple􀆟on March 31, 2024

Finding 2023-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2023-002. Washakie County is currently working on implementing a more thorough tracking procedure in order to document all of the significant processes for our federal awards. Also, in order to further track funds disbursed, a sams.gov account has been set up and is currently utilized in order to determine if an entity is eligible for disbursement of federal funds. An amendment to implement sams.gov utilization will be produced in order to add it to our current Procurement Policy.

FINDING 2023-004 Finding Subject: Child Nutrition Cluster – Procurement, Suspension, and Debarment Summary of Finding: Material Weakness, Other Matters The School Corporation had not properly designed or implemented an effective system of internal controls to prevent, or detect and correct, noncompliance. Procurement: A School Nutrition Cooperative (Co-ops, Education Service Center, Group Purchasing Organization, etc.) that would like to be classified as a School Food Authority (SFA) Cooperative must complete a questionnaire and submit it to the Indiana Department of Education (IDOE). Once a questionnaire is received IDOE will review the answers to determine a Cooperative’s classification. Only Cooperatives that submit the questionnaire and receive a SFA-only Cooperative classification from IDOE in writing will be considered a SFA only Cooperative for the purposes of the procurement process and procurement reviews. When the value of goods or services exceeds the simplified acquisition threshold, the proper purchasing method would be the bidding process, unless the purchase meets certain other qualifications. Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. 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. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The School Corporation purchased milk through Region 8 Education Service Center (Region 8). However, Region 8 had not received the SFAonly Cooperative classification from IDOE for fiscal years 2021–2022 and 2022-2023. As such, the School Corporation could not rely on the procurement done by Region 8. Region 8 could be considered one quote for procurement; however, the School Corporation did not obtain any other quotes related to the purchase of milk, therefore, an adequate number of quotes from qualified sources was not obtained. 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. INDIANA STATE BOARD OF ACCOUNTS 47 MADISON-GRANT UNITED SCHOOL CORPORATION Steve Vore., Superintendent Ben Mann, Chief Financial Officer Kristy Drewitz, Transportation Allison McGuire, Payroll/Benefits Anna Richards, Corp Secretary/Deputy Treasurer Inspire, Cultivate, and Promote excellence in every Argyll. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a vendor with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation noted that vendor’s were checked against Sam. Gove and verified to not be suspended or debarred. Four covered transactions that equaled or exceeded $25,000 were identified. All for transactions, totaling $213,795, were selected for testing. For three of the four vendors, the School Corporation did not verify the vendor’s suspension and debarment status prior to payment. The total amount spent with the three vendors was $162,733. Contact Person Responsible for Corrective Action: Kathy Bernaix Contact Phone Number and Email Address: 765-536-0008 kbernaix@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement: Three quotes will be requested for “small purchases” and the process will be reviewed to ensure it is performed. Suspension and Debarment: Before purchasing goods that total $25,000 or more from a vendor, the Food Service Director will look up the vendor on SAM.gov for debarment activity. Anticipated Completion Date: February 2024

Management’s Response and Planned Corrective Actions: 1. The corrective action planned: a. Internal control document and procedure that is consistent with the compliance requirement for: i. CFR §200.318, General procurement standards identify all requirements which the offerors must fulfill and all other factors to be used in evaluating bids or proposals i. §200.319, Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements ii. §200.320 Methods of procurement to be followed. 2. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Sr. Director of Finance, ShelterCare 3. The anticipated completion date: a. The written policies will be updated by 05/01/2024.

Planned Corrective Action: This item was included in the 6/30/22 Report on Compliance for Major Federal Programs which was finalized in February 2023. The G/L Vendor List was found to contain many inactive vendors and was modified. Beginning in October 2023, management began sending the Vendor List to EPStaffCheck on a monthly basis. Each vendor is run through OIG {Office of Inspector General for Excluded Individuals/Entities); OIG_Most_Wanted (Fugitives); SAM (System for Award Management for excluded parties); SON.Office of Foreign Assets Control (Specially Designated Nationals) and NY_Medicaid (Exclusion List).

Finding 2023-002 – Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Sandy Denny – Food Service Director Contact Phone Number: 812-952-2555 ext. 250 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all procurements obtain the required number of quotes and a debarment/ suspension check is performed as required. Anticipated Completion Date: July 2024 (new school year)

MANAGEMENT’S CORRECTIVE ACTION PLAN: Management will review and update as necessary, it’s current procurement policies and procedures to ensure compliance with all applicable sections of the Uniform Guidance, in specific, Sections 2 CFR 200.318(i) and 200.320(a)(2)(i) of the Uniform Guidance, as well as 24 PS 8.807.1. In specific, these procedures will include 1) obtaining all relevant information pertaining to procurements involving federal assistance from any cooperative purchasing group, 2) obtaining quotations from three qualified providers where applicable and documenting those results, and 3) properly document purchases using federal assistance when the vendor meets the criteria as a sole source provider. These three (3) updated procedures will be implemented during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for future purchases where applicable.

2023-004 – Procurement, Suspension and Debarment Cluster: Research and Development Sponsoring Agency: NASA, National Science Foundation (NSF), Department of Energy (DOE), National Institutes of Health (NIH), Department of Health and Human Services (DHHS) Award Names: Various Award Numbers: NNX17AB45G, 2137984, 2230861, DE-SC0010064, DE-SC0022559, R01MH115979-05, 1R01DA054967-01A1, 1R01DK132735-01, 3UM1AI068636-15S3, 5R01HL155905-03, 5R01GM143536-03, 2RF1AG048120-06R, 5UM1AI106701-10R2 Assistance Listing Titles: Science, Mathematical and Physical Sciences, Biological Sciences, Office of Science Financial Assistance Program, Mental Health Research Grants, Drug Abuse and Addiction Research Programs, COVID-19 - Trans-NIH Research Support, COVID-19 - Allergy and Infectious Diseases Research, Allergy and Infectious Diseases Research, Biomedical Research and Training, Aging Research Assistance Listing Numbers: 43.001, 47.049, 47.074, 81.049, 93.242, 93.279, 93.310, 93.855, 93.859, 93.866 Award Year: 2022-2023 Pass-through entity: N/A all are direct awards On January 2, 2024, the University's Procurement system, BruinBuy Plus, was updated to incorporate additional controls. When purchase requests are made, the system will identify any transactions over $10,000 involving federal sources and send them to the central Purchasing unit for review. Before these transactions are approved, the central Procurement Buyer must ensure that all necessary documentation and checks are completed. Spot checks are also performed by managers as an additional level of review. All relevant documentation, including quotes, price reasonableness, and Statements of Work, are now stored within BruinBuy Plus along with the transaction. In conjunction with the new system, Central Buyers received training from November 27, 2023, to December 22, 2023, for two hours daily.The Chief Procurement Officer has acknowledged that additional training is necessary and will be scheduled this spring. For inquiries regarding this finding, please contact Selina Martin at selinamartin@finance.ucla.edu who is responsible for the corrective action.

COVID 19 Coronavirus State and Local Fiscal Recovery Funds/ ALN 21.027 - Significant Deficiency - Internal Controls over Procurement Prior to purchase, Sarasota County worked with the State of Florida Medical Examiner to create and document procurement policies in conformance with the Uniform Guidance, to include sourcing of quotes, issuance of purchase orders, and certifications by vendors on acknowledgment and adherence to applicable 2 CFR requirements. The County acknowledges that the State of Florida Medical Examiner conformed with these requirements prior to purchase to include noncompetitive purchases which was further supported in a dated letter provided by the Chief Medical Examiner. The Program Division Manager, Steve Hyatt shall require and retain such additional documentation within its procurement files and will conform to sourcing this documented information for these instances prior to any future purchases. Implementation date for this process - Immediately

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micropurchases, 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. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The Cooperative did not adhere to the requirements necessary for them to be in compliance with the procurement of small purchases during the audit period. Suspension and Debarment The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As such, the Cooperative never entered into a contract, although their payments to the vendor exceeded $50,000. The INDIANA STATE BOARD OF ACCOUNTS 30 Cooperative did not perform procedures to ensure that the vendor was not suspended or debarred from participation in federal programs. Contact Person Responsible for Corrective Action: Lana M. Miller Contact Phone Number and Email Address: Phone Number-812-689-6282 Email- lmiller@sripley.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ROD Special Education Cooperative will make notes in the Board Minutes regarding the fact that only one vendor can provide specific services prior to entering into a contract or purchasing said services. Each company providing services will be checked on the SAM.gov website to ensure that the vendor has not been suspended or debarred. This documentation will be provided to the ROD board for review, and our Superintendent is a member of that board. Anticipated Completion Date: February 1, 2024

2023-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 through 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 enhancing the federal procurement policy to include sections 200.318 through 200.326. Name of the contact person responsible for corrective action: Shannon Marimón Planned completion date for corrective action plan: February 29, 2024

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 2022-003 Noncompliance – Procurement and Suspension and Debarment (Repeat Finding 2022-003) Significant Deficiency Recommendation: The Auditor recommended the Organization develop a system of internal controls aligned with the applicable compliance requirements to sufficiently document procurements and to ensure suspension and debarment is considered prior to entering into future covered transactions. Planned Corrective Action: While procurement requirements are followed, management concurs that the documentation of procurement activities does not always occur. The Accounts Payable will gather all procurement documentation with the purchase order request. Michelle Krauter, the Director of Accounting & Finance, will approve all purchase order requests. This documentation will be retained with the approved purchase order and invoices. Michelle will ensure all compliance requirements are followed and appropriately documented. If the U.S. Department of Education has questions regarding this plan, please call Michelle Krauter, Director of Accounting & Finance at 317.231.0010

Finding 2023-003 – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Michelle Babcock Contact Phone Number: 317-392-2505 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We have already established an improved internal controls procedures for procurement. We have established a checklist process to ensure the Suspension and Debarment Check has been completed for all federal purchases over the threshold. Anticipated Completion Date: October 2022

Corrective Action Planned: When the District decides to utilize cooperative purchasing programs on noncompetitive purchasing arrangements when spending federal funds, it will ensure that it complies with its procurement policy. The District will document its process and how it complies with the procurement standards and keep such documentation with federal award budget/procurement documents. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding for the year ending June 30, 2024. Contact Person Responsible: Eric S. Petery, Business Manager

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. 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. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The Cooperative did not adhere to the requirements necessary for them to be in compliance with the procurement of small purchases during the audit period. Suspension and Debarment The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred prior to entering into a covered transaction. As such, the Cooperative never entered into a contract, although their payments to the vendor exceeded $50,000. The Cooperative did not perform procedures to ensure that the vendor was not suspended or debarred from participation in federal programs. Contact Person Responsible for Corrective Action: Julie Dudley Contact Phone Number and Email Address: 812.537.7205 jdudley@lburg.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ROD Special Education Cooperative will make notes in the Board Minutes regarding the fact that only one vendor can provide specific services prior to entering into a contract or purchasing said services. Each company providing services will be checked on the SAM.gov website to ensure that the vendor has not been suspended or debarred. This documentation will be provided to the ROD board for review, and our Superintendent is a member of that board. Anticipated Completion Date: February 1, 2024

Specific corrective action plan for finding: Christi Walter, Coordinator Purchasing Department along with the Dom Atcitty, Grants Specialist, will review vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached. At the initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document from SAM.GOV verifying eligibility of vendor will be attached to the vendor file. Timeline for completion of corrective action plan: July 1, 2023 Employee position(s) responsible for meeting the timeline: Dom Atcitty, Grants Specialists; Christi Walter, CPO; Lisa Smith, Purchasing Specialist; Bellamie DeHerrera-Presley, Federal Grants Coordinator and Erica Benally, Federal Grants Specialist

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The failure to establish an effective internal controls system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the School Corporation. We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Food Service Director will obtain 3 quotes for any purchase over $10,000 from different vendors, in addition if the purchase is over $50,000 a contract will be awarded. Vendors will be verified by SAM.gov for suspension and disbarment, a record of these searches will be printed and kept in the vendor file. In addition, a vendor list will be provided annually to the school board for approval. Anticipated Completion Date: July 2024

This document serves as the response to the 2022-2023 Financial Audit on behalf of BELIEVE Schools, Inc. We’ve identified and reviewed the finding outlined below: The results of our auditing procedures disclosed one instance of noncompliance which is required to be reported in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) and which is described in the accompanying schedule of findings and questioned costs as Finding No. 2023- 001. Our opinion on the major federal programs is not modified with respect to these matters. In an effort to address the finding and to ensure the school's alignment with federal compliance standards, the following corrective action plan has been implemented for all purchases made with federal and state program funds: 1. For any procurement or contract ranging from $10,000-$250,000, The Principal, Angel Jackson-Anderson, should seek to acquire as many quotes as possible, aiming for up to five. Prior to finalizing any purchase order, invoice, or commencement of production, the school is mandated to receive and assess three price comparisons from different businesses or organizations. These price comparisons must be logged in the BCCHS Quote Comparison Template and reviewed by the following parties: a. The individual conducting the price comparison b. Building Level Operations Leader c. Executive Director for purchases or contracts exceeding $20,000 2. For any purchase or contract exceeding $250,000, a formal bidding process is required. BELIEVE Schools has adopted resources provided by the Indiana Department of Education: a. Procurement Checklist b. Procurement Plan Template (accessible through DOE) This protocol has been incorporated into the Standard Operating Procedures and School Handbooks, with all relevant stakeholders duly informed on February 16th, 2024.

FINDING 2023-003 Finding Subject: Subject: Child Nutrition Cluster - Procurement Summary of Finding: An adequate number of quotes were not obtained for small purchases. Contact Person Responsible for Corrective Action: Kellie Romer (Corporation Treasurer/Finance Director), Shelley Gardner (Corporation School Food Authority) Contact Phone Number and Email Address: 765-653-9771 Ext. 1010, kromer@greencastle.k12.in.us, 765-653-9771 Ext. 1011, sgardner@greencastle.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The procurement (small and micro purchases) will be verified by a two-person internal control; the food services director and food services assistant, finance director or deputy treasurer. We will also establish a process to address small and micro purchases. This would include acquiring bids for any combined expenditure(s) over a $150,000, acquiring quotes for any small purchase(s) between $10,000 and $150,000, and documenting equitable distribution among vendors concerning any micro purchases under $10,000. All vendor contracts will be approved yearly. All quotes and purchases will be verified by two-person internal control. Anticipated Completion Date: Immediately 2/8/2024

Condition: The organization did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Planned Corrective Action: Management has revised the Finance Management Manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities. Contact person responsible for corrective action: Misty Jordan, Director of Administration Anticipated Completion Date: 11/14/2023

2023-002 Suspension and Debarment Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A signed debarment letter is now a required document for vendors greater than $25,000. This letter is verified by our University procurement office before the item is purchased.   Name(s) of the contact person(s) responsible for corrective action: Dawn Durham Planned completion date for corrective action plan: 10/6/2023

Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved in the submission, review and/or approval of the schedule of expenditures of federal awards. This includes One City’s Executive Chef, Executive Director of K-8, COO and VP of Government Relations (who oversees compliance). Designated staff will take advantage of all DPI-provided training seminars and resources available, and we will track attendance of relevant staff members. This process will be in place by June, 2024.

Corrective Action Planned: This was first brought to the Authority’s attention in the current year. At such a late date in the federal project that has been in the works for multiple years, the Authority determined established procurement procedures would not be written and approved. The Authority did not make this decision in haste. The Authority met compliance guidelines for the procedures of items during the project. What we lack is an approved written document, which at this time is something we do not have the resources to undertake. Anticipated Completion Date: Ongoing Contact Person Responsible: Jennie Weary, Treasurer/Secretary

Finding 2023-004 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding summary: During the course of the engagement, Eide Bailly identified that the district did not have a procurement policy in compliance with Uniform Guidence. Responsible Individuals: Rhandi Knutson, Director Corrective action plan: A procurement policy in compliance with Uniform Guidance will be approved and implemented. Anticapted Completion Date: June 30, 2024.

2023-003: Written Debarred, Suspended Vendors & Federal Standards of Conflict Finding Condition - The Town of Dayton did not have written controls in place to ensure that vendors were not suspended or debarred or included on the list of vendors prior to entering into a contract with the Town. The written standard of conduct covering conflicts of interest and governing the performance of its employees and contractors engaged in the selection, award, and administration of Federal grants contracts. Corrective Action Plan - Even though the Town didn't have a formal written policy in place regarding the search for suspended or debarred vendors/contractors, the Town did do the SAM's search before signing agreements with contractors on each of the Federal Grant projects that were in place during the year. That being said, the Town will develop a written internal control plan and a policy on procurement for debarment in the coming months.