Corrective Action Plans

2022-005 Failure to Comply with Procurement Policy Name of contact person responsible for Corrective Action Plan: Robert Eaves, Director of Business Affairs Corrective Action Plan: The plan has commenced and the dollar minimum for Quotes has been increased from $500 to $25,000. When purchases are for $25,000 or more, three quotes will be obtained if vendors can be located for the goods or services requested. The dollar minimum will be input in the Office of Business Affairs Accounting Manual and correspondence sent to all employees via written memorandum and e-mail. Anticipated Completion Data: This process has started and we expect compliance before June 30, 2023.

2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553 and 10.555 Recommendation: We recommend that the School reviews its related policies and procedures to ensure it is retaining documentation showing that the School crosschecked the vendors with procurements over the threshold of $25,000 at the time of procurement, which could be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Operation Manager will develop a documented checklist and ensure checklist is signed and dated when reviewed. The checklist will include a print screen of the SAMS website for disbarment demonstrating the vendor is eligible. Name(s) of the contact person(s) responsible for corrective action: Karen Conner Planned completion date for corrective action plan: 2/1/2023

2022-001 Higher Education Emergency Relief Fund ? Assistance Listing No.: 84.425F Recommendation: We recommend that the University 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. The university has never accepted federal grants except for financial aid and a policy was never required until the allocation of Higher Education Emergency Relief Funds(HEERF) were provided. Action taken in response to finding: As of July 1, 2022 the university developed a federal procurement standards policy for procurement using government funding. This policy will be fully implemented in cases where government funding is provided for procurement of goods and services and addresses the bidding process and meet requirement for suspension and debarments. Name(s) of the contact person(s) responsible for corrective action: David L Kumm, Executive VP CFO/COO Planned completion date for corrective action plan: 7/1/2022

To: RHR Smith From: Casco Bay Islands Transit District Subj: Corrective Action Plan Date: June 1, 2023 We are aware of the Condition identified in Section Ill - Federal Awards, Other Matters regarding 2 CFR Section 200.318 through 200.327. During your audit procedures it was identified that the District's procurement policy did not include some of the elements required by the above federal regulations. In further conversations with you, as our independent auditors, it was also discussed that based upon procurement items sampled, no non-compliance matters were noted. We have amended our CBITD Procurement Policy as of June 1, 2023 to specifically include additional required elements.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Program Name/Assistance Listing Title: MBDA Business Center Assistance Listing Number: 11.805 Contact Person: Carlos Valdivia, VP of Administration and Finance Anticipated Completion Date: October 31, 2022 Planned Corrective Action: The 2 CFR Part 200, Appendix XI ?Compliance Supplement? released in July 2021, did not provide guidance on which of the twelve compliances apply to the grant in question. Therefore, the AZHCC Foundation did not have the proper procurement procedures in place during the calendar year ended December 31, 2021. AZHCC received the 2021 final single audit report, which included the noncompliance with the ?Procurement and Suspension and Debarment? finding, on August 9, 2022. AZHCC implemented and put into action the proper policies on October 1, 2022. It is the AZHCC Foundation?s policy that minority and women owned businesses whose expertise match the needs of the contract get preference over other contractors. While we have worked with our vendors for many years, by virtue of the government grant source, we are constantly vetting minority business enterprises for new and diverse contractors. The following was implemented on October 1, 2022: ? The AZHCC Foundation developed policies and procedures for: o purchases that exceed the micro-purchase threshold of $10,000 but are less than the simplified acquisition threshold of $250,000. o Verification that selected vendors are not suspended or debarred. ? The AZHCC Foundation distributed policies and procedures to staff. ? The AZHCC Foundation trained staff on the new policies and procedures. It is the AZHCC position that the correction action was implemented within a timely manner, within 60 days, from the day of receiving the 2021 final audit report. None of the transactions in question for the 2022 audit finding took place after the correction action was applied.

Corrective Action/Auditee Views ? Management acknowledges the comment; however, was not directly involved in the purchase of the equipment as it authorized the funds to be paid to one of the supporting non-profit volunteer fire companies for the procurement of hydraulic equipment used for extrication at the scene of a vehicular accident. The town recorded the asset as is the policy to record the capital assets purchased for the non-profit fire and rescue companies that serve our residents. Management will change the purchasing policy to include a policy that all outside agencies expecting funding from the town for any purchase must adhere to the town?s purchasing policy, allow the town to directly procure the items needed, or forfeit the right of reimbursement. Anticipated Completion Date ? June 30, 2023 Contact Person ? Kelli Russ, Finance Director

FINDINGS?FEDERAL AWARDS DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-002 Continuum of Care ? Assistance Listing No. 14.267 Recommendation: Procedures should be implemented to ensure an adequate review process is in place to monitor new and potential vendors to determine whether a conflict of interest exists. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: See attached Procurement and Conflict of Interest Policy. See Corrective Action Plan for chart/table Name of the contact person responsible for corrective action: Christine Simiriglia, President & CEO Planned completion date for corrective action plan: March 2023 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Christine Simiriglia at 215-390-1500.

Finding 2022-002 Federal Agency Name: U.S. Department of Education Program Name: COVID-19 - Higher Education Emergency Relief Funds ? Student, COVID-19 ? Higher Education Emergency Relief Funds ? Institutional, and COVID-19 ? Strengthening Institutions Program Procurement, Suspension, and Debarment Significant Deficiency in Internal Control FAL #: 84.425E, 84.425F, and 84.425M Finding Summary: The University previously had not received federal awards, other than Student Financial Assistance monies. As a result, they did not have a written procurement policy in place. Management worked on creating a policy in the prior fiscal year, however the policy does not include all the required elements. Responsible Individuals: Spencer Conroy, Chief Financial Officer Corrective Action Plan: This finding was a repeat finding because by the time that the initial matter was discovered it was already too late to rework the policy. Management has since put in place a procurement policy which complies with compliance standards. The finding will not recur. Anticipated Completion Date: Immediately

Finding 2022-007: Procurement, Suspension, and Debarment Federal Agency Name: Department of Health and Human Services CFDA #93.087& 93.829 Program Name: Enhance Safety of Children Affected by Substance Abuse & Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: Testing identified one contract for each of the above programs where the required contract provisions in accordance with Uniform Guidance were not included within the contract over $25,000. In addition, no documentation was retained to support management?s rationale to select both of these contracted vendors. Responsible Individuals: Project Directors (Christina Eggink-Postma, Sarah Heinrichs, Rebecca McCrackin) and CEO (Dan Ries) Corrective Action Plan: CEO will review contracts to ensure proper contract provisions are included in accordance with Uniform Guidance and the Center?s procurement policy. The CEO will document what has been reviewed and whether or not the contract has all the necessary contract requirements before contracts are executed. Anticipated Completion Date: This process was implemented beginning January 2023.

DEPARTMENT OF TREASURY AND CENTERS FOR DISEASE CONTROL AND PREVENTION 2022-004 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ? Assistance Listing No. 21.027 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ? Assistance Listing No. 93.323 Recommendation: We recommend the County design controls to ensure compliance with federal procurement and suspension and debarment regulation and its purchasing policy and suspension and debarment verification procedures. We recommend the County develop standard justification forms with approval of the noncompetitive procurement documented on the forms and the forms maintained in the procurement file. Also, we recommend the County update its purchasing policy to ensure clear, concise, and detailed suspension and debarment verification procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The County is currently in the process of implementing a county-wide contract clause that will be added to covered transaction contracts to comply with 2 CFR 180, to ensure covered transactions receive verification that the person or entity is not excluded or disqualified. Review and approval of this suspension and debarment verification will be performed during the contract approval process, which will include this standardized clause. The County?s purchasing policy and procedures manual will be updated to include this standard suspension and debarment verification process to ensure this procedure is communicated county-wide and followed. Additionally, the County will develop standard justification forms to document method of procurement to be maintained in the procurement file. The County will also update its contract templates to include applicable suspension and debarment attestation language which meets Federal requirements and update its purchasing policy and procedures manual to reflect these changes. Name(s) of the contact person(s) responsible for corrective action: Desiree Belding Planned completion date for corrective action plan: November 30, 2023

The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with 200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors. CFO, Eddriene Sylvester. Timeline 180 days.

District Response: A. What corrective action will be taken: District will follow all the requirements of 2 CFR 200 with respect to federal procurement requirements. B. Who is responsible (name and position): Dr. Stephen Gregory, Federal Program Director C. When will the plan be implemented? Corrective action started May 5, 2023, and will continue.

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 - 84.4250 - 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: The School District will review all contracts to ensure all payments to contractors are not in excess of the contracted amount. In addition, the policies and procedures for haling all funds, including ESSER, will be reviewed to ensure internal controls are in place and all compliance requirements are met. The Finance Director will participate in processional development to better understand how to calculate and report indirect cost. Estimated Completion Date: June 30, 2023 Contact Person: Mary Beth Gordon Telephone: 912-545-2367 Email: bgordon@longcountyschools.org

The Fiscal Officer and management company have reviewed the description of the issues and are taking steps to put stronger documentation procedures in place that will support the evaluation and selection of vendors paid from Federal programs. With respect to these specific purchases in FY22, we are confident that if the process had been appropriately documented, we would have reached similar conclusions about who was ultimately selected as the vendor for these projects. We believe the corrective actions we are taking will put us in full compliance with 2 CFR part 200 and the School?s Federal Procurement Policy in future periods.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Bryce Welsh Contact Phone Number:765-345-5101 Views of Responsible Official: We concur with the finding. While we believe that we had controls in place for this finding we failed to produce the proper documentation to prove that we did so. Description of Corrective Action Plan: Going forward we will make sure that all suspension and debarment documents are provided to the Business Manager and kept at central office. These documents will be reviewed and signed by the Business Manger showing internal controls are in place. We will also ensure that we have a contract with the vendors for purchases between $50,000 and $100,000. Anticipated Completion Date: 3/14/2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jami Parks Contact Phone Number: 812-794-8750 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The School Corporation will sign agreements with Food2School for all Food Service contracts to obtain quotes, these quotes will meet Procurement, Micro purchases and simplified acquisition requirements. Food2Schools will also obtain and share documentation with the school showing vendors meet suspension and disbarment requirements. Anticipated Completion Date: August 01, 2023 (Beginning of the 23/24 school years)

2022-006 Special Education Cluster (IDEA) Recommendation: The School Corporation should design procedures and controls to ensure compliance with suspension and debarment provisions. Before entering into a contract, a check should be performed and retained to support the contractor status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The school corporation will check vendors on the SAMS site to verify the contractors are not suspended. Documentation of the verification will be retained. Name of the contact person responsible for corrective action: Cheryl Harvey, Business Manager Planned completion date for corrective action plan: Begin immediately

FINDING 2022-002 Contact Person Responsible for Corrective Action: Shane Hacker, CFO; Tracy Boss, Deputy Treasurer; Jordan Ryan, Coordinator for Nutrition Services Contact Phone Number: 317-852-5726 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Moving forward, the Nutrition Services Coordinator will ensure that a certification of suspension and debarment is completed prior to approving contracts over the $150,000 threshold, per the district?s Child Nutrition Procurement Plan. Anticipated Completion Date: July 1, 2023

Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs and use federal funds for those purchases that a review of compliance with the procurement policy occurs. The District should then document its process and how it complies with the procurement standards. View of Responsible Officials: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and has developed administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Grant Guidance Federal acquisition thresholds and requirements. Effective the 22-23 fiscal year forward the District will fully deploy the referenced administrative procedures to all applicable District stakeholders and monitor all such procurements for compliance purposes.

2022-006 Higher Education Emergency Relief Funds (HEERF) Procurement, Suspension and Debarment Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters 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: Tabor College will ensure that appropriate procedures and policies are followed for procurement, including suspension and debarment. Name(s) of the contact person(s) responsible for corrective action: Cathy Castle, Vice President for Business and Finance Planned completion date for corrective action plan: Immediately.

FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency 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 COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioner Costs: $30,180 Prior Year Finding: None Description: The polices and procedures of the School District were insufficient to provide and adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Revise Federal Programs Handbook to enhance internal controls in the area of contracts. Provide addendums to contracted services to provide for retention bonuses to contracted staff. Estimated Completion Date: June 30, 2023 Contact Person: Seth Taylor, Chief Financial Officer Telephone: 229-723-4337 Email: staylor@early.k12.ga.us

FINDING 2022-002 Contact Person Responsible for Corrective Action: LaGrange County Auditor Contact Phone Number: (260) 499-6310 Views of Responsible Official: We concur with the findings from SBOA The County will establish a internal control system of checking Excluded Parties List System, collecting a certification from that person or adding a clause or condition to the covered transaction with that person for all vendors equal to or in excess of $25,000 for SLFRF award funds to ensure such contractors and subrecipients are not suspended, debarred or otherwise excluded. Copies of supporting documents to be retained. Anticipated Completion Date: Implementation will begin immediately.

Audit Finding Reference Number: 2022-003 Recommendation - South Shore should develop a documented procurement policy in accordance with the uniform guidance. Corrective Action Plan - We will develop a policy as part of our overall Policy & Procedure Manual that matches all uniform guidance regulations related to procurement.

Finding Summary: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Responsible Individual: Jake Roger, Town Administrator. Corrective Action Plan: The Town will produce policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Completion Date: December 31, 2023.

The PrimeCare Controller and the PrimeCare Grants Manager will attend Uniform Guidance training related to procurement to a.) ensure that all Uniform Guidance procurement rules and regulation are appropriately understood and appropriately reflected in PrimeCare?s procurement policies; and b.) implement procurement processes and workflows that are reflective of compliance with Uniform Guidance procurement rules and regulations.