Corrective Action Plans

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.

Segregation of Duties Recommendation: In regards to the payroll function, we noted that although the payroll clerk does not have access to certain rights or functions within the payroll system such as the ability to modify employees? salaries, the individual is performing all payroll duties. In regards to claims/cash disbursements, while the system allows the accounts payable clerk to add and modify vendors, the School District does have a process in place of adding new vendors which requires the signature of an Administrator; however, overall, we suggest that the segregation of duties be reviewed and adjusted where possible to strengthen the system of internal control. It should be noted that the School District has hired a Treasurer after fiscal year end, and payroll claims functions should be segregated to strengthen the system of internal control. Management?s Response: The District agrees regarding the need for segregation of duties. We now have a separate, full-time Treasurer who does not serve as the Payroll Clerk. Additionally, the Assistant Superintendent of Business reviews payroll and all supporting documentation during the certification of payroll. Finally, with the reorganization of work that has occurred in the business office, the creation and modification of vendors within the financial management system will be reassigned. In this way, the accounts payable clerk will no longer have access to activate new vendors or to modify existing vendors. Procurement and Suspension and Debarment Recommendation: The sample we selected for testing did not follow competitive bidding procedures or maintain documents as to the rationale for the method of procurement and contractor selection or rejection. However, management took remedial action in 2022-2023 as we noted an RFP. 48 CFR Section 52.244-5(a) states, ?The Contractor shall select subcontractors (including suppliers) on a competitive basis to the maximum practical extent consistent with the objectives and requirements of the contract.? Further, 2 CFR Section 200.318(i) states, ?The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but not necessarily limited to, the following: Rational for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.? The School District has taken remedial action for fiscal 2022-2023 and should continue to follow State and Federal procurement guidelines and select contractors on a competitive basis. Management?s Response: The District issued a Request for Proposals (RFP) to ensure that procurement of said professional services is consistent with Federal and State requirements. The District intends to maintain this system of procurement in the future. Internal Balances (Due To/From Accounts) Recommendation: The School District should clear all interfund balances to the extent possible in accordance with General Municipal law. Management?s Response: As previous noted by the immediate past Assistant Superintendent for Business, the interfund balances are maintained by a part-time Treasurer/Payroll Clerk and the Accounting Consultants, Management Advisory Group. Now that a full-time Treasurer has been hired, the review and clearing of these interfund balances will now be completed on a regular schedule, and in all cases, these internal balances will be cleared by June each year. Extraclassroom Activity Funds Recommendation: (Regarding Clubs with no activity) State Education Regulations provide that inactive funds shall remain in the custody of the Central Treasurer for six months and then either expended by vote of the organization controlling the funds as provided for in the bylaws or transferred to the general student organization or student council. A determination of the status of the clubs with no financial activity should be made to determine the proper disposition of funds. This will deter all clubs from becoming inactive in future years. The School District does have a policy in place to transfer inactive funds to the student organization. Management?s Response: Twenty clubs is a lot of clubs to be inactive. Some of the Clubs? inactivity is due to remnant COVID issues. The District will work with advisors to re-initiate activity, and for those clubs that we know will be inactive, we will transfer funds to the Student Council organization and notify the clubs, as appropriate. Special Purpose Fund Recommendation: We recommend that Trust agreements be located and filed accordingly so as to determine that revenues and related expenditures are within the terms of the agreements. Management?s Response: Moving forward, the District will maintain the scope and criteria of newly created scholarships. This new file will include the requirements for selection of scholarship awardees. Recommendation: We suggest that the School District analyze the balances and review the purposes of these funds so that a determination may be made as to the proper disposition of funds. Should it be determined that these amounts are no longer required to be held in trust, a board resolution should be approved transferring these funds to the General fund. We suggest that as previously mentioned, a schedule of each individual trust be prepared, and interest earned should be allocated accordingly, rather than having an account entitled Interest Earnings. Management?s Response: All scholarships will be moved to a separate bank account, instead of being co-mingled with other activities within the Special Revenue Account. This will enable us to track earned interest more granularly and allocate that interest accordingly.

COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 Recommendation: Our auditors recommended that the Organization implement processes and procedures to ensure that all vendors are reviewed against the debarred vendors listing prior to entering the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization currently utilizes a third-party vendor, Compliatric, to screen vendors in accordance with SAM.gov requirements on a routine basis. However, a procedure does not currently exist to ensure 100% of new vendors are entered into this separate system. A procedure is being developed to ensure that all new vendors are entered into Compliatric, and screening is completed prior to entering into a contract. Name(s) of the contact person(s) responsible for corrective action: Jason Sanchez, CFO Planned completion date for corrective action plan: Has been implemented

COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 Recommendation: Our auditors recommended that the Organization implement processes and procedures to ensure that all disbursements charged to the federal follow the proper procurement standards and to maintain support for the procurement methods used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 (Continued) Action taken in response to finding: The Organization is reviewing and modifying the Purchase Requisition and Purchase Order Policy to reflect current practices more accurately, update federal regulations and associated purchase thresholds. In addition, the Organization is improving internal procedures to manage requisition submittals which reach thresholds that would dictate multiple bid submittals as well as ensure an annual training of the Organization?s management and purchasers on policy parameters. Name(s) of the contact person(s) responsible for corrective action: Jason Sanchez, CFO Planned completion date for corrective action plan: Has been implemented

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 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) S425U2120012 (Year: 2021) Questioned Costs: $104,640.00 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: We concur with this finding. The process used to pay retention pay to staff has been reviewed and will only be a paid to staff employed by the Appling County Board of Education. Estimated Completion Date: 5/5/2023 Contact Person: Adrienne Taylor, CFO Telephone: (912)367-8600 Email: Adrienne.taylor@appling.k12.ga.us

Finding 2022-002 ? Procurement, Suspension, and Debarment Contact Person: Michael R. Castilleja, Director of Procurement & Other Support Services Current Status: Correction of this finding is in-progress. Anticipated Completion Date: December 31, 2023 Condition: The University did not maintain records for procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Additionally, as required by the University?s Procurement and Bid Policy, the University did not maintain and provide documentation of the performance of an annual pricing review in order to assess whether preferred vendors continue to provide comparable pricing to other vendors. Identification of repeat finding: N/A UIW is committed to complying with the Procurement, Suspension, and Debarment regulations as indicated in the Uniform Guidance Procurement Standards (2 CFR ? 200.317 through 200.327). The University?s practice to maintain records for procurements which include the rationale for the method of procurement, selection of contract type, price analysis (including bidding process) and justification of vendor selection are currently being followed. Due to the urgency and state of emergency the University was under, it hindered our efforts of documenting our procurement practices. An oversight of the Procurement Standards has been reviewed and we are confident that our policies and procedures are sufficient to satisfy the requirements of the regulations. In addition, the University will implement a Sole Source/Preferred Vendor Form that will require justification and evidence of a vendor meeting the requirements of the purchase within a reasonable, allowable and consistent manner. ? Sole Source Vendors will be identified by department needs and may be requested at time of purchase requisition. Determination will be based on vendor availability of products and needs. ? Preferred Vendors will be maintained for the year and must be requested for market pricing review to include date of request, vendor category and price for like items. The Preferred Vendors list will be maintained in the Procurement Department and may be requested for review by initiator of purchase requisitions. All Sole Source/Preferred Vendor request should be reviewed/signed by requestor, a Procurement Officer, and the CFO & VP for Finance and Administration.

Program: Coronavirus State Local Fiscal Recovery Funds (SLFR) CFDA No.: 21.027 Federal Grantor: U.S. Department of Treasury Passed-through: Fresno County Award No. and Date: Fresno County Agreement 22-126, April 5, 2022 Finding 2022-003: Procurement & Suspension and Debarment Type of Finding: Material weakness in internal controls over Procurement & Suspension and Debarment and Noncompliance View of Responsible Officials: Concur with the finding. Corrective Action Plan: ? The District will establish written procurement policies and procedures as required by the Uniform Guidance (2CFR Part 200). ? The District will implement the following internal controls: 1. Review the Uniform Guidance and update the current policies and procedures to include all the requirements not part of the District?s current policies. 2. Make available the updated policies and procedures to responsible management and employees. 3. Management should monitor compliance and performance with the policies and procedures. Projected Implementation Date: June 30, 2023 Name of Responsible Person/Contact: Josh Chrisman, Administration Officer

Finding 2022-001 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund - Institutional CFDA # 84.425F Finding Summary: In the testing of procurement, suspension, and debarment it was identified that there was no observable control documentation to directly indicate that a cost or price analysis was performed. Responsible Individuals: Tonya Sletto Corrective Action Plan: Based on the limited amounts of Federal Awards received by the University that require procurement procedures to be applied, the University was not aware of the formal policy requirements under Uniform Guidance. We will work to adopt a policy for procurement policy that includes the requirements noted under Uniform Guidance and use that policy when federal money is being spent. Anticipated Completion Date: October 31, 2022

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend the Town 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 Town of Easton will modify the current procurement procedures to add an additional section for those services, materials or products procured that have a Federal Grant Revenue source. Name(s) of the contact person(s) responsible for corrective action: Donald Richardson Planned completion date for corrective action plan: June 30, 2023

Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) CFDA No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance Repeat Finding from Prior Year: Yes, prior year finding 2021-09. Management?s or Department?s Response: We Concur. Views of Responsible Officials and Corrective Action: Procedures have been developed and implemented to comply with the County?s policies over procurement and suspension and debarment. Name of Responsible Person: Bruce Cosby Name of Department Contact: Bruce Cosby Projected Implementation Date: July 1, 2023

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Laura Clark, the Director of Finance, is currently developing a procurement and related conflict of interest policy. These policies will be presented to the Board of Directors for approval at the July 2023 board meeting. Name of the contact person responsible for corrective action: Laura Clark, Director of Finance Planned completion date for corrective action plan: July 2023

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2022 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2022-003 Description of Finding Procurement and Suspension and Debarment 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. EASTCONN should have internal controls designed to ensure compliance with those provisions. EASTCONN?s procurement standards do not include the required elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action EASTCONN?s Executive Director and the Board of Directors will review, revise, and approve an updated procurement policy to incorporate required elements of the Uniform Guidance related to expenditures funded with Federal Grants. Name of Contact Person Eric S. Protulis, Executive Director Projected Completion Date November 2023

Assistance Listings number and program name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Fund Contact: Maryn Belling Anticipated completion date: June 30, 2023 Corrective Action Plan: The County procurement officer will, in collaboration with responsible departments, follow County policies and procedures for determining and documenting each sole-source procurement including documenting the good-faith search for available sources, concluding a single source, and including the related documentation in the contract file. The Procurement Officer and departments responsible for procurement will participate in annual training about County policies and procedures regarding the determination and documentation of sole-source procurement.

2022-002 PROCUREMENT ? STATE ADMINISTRATIVE MATCHING GRANTS FOR SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP CLUSTER) Recommendation: It is recommended the County ensure they follow their countywide policies regarding federal procurement and retain documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will ensure they follow their federal procurement policy for purchases. Name of the contact person responsible for corrective action plan: Lindsey Meyer, Finance Director Planned completion date for corrective action plan: December 31, 2023

Finding 2022-002 Procurement Description of Finding The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326 and purchases were made that did not follow these requirements. Statement of Concurrence or Nonconcurrence Management agrees with this finding. Corrective Action: Corrective action will be taken to ensure the policy is updated and the correct procurement procedures are followed. Name of Contact Person: Edward B. St. John (475) 473-3352 Projected Completion Date: June 30, 2023

Finding No. 2022-007: Procurement Policy - Material Weakness in Internal Control Over Financial Reporting U.S. Department of Health and Human Services, Health Center Program Cluster; CDFA No. 93.224 Condition: There is no formal documentation or evidence to support that competitive price analysis for vendors selected by CCI several years ago or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Recommendation: Marcum recommends that CCI update its existing procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. Marcum also recommend that a review of all vendor contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Action Taken: CCI is recommending to the board to update its procurement policy by obtaining at a minimum-three separate bids for anything above $50,000.00. We are also in the process of hiring a full-time purchasing manager to oversee procurement policy and strategy. Anticipated Completion/Implementation Date: End of fiscal year 2024.