Corrective Action Plans

Description of Finding: During the Auditor?s control and compliance test work the following was noted: o In testing three of the consultants used, all three had contracts that exceeded $25,000 but were not tested for suspension and debarment. o In testing three of the consultants, used, all three had contracts that exceed the Simplified Acquisition Threshold (SAT) of $250,000, but no sealed bids, proposals, or documentation of sole source was performed. o Through further inquiry, the written ?micropurchase? policy of $50,000 was not self-certified. o Through further inquiry, small purchases that exceed micropurchase policy but are less than SAT did not obtain quotations. As a result, FHI is not in compliance with federal requirements when entering into procurement contracts as well as not meeting suspension and debarment requirements by potentially contracting with a suspended or debarred vendor. Statement of Concurrence or Nonconcurrence: A resume of every contractor and their budgeted compensation was provided to the Department of Agriculture with our competitive application as well as with the service agreement contract signed by both representatives of USDA and FHI. Because of timing on the grantor?s end, FHI has less than 10 business days to review and ratify contract and no one at USDA questioned use of consultants, consultants by name/resume or compensation amounts. However, we acknowledge Federal regulations cited by the Auditor. Questioned Costs: None Corrective Action: ? FHI will search SAM.gov for suspension and debarment of contractors and keep those records on file. FHI will perform this search annually as the contractors registration expires and is renewed. ? FHI will perform an annual self-certification that includes a justification, clear identification of the threshold, and supporting documentation to allow for $50,000 as the micropurchase limit. Name of Contact Person: Person responsible for completing the corrective action plan is Nicole Mast, Director of Operations, nmast@flowerhill.institute. Projected Completion Date: December 31, 2023 Oversight: Contractor documentation will monitored annually to ensure compliance through the end of the current contract (currently March 2026).

Suggested Action (s)- Send out communication to reinforce understanding and responsibilities of the verification process as required by CRS policy. Responsible Official- Global Controller Senior Director Finance Systems & Operations Regional Finance Officers Country Program SMT. Completion Date- September 30th, 2023.

2022-002?Procurement Corrective Action: Current Management is not able to confirm nor deny that appropriate documentation was not collected prior to payment, but highly doubts that it was not collected based on the reliability of the previous Grants Manager. Management notes that the vendor was specifically mentioned in the Grant submission. Management will ensure that purchasing SOP are implemented and selection of vendors is adequately documented. Management has secured project management software that will retain project documentation. This should ensure appropriate documentation is collected and available to all Management for the life of the project, until date of destruction. Person Responsible: Jennifer Hogan, Executive Director Completion Date: September 30, 2023

FINDING: 2022-004 Name of contact person: Bruce Peterson, Supervisor Corrective Action Plan: We have drafted a procurement policy that meets all the requirements of 2 CFR section 200.318 through 200.326 that has been approved by the Township board on June 12, 2023. The policy has been submitted to the Township attorney for review, and will be finalized pending any modifications or recommendations by our attorney. Proposed Completion Date: Immediately.

2022-003 FINDING Contact Person ? CJ Holl, County Administrator Corrective Action Plan ? The County will implement procedures to ensure that federal procurement standards are followed for federal grant purchases. Completion Date ? Ongoing

Management has updated their procurement policy to align with the requirements of 2 CFR 200.318

CORRECTIVE ACTION PLAN For the Year Ended September 30, 2022 Southwest Kansas Area Agency on Aging, Inc. respectfully submits the following corrective action plan for the fiscal year ended September 30, 2022. Name and address of independent public accounting firm: Kennedy McKee and Company LLP P.O. Box 1477 Dodge City, Kansas 67801 Audit period: October 01, 2021 through September 30, 2022 The findings from the September 30, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - Major Federal Award Programs Audit U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-001 Title III Aging Cluster Title III B Supportive Services CFDA 93.044 Title III C Nutrition Services CFDA 93.045 Title III C Nutrition Services Incentive CFDA 93.053 Grant Period: Year ended September 30, 2022 Condition: The Organization did not have a written procurement policy to properly implement all the requirements of 2 CFR Section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Criteria: In accordance with 2 CFR Section 200.319(c), non-federal entities must have written procedures for procurement transactions. Such policy should incorporate all requirements within 2 CFR 200.318 through 200.326 of the Uniform Guidance. Cause: The Organization?s procurement policy does not incorporate all the requirements of 2 CFR Section 200.318 through 200.326 of the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program compliance requirements. Southwest Kansas Area Agency on Aging, Inc. Corrective Action Plan February 9, 2023 Recommendation: Management should continue to develop comprehensive written policies and procedures to administer all federal programs. Current written policies should be evaluated for inclusion of and compliance with Uniform Guidance requirements. Grantee Response: Management agrees with the finding and will adopt written policies to comply with Uniform Guidance requirements. If the Oversight Agency has questions regarding this plan, please call Rick Schaffer at (620) 225-8230. Sincerely yours, Rick Schaffer Executive Director 236 San Jose Drive Dodge City, KS 67801

Finding 2022-005 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Testing and Mitigation for Rural Health Clinics FFAL #93.697 Compliance Requirements: Procurement, Suspension, and Debarment Finding Summary: The Facility did not obtain quotes from multiple vendors as it relates to the procurement and purchasing of flooring which was over the micro-purchase threshold. In addition, the vendor was not verified against the central contractor registry prior to transaction inception or on a periodic basis to ensure the vendor was not suspended or debarred. Responsible Individuals: Phillip Husher, CFO, Freeman Regional Health Services Corrective Action Plan: Going forward Freeman Regional Health Services will obtain and retain quotes from multiple vendors based on our procurement policies. Documentation will be retained to support the decision of the vendor selected. Also, we will review the Central Contractor Registry to ensure vendors are not suspended or debarred before entering into covered transactions. Anticipated Completion Date: September 30th, 2023

Finding 2022-002 Lack of Internal Control Over Procurement Name of Contact Person: Stella Krumrey, Tribal Council President Corrective Action Plan: The Alutiiq Tribe of Old Harbor has purchasing policies and procedures in place and takes them very seriously. The Tribe believes it followed the proper procedures for the transactions that took place during FYE 09-2022. Unfortunately, due to Tribal Administrator transition during the fiscal year, the documentation of proper purchasing procedures for a major transaction was misplaced and after a thorough search could not be located. The Tribe believes this error was a single mistake and not a pattern. Proposed Completion Date: September 30th, 2022

ARPA Business Support Program ? Assistance Listing No. 21.027 Recommendation: We recommend the Chamber adopt a procurement and suspension and department policy that is in accordance with requirements established by the Uniform Guidance. Furthermore, we recommend these policies are approved by the board of directors. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Chamber is not expecting to receive federal funds exceeding the $750,000 single audit threshold in the future. However, the Chamber will review 2 CFR ? 200.318 and 200.213 while preparing the procurement and suspension and debarment policies to ensure Uniform Guidance standards are followed. Name of the contact person responsible for corrective action: Colin Hastings, Executive Director Planned completion date for corrective action plan: May 2023

Recommendation: The Auditor recommended developing a system of internal controls which provides adequate documentation surrounding procurement and suspension and debarment transactions. Planned Corrective Action: Management agrees with the recommendation and has implemented the following steps. A procurement policy, compliant with the Procurement Standards codified in 2 C.F.R. ? 200.317 through? 200.327 has been approved by the Board of Directors. This policy states the procedures required for documentation for procurement of goods and services related to all Federal awards. As well, the procedure includes a step for accessing Sam.gov to review all vendors annually to ensure they have not been identified as suspended or debarred.

Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement new policies and procedures to ensure that all expenditures of American Rescue Plan (APRA) funds will follow the procurement guidelines outlined in the US Treasury rules and regulations as well as County procurement policies. Name(s) of the contact person(s) responsible for corrective action: Sherri Crow, Interim Director of Budget and Finance Planned completion date for corrective action plan: January 1, 2024

2022-004 Special Education Cluster ? Assistance Listing No. 84.027 & 84.173 Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will work with their departments utilizing federal dollars to ensure the proper procurement method is utilized for all procurements and that documentation of that process is retained so its clear what considerations were made in the procurement decision. Name of the contact person responsible for corrective action: Shari Thompson Planned completion date for corrective action plan: June 30, 2023.

Finding 2022-001 Program: Highway Planning and Construction Cluster CFDA Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2021-2022 Compliance Requirement(s): Procurement, Suspension, and Department Finding Summary: The City?s written policy and procedures for purchasing were not updated to incorporate the applicable Uniform Guidance requirements of sections 200.318 through 200.327 that apply to the procurement action based on the method of procurement. Responsible Individuals: Kelly Sessions, Director of Administrative Services Corrective Action Plan: The City is working to update its written procurement policies and procedures to incorporate the applicable requirements identified in sections 200.318 through 200.327 of the Uniform Guidance that apply based on the procurement action and the method of procurement as required by section 200.318(a). Anticipated Completion Date: September 30, 2023

2022-001 Procurement, Suspension and Debarment Contact: Joseph Wilson Title: SVP, Procurement Phone Number: 202-760-4193 Estimated completion date: September 2023 Corrective Action: Management agrees with the finding and recommendations set forth within and is nearing completion of its revised procurement policies and procedures to conform with Uniform Guidance procurement requirements. The updated procurement policy is scheduled to be released during the third quarter of the fiscal year 2023. Training on the Uniform Guidance procurement requirements has been developed and will be required for all staff with procurement responsibilities to ensure (1) adherence to Uniform Guidance and (2) that appropriate justifications for noncompetitive contracts are used and properly documented. Last, during the first quarter of the fiscal year 2023, NeighborWorks implemented a new contracts management system that will be used to manage all aspects of vendor contracts from planning to closeout, including the contract expiration date. Full transition to the new system is targeted for the end of the fiscal year 2023.

Finding 2022-002 ? Child Nutrition Cluster ? Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Serena Francis, Business Manager Contact Phone Number: (765) 226-0603 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We have joined the Food 2 School consortium beginning with 2022-2023 school year. Both our Food Service Director and our Business Manager receive all emails and communication. This will allow internal control and oversight to ensure that the consortium is compliment with all state and federal procedures. We also have moved all of our small purchases into this purchasing consortium system. Anticipated Completion Date: August 1, 2023

CORRECTIVE ACTION PLAN JUNE 30, 2022 REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Wendi Allardice - Superintendent Karen Hancock - Title I/ESSER Grants Manager 2. Corrective action planned: A. Protocols developed to obtain at least 3 vendor quotes for any items over 10,000 with an analysis and justification of vendor chosen. B. Protocol in place for checking for vendor suspensions or debarment prior to purchase approval. C. Monthly meeting for comparison of proposed and estimated purchases and actual purchases and charges to the Grant. 3. Anticipated completion date: Anticipated completion date for above listed plan: 08/31/2022

Finding 2022-002: Procurement Policy (Material Weakness) Information on the Federal Program: U.S. Department of State ALN 19.040 Criteria or Specific Requirement: 2 CFR Section 200.318 requires that 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. Condition: FCE does not have a formal written procurement policy that conforms to the requirements of the Uniform Guidance. As a result, no procurement files were maintained to document FCE's procurement actions. Cause: FCE has no accounting policies and procedures in place to provide guidance to management on the documentary evidence requirements in accordance with proper internal controls and the Uniform Guidance. Effect or Potential Effect: Without either a procurement policy or procurement documentation, there is a risk that FCE did not perform a proper evaluation of each potential vendor whose costs were charged to federal programs. Recommendation: FCE should develop accounting policies and procedures to provide guidance to management regarding the proper internal controls over both financial reporting and compliance with federal awards. Included in those policies and procedures should be a procurement policy that conforms to the requirements of the Uniform Guidance. Furthermore, FCE should maintain documentation in its files to provide evidence to support that it followed the procurement policy. Action Taken: FCE acknowledges the requirements of the Uniform Guidance and the non-compliance implication for Federal awards. FCE is in the process of developing and implementing a procurement policy to ensure proper competitive procedures are followed with respect to its procurements, specifically its vendors. FCE will ensure that proper documentation is maintained in its files in accordance with the policy to be implemented.

UNITED STATES DEPARTMENT OF EDUCATION 2022-002 Education Stabilization Fund: Higher Education Emergency Relief Fund Student Portion and Institutional Portion ? Assistance Listing No. 84.425E, 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. Action planned/taken in response to finding: The University has reviewed and will continue to monitor procurement and suspension and debarment policies and update procedures as needed to ensure compliance with federal requirements. Name(s) of the contact person(s) responsible for corrective action: John Nisbet, Interim Vice President of Administration & Finance Planned completion date for corrective action plan: April 2023

Finding 2022-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2022-002. A Sams.gov account has been activated in order to verify that entities that are being utilized for County business are not excluded from or are ineligible for participation in Federal programs or activities. Also, the County is currently drafting a Procurement Policy for Washakie County to utilize for the use of Federal funding as well as in an everyday manor of purchasing and maintenance of county facilities in order to satisfy above finding.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jessica Secrease Contact Phone Number: 765-456-2804 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County will establish a federally-compliant conflict of interest policy in addition to the County?s current conflict of interest policy. The County Attorney will be notified again that this policy still needs to be created. Anticipated Completion Date: 10/31/2023

Finding Number: 2022-001 Condition: The College did not have a policy in place to ensure it was complying with "Never Contract with the Enemy" and verifying that a contractor is not debarred, suspended, or otherwise excluded from doing business with federal assistance programs or activities. In addition, the College's policy does not include all provisions in 2 CFR Section 200.318-327. Planned Corrective Action: An Albion College ?Never Contract with the Enemy? policy will be put into place and have the following conditions within the policy: The ?Grants and Foundation Relations Grants Manual? will be updated to include policy information about this federal regulation and how to determine whether a subcontractor/vendor is prohibited under this policy from being paid with federal grant funds. The Grants and Foundation Relations team (?GFRT?) will include the federal regulation in every ?Grants Kickoff Meeting? checklist and will discuss with the Principal Investigators (?PI?s) during grant development so that issues can be addressed at the beginning of federal grant application process. PI?s of the federal grants will be responsible for checking the SAM excluded vendor list as they are finalizing their budget and/or planned expenditures to confirm all subcontractors/vendors are allowed and in good standing, before any contract over $50,000 is executed or any invoice greater than $20,000 is paid. The Business Office will verify that the vendors or subcontractors for federal grants have been checked against the SAM excluded vendor list during the expenditure approval process. In addition, the College with develop a procurement policy that conforms to provisions in 2 CFR Section 200.318-327 and all federal grant recipients should review and adhere to that policy for all purchases and expenditures made with federal grant funds. Consult with GFR or the Business Office if there are questions about these standards and how they may impact federal grant expenditures. Contact person responsible for corrective action: Amy Routhier-Chief Advancement Officer for Grants and Foundation Relations & Albert Hammond-Staff Accountant-Gifts and Grants Anticipated Completion Date: The GFRT has added a ?Never Contracts with the Enemy Policy? to the Grant Manual, which is presented at all ?Grant Kickoff? meetings. The team also discusses with each (?PI?) in grant development what the policy expectations are.

2022-003 - Procurement Corrective Action Planned: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget., its own existing Board Policies, and has developed administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement methods. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding in the current fiscal year . Contact Person Responsible: Kenneth L. Medina, MBA, Business Manager/Board Secretary

DHS agrees with the finding and recommendation. DHS will remind staff via electronic memoranda to ensure compliance with federal and County procurement requirements and maintain records sufficient to detail the history of the procurement.

Finding ref number:2022-001. Finding caption: The City did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of City contact person: Holly Beller P.O. Box 548, Ilwaco WA 98624 (360) 642-3145. Corrective action the auditee plans to take in response to the finding: The City will develop and adopt written policies and procedures that conform with Uniform Guidance (2 CFR 200.318-327) for procurement activity and conflict of interest requirements. Anticipated date to complete the corrective action: January 1, 2024.