Corrective Action Plans

2022-003 ? Procurement, Suspension, and Debarment Corrective action plan: The Tribe will amend its Financial Management System, to increase the micro-purchase procurement threshold from $2,000 to $10,000, set by the Federal Acquisition Regulation. When processing Purchase Orders, the Purchasing Clerk will verify that a minimum of three bids or quotes have been submitted with the Purchase Order request, for those items costing $10,000 or more. This requirement will help ensure that goods and services are being obtained at a fair price. The Tribe will amend its Financial Management System to include a policy on suspension and debarment. For purchases exceeding $25,000, the Finance Manager will perform a search of the vendor on the Systems for Award Management (SAM) website, to verify that the vendor receiving payment has not been suspended or debarred. Personnel responsible for corrective action: Finance Manager (Lisa Donham) Estimated corrective action completion date: December 31, 2023

HEERF Procurement, Suspension and Debarment ? Assistance Listing No. 84.425F Recommendation: We recommend that the College review their procurement policy to ensure a process is in place to follow it in the future. We also recommend a policy be drafted surrounding suspension and debarment that includes all federal requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will review their procedures around HEERF reporting and ensure someone is designated to review prior to uploading the reports. Name(s) of the contact person(s) responsible for corrective action: Kelly Flege Planned completion date for corrective action plan: update plan

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number: 317-485-3100 Views of Responsible Official : We concur with the finding Description of Corrective Action Plan: The Food Service Director (FSD), with assistance from the CFO, will develop a plan to secure a third vendor for kitchen equipment repairs, both for emergencies or regular maintenance repairs. The FSD and CFO will also develop a plan to solicit service plan proposals from qualified providers. The FSD and CFO will utilize approved service agreements through purchasing cooperatives, if available or, solicit responses through the public works bidding process. If a responsive responsible bidder can be secured, the service contract will be approved by the school board of trustees. Anticipated Completion Date: 7/1/2023

View of Responsible Officials and Planned Corrective Actions: FamilyForward was responsive and provided requested information to the awarding entity at each stage of the appropriation, single source determination, contracting, and payment process. FamilyForward relied upon the awarding entity?s single source determination that activities undertaken in our role as subrecipient were conducted in accordance with all required policies and procedures, including procurement. FamilyForward will implement procurement policies and procedures to ensure that we meet requirements of Uniform Grant Guidance in advance of soliciting or securing federal funds for projects.

The District will monitor vendors to ensure they are able to accept federal monies. Samantha Schweizer, Business Administrator by 6/30/2023.

Charter Schools ? AL #84.282 2022-003 Noncompliance ? Procurement and Suspension and Debarment (Repeat Finding 2021-003) 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 reorganization of the Business Office described above in 2021-002 will allow the Controller to oversee procurement of purchases with federal funds and to ensure all compliance requirements are followed and appropriately documented. If the U.S. Department of Education has questions regarding this plan, please call Juli Woodrum, Vice President & Chief Financial Officer at 317.231.0010 x16109.

2022-004 INTERNAL CONTROL OVER COMPLIANCE AND COMPLIANCE WITH PROCUREMENT, SUSPENSION AND DEBARMENT The National Trust has a Procurement SOP that is fully responsive to CFR ?200.318, and the sampled expense complied with that policy when procured in April 2022. Federal funds were awarded in July 2022 permitting reimbursement of costs incurred as early as March 2021. At the direction of pass-through entity Westchester County, these one-time coronavirus relief funds were applied to reimburse the National Trust for expenses selected by that entity even though the vendors were contracted prior to the award of relief funds. To remedy any gaps in our process, the National Trust will modify the Procurement SOP to clarify that multiple contracts with a single vendor must be treated as a single contract for purposes of the small purchase threshold and will ensure that all expenses are subject to the more stringent requirements under CFR ?200.318. Additionally, the National Trust will modify the procurement procedures to ensure that suspension and debarment screening occurs prior to entering contracts. Individual(s) Responsible for Corrective Action Plan: Thompson Mayes Chief Legal Officer and General Counsel 202-588-6182 Anticipated Completion Date: June 30, 2023

When using federal funds the County Board Administrator will retain documentation recording the details of procurement and also complete suspension and debarment procedures for a vendor when the procurement is over $25,000.00.

Finding 2022-001: Significant deficiency in internal control over procurement. Summary: There was no documented evidence that a contractor was required to comply with the prevailing wage requirement of the Federal Award agreement in one contract under the Federal Award. Corrective Action Planned: Written policies and procedures regarding procurement and grant compliance will be updated and implemented to ensure compliance with procurement terms and conditions of Federal Awards. Anticipated Completion Date: By Sept 30, 2023. Name of Contact Person Responsible for Corrective Action: Tammy Rash, Administrative Services Director

2022-003 PROCUREMENT, SUSPENSION AND DEBAREMENT ? COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Recommendation: We recommend the county align their county wide policies to address any necessary modifications to the process if procurement transactions are federally funded. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their internal procurement policies to better align with federal requirements for purchases that fall under these requirements. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

2022-004 PROCUREMENT, SUSPENSION AND DEBAREMENT ? STATE ADMINISTRATIVE MATCHING GRANTS FOR SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP CLUSTER) Recommendation: We recommend the county align their county wide policies to address any necessary modifications to the process if procurement transactions are federally funded. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their internal procurement policies to better align with federal requirements for purchases that fall under these requirements. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jim Evans Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This finding has been corrected by discontinuing purchases from the vendor in question for the remainder of the 2022-2023 school year. In future years, future purchases from this vendor will be limited to $9,000.00 per fiscal year. The purchases will be monitored by the Food Service Director and the Food Service Managers in each building. Anticipated Completion Date: This finding has been corrected.

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Brook Cleaver Contact Phone Number: (765) 675-2147 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Superintendent and Treasurer will work to ensure that bids are sought and kept on file for projects exceeding the simplified acquisition threshold. Once a vendor is selected, Treasurer will search exclusions in the Sam.gov portal for vendors that may be suspended or debarred from participation in federal assistance programs and keep said documentation on file. Anticipated Completion Date: Immediately.

U.S. Department of Transportation 2022-001 Formula Grants for Rural Areas ? Assistance Listing No. 20.509 Recommendation: We recommend that current policies and procedures over covered transactions be updated to include one of the following procedures related to suspension and debarment: - Searching for the person or entity within the Excluded Parties List System; - Collecting certification from the person or entity; or - Adding a clause or condition to the covered transaction with that person or entity Additionally, all contracts should be maintained and kept on file to ensure records are complete. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VAC management has drafted a policy to ensure that a check of the excluded parties list system is completed and documented prior to entering any covered transaction over $25,000. Name(s) of the contact person(s) responsible for corrective action: Justin Dooley, Finance Director Planned completion date for corrective action plan: 2/15/2023

Recommendation: We recommend the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Action taken: The district entered into a shared services agreement with Capital Region BOCES in March of 2022 for management of the School Nutrition program. It was assumed that this was a procedure they followed; however, documentation was not provided and the external auditors included it as a finding. Todd Barker is the new School Nutrition Director with BOCES and he will provide documentation to the district that due diligence has been done to meet this requirement. Anticipated completion date: 11/1/2022

March 10, 2023 Federal Audit Clearinghouse Re: Corrective Action Plan for Community Action Partnership of Mercer County To whom it may concern: Views of Responsible Officials and Planned Corrective Actions: 2022-01 There is no disagreement with the audit finding regarding our procurement policies and the lack of documentation in the Weatherization file that was reviewed. The Organization will review the Procurement policies and make necessary adjustments to how we acquire services from contractors and what the thresholds are. We will also be reviewing our documentation policies in Weatherization and making the adjustments to what documents go into the consumer file. Employee Responsible for Corrective Action: Michelle Clarke Completion Date: May 31, 2023 Respectfully Submitted, Michelle Clarke VP/CFO

October 14, 2022 U.S. Department of Education 400 Maryland Avenue, SW Washington, D.C. 20202 Re: Corrective Action Plan Finding 2022-002: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds, Procurement, Suspension and Disbarment Program: COVID-19 Education Stabilization Fund (ESF) - Institutional Portion Assistance Listing Number (ALN): 84.425F Federal Agency: U.S. Department of Education Federal Award Identification Number: P425F201693 Federal Award Year: June 30, 2022 Condition: The College?s policies and procedures over procurement generally conform to the requirements outlined by the Uniform Guidance with an exception bonding requirements, contracting with small and minority businesses, and items from Appendix II to Part 200. The auditors compared the College?s policies and procedures to the applicable sections of the Uniform Guidance by reviewing two vendors of a total of four vendors with expenditure for the ESF funds and obtained the associated supporting documentation for our selections. Additionally, the auditors noted that the Institution?s procedures were not followed with regard to ensuring full and open competition, obtaining bids/quotes for the items above the micro-purchase threshold, or retaining documentation for the requirement for verifying for vendor suspension or debarment prior to contracting. The College did check for suspension/disbarment following our identification of the finding and there were no issues. The sample was not a statistically valid sample. Corrective Action Plan Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. Members of the College did not appropriately follow federal procurement guidelines related to costs that were included in the institutional reimbursement portion of HEERF funding. This was an oversight and occurred as a result of the timing of when the purchases were made, or the contracts were entered into, and when the HEERF funding and applicable guidance was communicated by the Department of Education. At the time the contracts were entered into, members of the College did appropriately review all contracts and the related costs for reasonableness to ensure that the College was being prudent with its financial resources, whether from the federal government or not. Members of the College have also reviewed SAM to ensure that these vendors were not suspended or debarred. The College?s federal procurement policies and procedures will be updated to ensure that all items from the Uniform Guidance are included and followed for all federal grants. Nathan Engle Controller

2022-001: Procurement and Suspension and Debarment Corrective Action: Northwest College will perform a review of its current procurement policy, including purchasing thresholds, record retention of supporting documentation regarding method of procurement utilized, and maintaining supporting documentation regarding suspension and debarment for all contracts or purchases expected to equal or exceed $25,000 of Federal funds. Northwest College will revise its procurement policy as determined necessary and in accordance with Northwest College?s policies. Anticipated Completion Date: June 30, 2023 Contact Persons: Brad Bowen, Finance Director

Regent concurs with this finding. The issue was fully rectified in 2022. Due to the timing of when the issue was identified, two audit years were impacted, however this should not be interpreted as an ongoing issue. There were no questioned costs associated with the finding. Regent?s Correcting Action Plan includes two components: (1) The Regent University Purchasing Policies governing the use of any Federal awards have already been updated to fully reflect alignment with Federal Procurement Policies, and Regent will follow those updated policies in full; and (2) as a component of the updated policy, Regent University will complete a review of any vendors associated with Federal awards for which the suspended and debarment requirements apply to ensure compliance with Federal policy, and the first such review has already concluded.

June 9, 2023 Maher Duessel 50.3 Martindale Street-Suite 600 Pittsburgh, PA 15212 To Whom It May Concern: Please see our corrective action plan for the findings reported in the June 30, 2022 Schedule of Findings and Questioned Costs. Finding 2022-001- General Ledger Maintenance and Reconciliation Criteria: Timely reconciliation of financial data is necessary to ensure accurate financial information is reported in order to make appropriate business decisions by management and those charged with governance. Condition: The West Mifflin Area School District {School District) did not consistently perform internal control procedures designed to maintain and reconcile the general ledger throughout the year. As a result, the trial balances originally presented for the audit were not properly reconciled and balanced. Cause: The School District did not consistently follow its procedures to ensure that all balance sheet accounts were reconciled to the general ledger and accurately reported in a timely manner. Effect: The financial data was not fully reconciled and completed throughout the year. The audit was delayed to provide time for the trial balances to be updated and ready. Various adjustments were necessary to update the records for the audit and to prepare the financial statements. Recommendation: We recommend that the School District reconcile all of its accounts in a timely manner. Reconciliations should be completed on a monthly basis to support and ensure that the accounts are properly stated. The review should ensure that the reconciliations are completed accurately and that reconciled amounts agree to the general ledger. The review and approval should be documented. Views of Responsible Officials and Planned Corrective Action: The School District agrees with the recommendation. The process undertaken to update the financial records has been updated to include a more formal procedure to reconcile the general ledger. This review is being performed on a more regular basis and the accounts will be updated and reconciled timely and in advance of the fiscal year 2023 audit. Finding 2022-002- Questioned Costs Related to Procurement Federal Agency: Department of Education Federal Communications Commission Program: COVID-19 Education Stabilization Fund (ESF): 84.425 COVID-19 Telehealth Program: 32.006 Criteria: In accordance with Uniform Guidance procurement requirements found in 2 CFR Part 200.318 through 200.237, the School District is required to ensure that procurement methods used for purchases are appropriate based on the dollar amount of the purchase. Recipients of federal awards should have internal controls in place to ensure procurement practices are consistent and appropriate. Policies should dictate the method of procurement that should be used, who is authorized to approve purchases, and what procurement documentation and information should be maintained. The policy should also explain which items are eligible for non-competitive procurement (i.e., available only from a single source, public emergency, expressly authorized by awarding or pass-through agency, or if competitive procurement results are deemed inadequate). Condition: The School District did not adequately document its analysis that its technology purchases for the ESF and the Telehealth Program qualified for non-competitive procurement for being available through a single source. As a result, the School District did not have documentation to provide evidence of compliance which resulted in questioned costs. Cause: The School District did not have a formal procedure in place to adequately document the procurement procedures that were used. Effect: The School District was not in compliance with the procurement requirements of the Uniform Guidance. Questioned Costs: $1,001,167 based on the technology equipment invoice applied to the ESF and $499,768 based on the technology equipment invoice applied to the Telehealth Program. Recommendation: We recommend that the School District ensures that their purchasing policy formally reflects the procurement requirements in the Uniform Guidance. We recommend that the School District establish procedures to ensure that their purchasing policy is followed, including the use of competitive bids or proposals, when appropriate. Views of Responsible Officials and Planned Corrective Action: The School District agrees with the recommendation. However, in the beginning of the ESF program, the School District had to act fast to ensure that they could provide the necessary technology to its students. Supply of such equipment was low and the School District had to purchase items that were available in the necessary timeframes for the school year. The School District's management id informally review, justify, and approve all purchases made with ESF and Telehealth funds. Going forward, the School District has recognized its need to enhance its purchasing procedures and will be reviewing its purchasing policy to ensure that it is in compliance with the requirements. Furthermore, the Business Office will ensure that the purchasing policy is followed for all purchases, especially those made through federal programs. These improvements will be in place in advance for the start of fiscal year 2024.

Planned Corrective Action: The contract with Prodigy- Building Solutions LLC is in its final stage for completion at this point, Going forward the district will request more documentation from the Ohio Purchasing Council before awarding a future project. Anticipated Completion Date: November 1, 2023 Responsible Contact Person: Ben Teeters, Treasurer, Hillsboro City School District

FINDING 2022-003 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: The Director of Food Service and Assistant Director of Food Service will review the SAM Exclusions prior to entering a financial agreement with the vendor. The Child Nutrition Secretary will review all claims to ensure no contractors are subject to non-procurement debarment suspension are used. The acquisition threshold will be monitored for all vendors by the Director of Food Service and Assistant Director. Formal bid process and awarding of contracts will be followed as federal regulations required. ANTICIPATED COMPLETION DATE: March 2023

FA 2022-001 Improve Controls over Procurement Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.027 - Special Education Grants to States COVID-19 - 84.027 Special Education Grants to States 84.173 - Special Education Preschool Grants COVID-19 - 84.173 Special Education Preschool Grants Federal Award Number: H027A200073 (Year:2021), H027A210073 (Year: 2022), H027X210073 (Year: 2022), H173A200081 (Year: 2021), H173A210081 (Year: 2022), H173X210081 (Year: 2022) Questioner Costs: $72,747 Description: A review of expenditures charged to the Special Education Cluster (Assistance Listing Numbers 84.027 and 84.173) revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement procedures were followed. Corrective Action Plans: We concur with this finding. Internal Controls procedures have been reviewed and will be followed to ensure that required procurement methods are being applied to each transaction and that proper documentation is maintained in the expenditure field. Transactions will be reviewed by the Program Directors to ensure that the internal control procedures are operating appropriately and in accordance with Federal Programs Uniform Guidance. Estimated Completion Date: Fiscal Year 2023 Contact Person: Trey Wood, Finance Director Telephone: 706-795-2191 ext. 1023 Email: trey.wood@madison.k12.ga.us

Finding: Per 2 CFR 200.303, the Council must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Non-federal entities other than states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Entities must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for good and services awarded under non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Corrective Actions Taken or Planned: Recently we implemented and communicated a revised Procurement policy that reinstates the requirement of 3 competitive bids if the requisition amount is over $10K. NSC will ensure reinforcement of this policy through multiple layers of review (Legal, Accounting and Executives). Although, the policy was recently reinstated NSC will ensure that it will abide to the policy as much as is possible for all purchases prior to November 1st. In order to facilitate and implement the new procurement policy, NSC will utilize ERP system AVID which helps create approval routings through automated workflows. Accounting, Legal and up to the VP level will ensure and review proper documentation. The CFO and COO will be the final line of review prior to ultimate approval for all purchases above the VP delegation level of authority. The following approvals are required for procurements for items up to: 15K by VP?s of business units 50K by CFO, 100K by COO, Over $100K by CEO. A thorough review of Federal grants will be performed and a new standard operating procedure created, to ensure that all federal ruled are properly being followed as part of the procurement policy. Finally, multiple training sessions and communications to all affected staff will be conducted in order to ensure future compliance at all levels. Anticipated completion date: October 27th 2022 Individual Responsible: Ron Hausner, CFO

2022-002 Health Centers Cluster ? Assistance Listing No. 93.224 and 93.527 Health Center Infrastructure Support ? Assistance Listing No. 93.526 Recommendation: Management should adhere to or revise the Organization?s existing procurement policy and implement a system of processes and internal controls to ensure that the appropriate level of documentation is maintained based on the procurement methodology selected for a transaction of contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) Procurement ? missing documentation for sole source purchase justification or price comparisons. Heartland?s purchasing policies and procedures were reviewed for content and clarity. In addition to the policy and procedure review, we will implement a more robust documentation, review, and approval process regarding larger purchases and sole sourcing. Purchases that are grant related and > $2,500 where the 3 bid minimum decision-making process is being waived and sole source is being utilized will be documented by the purchasing manager and reviewed, approved, and signed by our CEO as to why this is the optimal vendor (1). (See attached template) 2) Suspension and Debarment- missing documentation for quarterly review of vendors. Vendors will be reviewed on a quarterly basis to ensure that they are not on the exclusion list. The Accounting Specialist will report to the Controller on a quarterly basis regarding the status of the vendor review, and documentation of the review will be provided to the Controller at that time. Name(s) of the contact person(s) responsible for corrective action: Michael Cohlman, CFO and Tony Bartlett, Controller Planned completion date for corrective action plan: 4/1/23