Corrective Action Plans

Finding 2022-002: COVID1-19 Education Stabilization Fund, Higher Education Emergency Relief Funds ? Procurement, Suspension and Debarment Program: COVID-19 Education Stabilization Fund (ESF) Federal Agency: U.S. Department of Education Pass Through Entity: Not Applicable Assistance Listing Number: 84.425F Federal Award Number: P425E200445 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. 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 eleven vendors with expenditure for the ESF funds and obtained the associated supporting documentation for our selections. For one of the vendors, it was determined that the College did not obtain multiple quotes before engaging in the contract. 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 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. Staff responsible for procurement 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, all contracts and the related costs were appropriately reviewed 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 subsequently 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.

Cluster: Research and Development Federal Agency: Department of Health and Human Services, Department of Defense Award Names: First-in-human clinical translation of a near-infrared, nerve-specific fluorophore to facilitate tissue-specific fluorescence-guided surgery; Self-Administered, Motor-Free, Cognitive Screening Battery for MS: Development and Initial Validation; Decision Making in Transmasculine Genital Reconstruction Surgery (TMGRS) Award Numbers: 1R01NS116994-01A1; W81XWH2010330; R21DK124733 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development; Diabetes, Digestive, and Kidney Diseases Extramural Research Assistance Listing Number: 93.853; 12.420; 93.847 Award Year: 2021 - 2022 Pass-through entity: Not applicable Management agrees with the finding related to Procurement, Suspension and Debarment. To address these deficiencies Research Operations will conduct staff training for Departmental Research Administrators to ensure staff are knowledgeable of the current policy and the documentation requirements related to purchases above the micro-purchase threshold. D-H is currently following the required procedures but will ensure that the procurement files include supporting documentation, including review of multiple vendor quotations or sole source justification documentation. Furthermore, D-H will update procedures to ensure that all purchases have evidence of the suspension and debarment verification completed prior to payment. Leadership Responsible: Barbara A. Vance, PhD, CRA, Vice President, Research Operations Anticipated Completion Date: 12/31/2023

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) Questioner Costs: $265,630 Description: The polices 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 wages to staff has been reviewed and will only be paid to staff employed by the Colquitt County Board of Education. Estimated Completion Date: Contact Person: Jeremy Jones, CFO Telephone: 229-890-6224 Email: jeremy.jones@colquitt.k12.ga.us

FINDING:2022-003 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: In the future the Food Service Director will check on Sam.gov for any Disbarment on any purchases that is over $10,000.00. She will print it out and initial and keep on file. In the future the Food Service Director will include in their Service Agreement form #1048, for Disbarment, Suspension. The School Corporation will seek Bids/Quotes for anything over $10,00.00 in the future. If the school is not asking for Bids/Quotes for repairs, we will use the company that we have a Maintenance Agreement with. Anticipated Completion Date: February 2023

CORRECTIVE ACTION PLAN November 11, 2022 Kansas State Department of Education and Kansas State Department of Administration High Plains Educational Cooperative, District Number 611 respectfully submits the following corrective action plan for the year ended June 30, 2022. Dirks, Anthony & Duncan, LLC Po Box 885 Ulysses, KS 67880 Audit Period: June 30, 2022 FINDINGS ? FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027; 84.173 Finding 2022-001 ? Internal Controls Recommendations: The Board of Directors, the Director and key positions of management should adequately document internal control procedures relating to procurement and suspension and debarment and adopt board policies related to such. The Board should then periodically check for changes in federal guidelines and update the board policy and needed. Action Taken: We agree with the recommendation and will adopt the board policies at the next meeting. We will also have a meeting to enhance and document stronger internal controls with board members, the Director, Board Treasurer, Technology Facilitator and Finance Clerk. Our targeted implementation date is March 2023. If the Kansas State Department of Education and/or Kansas State Department of Administration has questions regarding this plan, please call Shelly Harris at 620-356-5577. Sincerely yours, Shelly Harris Director

FINDING 2022-001 Contact Person Responsible for Corrective Action: Tamara L. Asdell Contact Phone Number: 812-726-4440 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will anticipate annual procurement expenses with vendors outside of the Southern Indiana Education Center, If the anticipated expenses for the fiscal year are in excess of $10,000 but less than $150,000, the food service director will work to obtain quotes from at least three sources. If the anticipated expenses for the time period are in excess of $150,000, the food service director will conduct a formal bid process and award a contract to the most qualified, lowestpriced vendor. Any vendor with a contract for purchases of $25,000 or more will need to provide a certification or include a contract clause stating the vendor is not suspended or disbarred from participation in federal assistance programs. If not certification or contract clause is produced, the food service director will contact the corporation treasurer to check the vendor's status in SAM. Anticipated Completion Date: August, 2023

CORRECTIVE ACTION PLAN FINDING 2022-004 Contact Person Responsible for Corrective Action: Region 8/Heidi Sprunger Contact Phone Number: 260-589-3133 Views of Responsible Official: We concur with the finding. The district is working with Region 8 to obtain the corrective action plan that was submitted previously. Description of Corrective Action Plan: We will monitor this with Region 8 to ensure that the corrective action plan that was submitted is followed. Anticipated Completion Date: Immediately

Action planned in response to finding: Management will implement procedures to ensure that competitive purchasing procedures are performed for all transactions above the micro purchase threshold and documentation is maintained to support the procurement procedures performed.

Finding 2022-004 Department of Environment Protection Agency, Passed through North Dakota Department of Environmental Quality Federal Financial Assistance Listing/CFDA Number 66.458 Clean Water State Revolving Fund Cluster Finding Summary: During the course of the engagement, Eide Bailly LLP identified that the District does not have a written policy on procurement that satisfies the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Jerry Blomeke, General Manager Corrective Action Plan: The District will establish a written policy that addresses all the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Anticipated Completion Date: December 31, 2023.

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)