Corrective Action Plans

Description of Finding: There were two vendors that did not have the documentation to substantiate the use of the vendors, or the necessary pricing quotations. Corrective Action Plan: In the case of these two vendors, there were items ordered directly by a University department. These vendors were familiar vendors in the work of the department, so the standard vetting and documentation by the Purchasing department was not performed and documented. To correct this, all new vendors for purposes of Federal Awards will not be added into the system until reviewed and approved by the Purchasing department. The responsible parties are Lori Gordien Case at lgordien@laverne.edu, Xochitl Martinez-Eckel at xmartinez@laverne.edu, and Debbie Deacy at ddeacy@laverne.edu . This was corrected in November 2022.

Response: Management notes that, as this is their first time receiving significant federal funding and this was one-time emergency funding rather than an ongoing award, they do not have procurement procedures in writing which adhere to 2 CFR Part 200.318(a). However, they adhered to their internal written procurement procedures and conflict of interest policies, followed the award guidelines, and obtained multiple bids in the selection of vendors for contracted services. Action to be taken: Management notes that, as this was one-time emergency funding rather than an ongoing award, they do not anticipate receiving federal funding in the future. As such, they do not intend to document these procedures in writing at this point. However, if they apply for federal funding again in the future, they will develop written procedures at that point. Responsible Person: Andrew Edwards, Executive Director

Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. These procedures will help ensure compliance with Compliance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will create a formal, written procurement policy. Management will also review the noncompetitive procurement procedures and will document how and why our vendor(s) meets these requirements, if applicable. Additionally, HTHF will improve internal processes increasing the foundation?s work with our accounting support staff moving to a monthly service from quarterly with expenses entered into QuickBooks each month. Once expenses are entered, they will be reviewed by management and by the board treasurer. Name(s) of the contact person(s) responsible for corrective action: Joseph Holmes Planned completion date for corrective action plan: 10/31/23

Finding 2022-010 Lack of Internal Control over Procurement Name of Contact: Roxanne Peele, Office Manager Corrective Action: HCA will adhere to financial policies and procedures and maintain documented procurement action and methods in selecting vendors for major purchases. Proposed Completion Date: 08/31/2023

Recommendation: We recommend the University revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: EOU is currently reviewing the institutional procurement process to determine if a single set of guidelines should be in place, rather than federal vs non-federal funding. Using a single set of guidelines would create a uniform procurement process, no matter the funding source, however additional options are currently being investigated. Name(s) of the contact person(s) responsible for corrective action: Haley Evans, Controller Planned completion date for corrective action plan: October 2023

Finding: 2022-02 Finding Summary: Utah Food Bank verified that contractors were not suspended, debarred, or otherwise excluded from System Award Management (?SAM?), but did not document the procedure and did not retain documentation of this action. Responsible Individuals: Jennifer Pratt, Chief Financial Officer Corrective Action Plan: Utah Food Bank will continue to enhance internal controls over written procurement policies and monitoring vendors to ensure its compliance with the Code of Federal Regulations, including keeping documentation of SAM compliance on each vendor before the work starts and upon each disbursement. Anticipated Completion Date: February 24, 2023

U.S. Department of Treasury 2022-003 COVID-19 State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend the City 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 City 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: Alisha McAndrews Planned completion date for corrective action plan: December 31, 2023.

2022-004 U.S. Department of Justice Federal Financial Assistance Listing/Federal CFDA #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Finding Summary: It was identified that there was no observable documentation to indicate that the required procurement or suspension and debarment procedures were performed on all vendors. Lack of oversight, awareness, or understanding of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous or to suspended or debarred vendors. We recommend that the Organization maintain the appropriate documentation evidencing that procurement and suspension and debarment procedures have been completed. Status: The procurement process is relatively new to the Organization and began during the pandemic with limited staff. The Organization has hired an additional FTE in the Business Office to assist with the management of this task. Responsibility of: Jennifer Babcock, Finance Director. Estimated Completion Date: 12/31/23

FINDING 2022-004 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure that all micro-purchases of $10,000 or less have the appropriate documentation and quotes required by Federal guidelines along with any purchases above the given thresholds based on procurement regulations. Documentation of quotes, bids, or contracts will be maintained by the GCSC Food Service manager and approved by the CFO for accuracy and completeness. A policy and procedure will be created to ensure that supporting documentation is received from the food service vendor that corresponds to any discounts or rebates received and are reflected appropriately in the billing reports. The GCSC Food Service manager will review documentation for billing accuracy prior to claims being paid and approved by the CFO. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

Formal finding #2: Unallowable labor charges were billed to the SFA by SFMC. Response: After consulting with CNU, the SFA requested the SFMC to review practices for billing of labor. They opted not and the district went back to self-operating, no longer using the SFMC. We are seeking legal counsel on recouping of erroneous expenses.

2022-001 Charter Schools ? Assistance Listing No. 84.282 Recommendation: We recommend that the School prepare and adopt a formal, written procurement and suspension and debarment policy that meets federal standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We plan to create a procurement protocol to present to the Board of Directors for approval. Name(s) of the contact person(s) responsible for corrective action: Barbara Burke Fondren Planned completion date for corrective action plan: by June 30, 2023

Corrective Action Plan for Current Year Finding Turning Point of Central California, Inc. submits the following corrective action plan for the identified finding for the audit period July 1, 2021 through June 30, 2022: Finding 2022-001 Procurement Corrective Action: Turning Point of Central California, Inc. has updated Procurement Policy to comply with Uniform Guidance. Turning Point of Central California, Inc. is implementing procedures to obtain and retain required documentation to conform with applicable federal statutes and procurement requirements identified in 2 CFR Part 200. Person Responsible: Finance Director David Lozano. Timing for Implementation: As soon as possible prior to be effective for the fiscal year ending 6/30/24.

Views of Responsible Officials and Planned Corrective Action: Management agrees with the above finding and will amend the Employee and Board Codes of Conduct to address Federal Contracts.

Finding 2022-003 ? Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Scott Miller, Jill Pollard Contact Phone Number: 765-659-1339 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Finding 2022-003 Child Nutrition Cluster - Cafe will gather information and more bids and notate going forward. Anticipated Completion Date: June 30, 2023

FINDING 2022-002 Information on the federal program: Subject: Special Education Cluster - Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 and 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-068-PN01, 21611-068-PN01, 20619-068-PN01, 21619-068-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness, Noncompliance, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Context: For the audit period, there were two vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain price or rate quotations from other vendors or document the basis for purchasing from the vendor that was utilized. The amount disbursed to the vendor in fiscal year 2021 and 2022 was $32,638 and $39,945, respectively. In fiscal year 2022, the School Corporation stated they had obtained two quotes, but was not able to provide documentation supporting two quotes were obtained. The School Corporation was not able to provide verification that the vendor was not suspended or debarred. The lack of controls and noncompliance occurred throughout the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Special Services will conduct the search for individuals to fill the specialized or high-need positions required. If the positions are not filled by employees of Centerville-Abington Community Schools (CACS) then a search for vendors providing the services is conducted. The Director of Special Services will obtain quotes from an adequate number of qualified sources, three if possible. The quotes will be submitted to the Superintendent of CACS for review, sign & dated and returned to the Director. The reviewed quotes will be maintained in each FY grant folder. The Director will also maintain a memo of the procedure for filling the specialized or high-need positions. The memo will also be reviewed by the Superintendent of CACS each year and maintained in each FY grant folder. If a vendor is selected to fill the positions the Director of Special Services will conduct the suspension & debarment search on each vendor contracted. The suspension & debarment search documents will be printed and sent to the Superintendent of CACS for review, sign & dated and returned to the Director. The reviewed suspension & debarment documents will be maintained in each FY grant folder. Copies of all of A District Accredited School Corporation Since 2007 the above described reviewed, signed & dated documents will be filed in each FY grant folder maintained by the Corporation Treasurer of CACS. Responsible Party and Timeline for Completion: The Director of Special Services will conduct the search for qualified individuals or vendors to fill the specialized or high-need positions as soon as the need is identified or as positions become open. If an individual is not hired as an employee of CACS then quotes will be obtained & a vendor will be contracted. If a vendor is contracted the Director of Special Services will conduct the suspension & debarment search within three business days of selecting the vendor. All required documents will be sent to the Superintendent within three business days of receipt of each document. The Superintendent will return reviewed, signed & dated documents to the Director within three business days. Copies will be provided to the Corporation Treasurer at the same time they are sent to the Director. These procedures will be implemented immediately.

Information on the federal program: Subject: Child Nutrition Cluster - Procurement Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553 and 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Context: For the audit period, there were four vendors that fell within the small purchases procurement threshold. Small purchases are those vendors that the School Corporation has purchased between $10,000 - $150,000 of products and goods. During the testing of Procurement and Suspension and Debarment, we noted one instance in a sample of one, where the School Corporation did not obtain three price or rate quotations from other vendors or document the basis for purchasing form the vendor that was utilized. The School Corporation compared the prices from the selected vendor to one vendor from their purchasing cooperative but did not obtain any additional quotes to meet the three-quote requirement for the small purchases procurement threshold. The lack of controls and noncompliance occurred throughout the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Director (FSD) will obtain a minimum of three price or rate quotes for each vendor with expected purchases of $10,000 to $150,000 each school year. Those quotes may be from vendors within and/or outside of the purchasing cooperative. Those quotes will be sent to the Assistant Superintendent who will then present those quotes with a recommendation to the School Board at a meeting open to the public. The School Board will award the appropriate vendor with the purchase of goods for the school year. The discussion, vote and award will be noted in the minutes of the school board meeting. The Assistant Superintendent will notify the FSD of the school board?s decision via email with signed & dated quotes attached. The FSD will maintain copies of all quotes including the quotes that were not accepted in each school year folder. The FSD will send suspension & debarment documents to the Assistant Superintendent for review, signature and date within three business days of selection of the vendor. The Assistant Superintendent will return the suspension & debarment documents to the FSD within three business days of receipt of the documents. The FSD will maintain all reviewed, signed & dated documents in each school year folder. Responsible Party and Timeline for Completion: The corrective action plan will take effect immediately. All tasks will be completed before each new school year begins. The FSD is responsible to obtain three rate or price quotes. The FSD will conduct the suspension & debarment search. The FSD is responsible A District Accredited School Corporation Since 2007 to maintain the files for each school year. The FSD will send all required information to the Assistant Superintendent. The Assistant Superintendent will present and make recommendations to the School Board. The Assistant Superintendent will notify the FSD of the School Board?s decision. SUMMARY

Views of Responsible Officials and Planned Corrective Action: Management prepared a new written procurement policy that defines all types of purchases and is in compliance with the provisions of the Uniform Guidance. This policy was implemented on July 1, 2022.

Planned Corrective Action: In the event of future receipts of Federal Awards, management and the board of directors will work towards developing a Federal Award Policy and Procedure manual. Person Responsible for Corrective Action Plan: Tim Stephens, Executive Director Anticipated Date of Completion: Prior to receipt of additional federal awards.

Finding 2022-003: Procurement Policy a. Comments on Finding and Each Recommendation The University agrees with this finding. As a small, private institution with few federal grants a formal procurement policy had not been previously deemed as necessary. In addition, a cumbersome process for approving official University Policies prevented a timely adoption of a Procurement policy once circumstances warranted one. Action(s) Taken or Planned on the Finding The University updated its process for implementing policies in January 2023. The policy committee began meeting in 2023 and is developing a procurement policy for the University that addresses Federal Procurement requirements. For inquiries regarding this finding, please contact Anna Davis at (405) 208-5542 who is responsible for the corrective action.

Section III - Federal Awards Findings and Questioned Costs Compliance Requirement - Procurement, Suspension and Debarment Significant Deficiency in internal control over compliance and compliance Condition: As part of compiling the Commission's population for procurements, from which a procurement sample would be selected, the Commission identified $26,432 of expenditures charged to the grant that were erroneously included in the SEFA, as the procurement methods were not eligible for federal expenditures. As a result, prior to testing compliance related to procurement, the Commission reclassified the $26,432 of expenditures from the federal grant and removed from the SEFA as of June 30,2022. Cause: The Commission's procedures did not allow for timely identification of the expenditures prior to including on the SEFA (and claiming reimbursement). Effect: A journal entry was posted to correct current year federal revenue balance as of June 30, 2022 in the amount of $26,432. Further, the Commission has applied these expenditures to future draw downs in order to reverse the expenditures that were claimed. Recommendation: We recommend that the Commission review its closing policies and procedures as well as its federal grant management procedures to ensure procurement methods are considered prior to claiming expenditures or reporting on the SEFA. Commission Response: Staff concurs with the recommendation and has reviewed and discussed procedures with finance and transit staff. The invoices are coded for expense and funding by project managers. The reimbursement of expenditures is requested based on this information. During this time period there was a shortage of staff both in the finance and transit departments. Funding requirements were reviewed with transit staff. Finance staff will strengthen the invoice process to verify project manager coding against invoicing to prevent and if necessary, timely correct funding errors. Project Managers will be responsible for reviewing monthly project manager reports that include expenditures and associated funding reimbursed.

Finding 2002-002: Procurement Compliance Description: The Distilled Spirits Council of the U.S. recognizes the importance of implementing a procurement process in accordance with 2 CFR 200.318(a). The International Team (with feedback from the Finance Team), will adopt an updated procurement process with procedures to address various methods of procurement and ensure all vendors entered a covered transaction are not debarred, suspended, or otherwise excluded. Anticipated Completion Date: October 1, 2023 Responsible Contact Persons: Name: Kyna Ricks Position: Controller Email: kyna.ricks@distilledspirits.org Phone: 202-682-8869 Name: Robert Maron Position: Vice President, International Trade Email: robert.maron@distilledspirits.org Phone: 202-682-8826

Condition: During our testing, we noted that the Loan Fund internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Recommendation: We recommend that the Loan Fund reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management accepts this finding and has made efforts to review and update our policies to meet federal cost principles and requirements. These are currently pending approval by the Board of Directors for implementation. Name(s) of the contact person(s) responsible for corrective action: Conchie Searle, CFO Planned completion date for corrective action plan: May 2023

Corrective Action Plan for Finding IC2022-001: Financial Reporting Accomack County understands the repeat finding regarding financial reporting. In our response in FY 21 to this comment we stated ?through the addition of one FTE in the FY 23 year, staff training in particular content areas such as financial reporting, pensions and OPEB reporting, and some realignment of duties with existing staff, we are able to continue internally prepared financial reports through the year and the Annual Comprehensive Financial Report (ACFR) properly and timely?. As an update, we have not been able to make a hire at this time, and have chosen to reformat the position to non-entry level and re-advertise in the spring of 2023. While an additional resource will be helpful, existing staff understanding of timing, and year- end financial reporting will continue to be both ongoing, and a priority. Accomack County Finance continues to consider financial reporting, including the year-end annual financial report a core competency and are open to suggestions in processes or protocols that will advance our capacity and capability in this area from Brown Edwards. As part of this response, County finance recognizes we are responsible for timely and accurate reporting which includes Accomack County Public Schools (ACPS) financial information and all other component units in the ACFR. As we are currently staffed, we do not have capacity for review of ACPS financial work through the year and have previously relied on their finance department. Unfortunately, that has caused delays, findings and revisions to financial exhibits several times at year end for corrections noted by the auditors. The County will explore options for reducing the aforementioned problems and thereby improving this issue as relates the ACPS financial information. Lastly, a component of the delay in FY 22 was the Landfill Closure/Post-closure liability in conjunction with Department of Environmental Quality. We have begun a specific time-line in coordination with the Deputy Director for Public Works, who has responsibility over the landfill and south transfer station so that finance has complete and approved cost information (through the DEQ process) prior to year-end each year, or just after year-end (timely). Responsible Official: Michael T. Mason, CPA, County Administrator mmason@co.accomack.va.us (757-787-5716); estimated completion date of not later than July1, 2023 for the new hire. Corrective Action Plan for Finding FA-2022-001: Procurement Accomack County Public Schools concurs with the need to maintain its Procurement Policy in concurrence with 2 CFR Part 200. The schools will review and update procurement policies to be in compliance. Responsible Official: Chris Holland, Accomack County Public Schools Superintendent, chris.holland@accomack.k12.va.us, (757)787-5759; Estimated completion date is not later than the May, 2023 School Board meeting.

Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2021 ? September 30, 2022 Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: Out of six procurements which were tested, we noted that five of them, for which the District obtained quotes using the small purchase method, did not contain documentation detailing the history of the procurement, including any other quotes obtained. Questioned Costs: ALN 84.027 - $415,251.22. Cause: The district was unaware that they needed documentation for noncompetitive procurements as well as that their policy had a different micro-purchase threshold compared to what was in the UG. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is not a repeat finding. 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. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: Out of eight procurements which were tested, we noted that three of them did not have proper documentation for the justification of noncompetitive proposals and one of them the District did not have documentation detailing the history of the procurement, including any other quotes obtained due to the District not following the micro-purchase threshold listed in their policy. Questioned Costs: $58,198.49 Cause: The district was unaware that they needed documentation for noncompetitive procurements as well as that their policy had a different micro-purchase threshold compared to what was in the UG. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is not a repeat finding. 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. Views of Responsible Officials: There is no disagreement with the audit finding.