Corrective Action Plans

Significant Deficiency in Internal Controls ? Procurement, Suspension and Debarment Funding Agency: Department of Treasury Program: Emergency Rental Assistance Program Assistance Listing Number: 21.027 Criteria or Specific Requirement: Criteria or specific requirement: 2 CFR 200.318(i) states that "the non-Federal entity must maintain record sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price". In addition, 2 CFR 200.320(a)(2)(i) states that "... If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity". Per the Organization's written procurement policy, the adequate number of sources is determined to be three. Condition: For the entire population (two disbursements from one procurement), documentation was not retained for the adequate number of price comparisons prior to exercising the procurement, as required and stated in the Organization's written procurement policy. Context: A sample of two disbursements from a population of one procurement transaction charged to the major program that exceeded the Organization's established micropurchase threshold of $10,000. The transaction was found to be out of compliance with the Procurement requirements, as documentation was not retained for the adequate number of price comparisons. Questioned Costs: Undeterminable Cause/Effect:. An employee charged with the procurement process for these transactions misinterpreted the aggregation rules between capitalization and procurement thresholds, and therefore did not obtain nor retain three contemporaneous quotes. Without adequate records retained, the Organization is at risk of noncompliance with the standards of Procurement. Recommendation: Opportunity Council has already taken steps to communicate the error with the applicable employee and is currently implementing an additional level of fiscal review earlier in the procurement process to ensure that documentation exists prior to procurement and that it is retained with the accounting record. We recommend moving forward with the additional layer of review and emphasizing the importance of the procurement standards and established policy to all authorized purchasers within the Organization. View of Responsible Official and Corrective Action Management accepts the finding and is taking the following corrective action to prevent recurrence: ? Updating Organizational Policies to clearly permit a higher small purchases threshold, combined with annual certification of eligibility, to sharply decrease the likelihood of recurrence of the underlying cause of the finding. ? Implementing accounting system-level controls that will require an additional approval from assigned fiscal staff to transactions exceeding the small purchase threshold prior to payment, ensuring accountability for monitoring of required documentation for procurements in excess of the threshold. ? Procurement training planned throughout the agency to ensure that personnel authorized to initiate procurement transactions are aware of organizational policies and have the guidance necessary to comply with procurement rules.

SINGLE AUDIT FINDINGS: Finding 2022-002: Procurement and Suspension and Debarment Description of Finding: The Town?s procurement standards included an incorrect threshold for small purchases as outlined in 2 CFR sections 200.318 through 200.326 ($25,000 versus $10,000). Statement of Concurrence or Nonconcurrence: There is no disagreement with the audit finding. Corrective Action: The Town will review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Name of Contact Person: Susan E. Hale, Municipal Finance Officer Projected Completion Date: June 30, 2023

Finding Number: 2022-005 Condition: The Corporation's procurement procedures does not fully conform to the procurement standards identified in ?? 200.317 through 200.327. Planned Corrective Action: The procurement policies will be revised and additional education will be conducted for those individuals responsible for the procurement process. Contact person responsible for corrective action: Kristen St. Peter Anticipated Completion Date: June 2023 Management Response: Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.

Higher Education Emergency Relief Fund ? Assistance Listing No.: 84.425F Recommendation: We recommend that the University establish a process where when the SAM.gov check is performed, evidence is retained to show that this was completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The procurement policy for Federal Grants will be revised to include the process of how to have a SAM.gov check performed and documented for evidence, as well as include procedures for the procurement of goods over $250,000. At this time, with the HEERF grant completely spent, there are no other Federal grants in place where the SAM.gov check would be required. However, the revised policy will be communicated to department managers for future federal grant awards. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: June 1, 2023

U.S. DEPARTMENT OF TREASURY 2022-001 Coronavirus State and Local Fiscal Recovery Funds- ALN No. 21.027 Recommendation: We recommend the Town design and document a procurement policy in accordance with the compliance requirements outlined in Title 2 of the U.S. Code of Federal Regulations part 200.318. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We agree with the auditor?s findings. Management will design a formal procurement policy. Name(s) of the contact person(s) responsible for corrective action: Sue Nickerson, Town Accountant. Planned completion date for corrective action plan: Immediately.

Finding Reference Number; 2022-002 Federal Agency:Department of Agriculture (USDA) Description of Findi ng: Criteria: : 2 CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal Jaws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additional ly, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or inel igible for partici pation in Federal assistance programs or activities. Condition: During audit testing performed by Mengel, Metzger, Barr & Co, LLP, they noted the following: - The contractors util ized by the Food Bank in 2022 were not properly checked for compl iance requirements regarding debarment. They did not have a control in place to ensure the contractors used for their covered transactions were not made with a debarred or suspended party . Statement of Concurrence or Nonconcurrence: The Food Bank agrees with this findi ng. Corrective Action : The Food Bank has implemented procedures to ensure all contracted vendors are vetted to ensure they are not on the federal exclusion list. All contractors used in 2022 have been checked and are not on the list. Name of Contact Person: Renee Law, Chief Financial Officer; phone number 518-786-3691 ext 226; email ReneeL@Regionalfoodbank.net. Projected Completion Date: May 31, 2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Christy Nale Contact Phone Number: 765-492-5411 View of Responsible Official: Procurement request for milk and dairy was requested from the West Central Educational Service Center. After not receiving the bid request in a timely manner, the procurement bid was received from the Wilson Education Center. The North Vermillion Community School Corporation was unaware that the Wilson Education Center was not IDOE approved in 2021. The IDOE approved cooperative list was not made available to our corporation, and not easily accessible on the IDOE School Nutrition link. Description of Corrective Action Plan: The corrective action has been made as the Wilson Education Center was approved as a Cooperative Procurement site in 2022 by the IDOE. Anticipated Completion Date: No anticipated date, the Corrective Action has already been completed.

Finding 2022-003 Contact Person Responsible for Corrective Action: Rhonda Morgan, FSD Contact Phone Number: 765-240-2386 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement: Frontier School Corporation will have the Food Service Director prepare contacts to all possible food & drink vendors asking for Vendor Bids for the following school year. Any email correspondence will be CC?d to the Corporation Treasurer and Superintendent when contacting the Vendors. A phone call log will also be kept by the Food Service Director. After receiving Vendor Bids, all Vendor Bids or Vendor Declining to Bid will be presented to the School Board for their approval. The Food Service Director will also give a recommendation at that time on who they would like to award the Vendor Bid to. After the School Board vote on Vendor Bid Awards, e-mail correspondence will be sent to all vendors with Corporation Secretary and Superintendent CC?d. All email data, phone logs, and School Board notes will be filed in the Food Service Director?s office. This internal control system will ensure compliance with the state Procurement agreements and requirements. Anticipated Completion Date: The CAP will be in place by March 24, 2023 in preparation for the Vendor Bids for the School Year 2023-2024 to be prepared and sent out in April 2023. Suspension and Debarment: Frontier School Corporation Food Service Director will check SAM Exclusions, collect a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. This information would then be kept in the Vendor?s file. Anticipated Completion Date: The CAP will be in place by March 17, 2023 in preparation for the Vendor Bids for the School Year 2023-2024 to be prepared and sent out in April 2023. The Food Service Director will have current vendors checked on SAM Exclusion or have a certification from that vendor, or adding a clause or condition to the covered transactions with the current vendors by March, 17, 2023.

Finding: 2022-001 Department of Education Federal Program(s): Education Stabilization Fund- AL No. 84.425F and 84.425M Type: Significant deficiency in controls over compliance Compliance Requirement: Procurement Recommendation: We recommend the College implement a procurement policy with the requirements identified in 2 CFR Section 200.318 through 200.327. Explanation of any disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is in the process of formalizing the procurement standards noted above within its purchasing policies. Planned completion date for corrective action plan: April 30, 2023 Name(s) of the contact person(s) responsible for corrective action: Holly Higgins, Director for Business Services

U.S. Department of Health and Human Services 2022-002 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Health Center update the procurement and conflict of interest policies to meet Uniform Guidance requirements, and ensure proper documentation is retained for transactions, particularly in cases where single source procurement is utilized over the micro purchase threshold. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement and Conflict of Interest Policies were recently revised in Oct 2022 and Dec 2022 ahead of HRSA operational site visit to meet Uniform Guidance requirements. Staff have been trained on requirements related to the procurement thresholds and documentation standards. Documentation and discussion of procurement standards will be captured per that policy, with board action and discussion. Name(s) of the contact person(s) responsible for corrective action: Lori Zook, CFO Planned completion date for corrective action plan: 12/20/2022

Finding Number: 2022-03 Anticipated Completion Date: 10/31/2022 Responsible Contact Person: Laurence Emrie Planned Corrective Action: In response to PwC?s prior audit finding, the Company completely revised its Vendor Selection Form (for Projects Expending Federal Funds Only), effective as of October 2022, to provide explicit directions on the process to be followed when requests for bids from multiple vendors result in only one responsive bid being received. As such, this issue was remediated in October 2022. In such cases, the procurement must be documented as a noncompetitive procurement in Section 3 of the Vendor Selection Form. As a result, enhanced documentation must be attached to the Vendor Selection Form to justify the use of noncompetitive procurement as a purchase mechanism before the purchase will be approved. Moreover, management oversight of the procurement process has been enhanced by having both the Legal Office and the Accounting/Finance Office review and sign-off on the Vendor Selection Form and supporting documentation prior to purchase authorization for goods or services above the micro-purchase threshold being approved.

2022-002 ? COVID-19 ? Education Stabilization Fund ? Institutional Portion Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which its plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Planned Action 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. Proposed Completion Date: The School will review processes to ensure we are in compliance by March 15, 2023.

Price or rate quotes will be obtained from three different sources when required by the Uniform Guidance. Doris Guzman will monitor budget projections to determine which expenses will require implementation of the appropriate level of procurement procedures that must be followed. Additionally, Hispanic Federation?s program managers will be trained on how to execute the Hispanic Federation Procurement Policy. Finally, Hispanic Federation?s new Compliance Department will review contracts to determine compliance needs.

Federal Procurement Requirements for Higher Education Stabilization Fund Planned Corrective Action: A policy addressing procurement standards has been created and will be implemented for future expenditures Person Responsible for Corrective Action Plan: Cindy L Weaver, Interim CFO/Director of Finance Anticipated Date of Completion: July 25, 2023

CORRECTIVE ACTION PLAN July 21, 2023 We have prepared the following corrective action plan as required by the standards applicable to financial audits contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Specifically, for each finding we are providing you with the names of the contact people responsible for corrective action, the corrective action planned, and the anticipated completion date. 2022-101: Procurement and Record Retention Recommendation: The Organization should maintain proper documentation to help ensure that all the required documentation is retained in order to confirm its compliance with federal procurement requirements. Action Taken: Early in 2023, the organization revised our grant process to ensure proper documentation and retention during the grant award period. A new grant closeout process and grant closeout checklist was developed to ensure compliance with all documentation and retention requirements. Contact Person: Laura Rood, Sr. Procurement Manager Completion Date: June 2023

Finding: 2022-01 The College, under the direction of the Vice President of Business and Finance, is in the process of revising the existing Procurement Policy to include the required federal procurement standards set out in 2 CFR sections 200.318 through 200.326. It is anticipated that the new policy will be in place by June 30, 2023. While the requirements have not been stated in the current policy, the College believes that it is following the prescribed requirements in practice. The College understands the importance of following the guidelines and providing clear expectations in the policy. Person responsible: Lynn Miskus, Vice President for Business and Finance. Contact Information: LMISKUS@CCSJ.EDU; 1-219-473-4310

FINDING 2022-001 Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number: (812) 438-2655 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will maintain communication with the Wilson Education Center to ensure that they comply with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. In the event that the Wilson Education Center does not comply with the above requirement, the school corporation will look at the federal website to ensure that all vendors are on the approved list. If the Wilson Education Center fails to meet the above criteria, the school corporation would advertise to solicit bids for milk and bread. Anticipated Completion Date: January 13, 2023

Finding # 2022-002 Immaterial noncompliance over procurement U.S. Department of Agriculture ? Rural Development 10.755 Rural Innovation Stronger Economy U.S. Department of the Treasury 21.027 Coronavirus State and Local Fiscal Recovery Funds Finding: The Organization should follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 including documentation to justify when a competitive process was not used. The Organization?s procurement policies also should be expanded to incorporate the provisions of the standards referenced. Recommendation: The Organization's procurement policy must have documented procurement procedures, consistent with state, local, and tribal laws and regulations for the acquisition of property or services required under a federal award or subaward. The Organization should maintain records sufficient to detail the history of procurement. Corrective Action: Spruce Root will review the federal procurement guidelines and update its policies and procedures to be consistent with federal requirements. Anticipated Completion Date December 31, 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Judy Brooks, Food Service Coordinator Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Coordinator will follow our procurement procedures for all purchases. Food Service Coordinator will document that vendors for the BID are not suspended or debarred from participation in federal programs before purchasing also vendors used through the Wilson Center. The Deputy Treasurer will verify procurement and suspension and debarment documentation is on file before payment is made. When we are checking the vendors on the sams.gov website and there are no results founds then we will also request the vendor to submit a suspended and debarred form. Anticipated Completion Date: 2/13/2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tammy Breedlove, Food Service Director Contact Phone Number: 765-569-4308 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The following internal control process has been added to the Business Office Handbook Effective February 1, 2023. It is the responsibility of the Food Service Director to ensure compliance and comply with the grant agreement and the Procurement and Debarment compliance requirements. Each School year, the Food Service Director & Superintendent will present the West Central IN ESC Food Service Bids & any Food Service Small Purchase quotes to the School Board for review and approval. Audit Evidence will be the Board packets and Board Minutes. Food Service Small Purchases- The Food Service Director will obtain quotes directly from the vendors or use the vendor?s website/catalog to compare products and prices. The Food Service Director attends WCIESC procurement meetings to get the most up-to-date pricing information. It is the responsibility of the Food Service Director to keep all documentation. The Food Service Director will present the documentation to the Business Manager for review. Small Purchase Vendors will be approved by the School board each School Year. Audit Evidence will be the quote documentation as well as the Board packets and Board Minutes. Anticipated Completion Date: March 15, 2023

FINDING 2022-006 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd VanDerWeele Contact Phone Number: 574.223.2159 Views of Responsible Official: We concur with the finding. The Special Education Director will obtain pricing when cumulative costs are projected to exceed the micro purchase threshold an adequate number of qualified sources. The Special Education Director will document and communicate the results of this process with the Business Manager and Superintendent. Anticipated Completion Date: July 31, 2023

To Whom It May Concern: This is in answer to finding 2022-001 for the Carver, Florek & James CPA's Auditors for the findings in Park County's 2022 Audit. Page 53 - Responses for Finding 2022-001 Written Debarred, Suspended Vendors & Federal Standards of Conflict of Interest A second user (accounts payable) was set up in November 2022 to search for entities that we pay with federal dollars to make sure they are in good standing with Sam.Gov before paying any dollars to those entities. The County will investigate seeking out training with Government Finance Officers Association (GFOA) to see what is available that would help with grant administration by February 2023. The County will add some wording to the Procurement Policy to make sure all departments that use grants will know the procedures regarding debarred or suspended vendors with a completion date of February 2023. The County Clerk, Colleen Renner, will be responsible for ensuring these actions are initiated and completed. Colleen Renner Park County Clerk

FINDING 2022-001 Information on the federal program: Subject: Special Education Cluster (IDEA) - Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027, 84.173 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency, Other Matters Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Context: During testing of procurement over the Special Education Cluster, it was noted that the School Corporation did obtain an appropriate number of bids relating to Special Education consultants as required under small purchase procurement guidelines. There were two consultants charged to the Special Education Cluster during the audit period with expenses totaling $147,319. One of these consultants was selected during testing for procurement. The issue impacted both ALN 84.027 and 84.173. No issues were identified when testing suspension and debarment requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Due to the number of students we service with special needs, we often need to contract out for some of our Speech Language Pathology services. We currently have three contractors that provide outstanding services for us and we haven?t annually bid this out since the pool of providers is very small. In the future, we will document the process that we take to try to fill these spots with full time employees, how we request various pathologists from a multitude of vendors, and the decision making process to choose the contractor. We will review the rates provided by other potential contractors and seek School Board approval for whomever is the contracted vendor. Responsible party and timeline for completion: Our Director of Student Services, Rebecca Gromala, will oversee this corrective action plan. It is too late to make this correction for the current 2022-2023 school year. We anticipate this being corrected by September 1, 2023 for the 2023-2024 school year.

The management team agrees with the auditor?s recommendation and has already implemented controls to address the stated concerns. Due to the public health emergency related to COVID-19, management elected to use the exception under 2 CFR 200.320(c)(3) due to the public exigency or emergency. However, management understands that the related compliance requirements have since been updated and we have adopted procedures to review any updates to compliance requirements prior to executing contracts with federal awards. Additionally, the Grants division has attended multiple trainings since the occurrence pertaining to SLFRF compliance requirements. The Grants Director also subscribes to several listserv notices to keep current on any changes in guidance. The Grants Director is responsible for the corrective action as it relates to this finding.

FINDING 2022-001 Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: United States Department of the Treasury Passed-through: N/A Compliance Requirements: Procurement, Suspension and Debarment Auditor Recommendation: We recommend the City modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. Views of Management/Responsible Officials and Corrective Action: The City concurs with the auditor?s recommendation and will modify and strengthen its policies and procedures to ensure that the required Uniform Guidance standards are addressed. The City has never had a finding in its Single Audit before and was not aware that the procurement standards identified in Title 2 of the Code of Federal Regulations (CFR), specifically 2 CFR sections 200.317 through 200.326, had to be included in the City?s procurement policy. Being that this was the first time the City received the ARPA funding and was subject to this requirement, this deficiency came up. The City will review and bring its current policy up to date. The City also made an effort to comply when a deficiency was known. In August 2022, the City established its Debarment and Suspension policy. With this policy in place, the City will review its current process to ensure that going forward, verifications for debarment and suspension are performed for contractors prior to entering into transactions with them. Name of Responsible Person: Kim Sao, Finance Director Implementation Date: 6/30/2023