Corrective Action Plans

2022-005 Higher Education Emergency Relief Fund (HEERF) ? Procurement, Suspension and Debarment Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement Policy put in place in February 2023. Name(s) of the contact person(s) responsible for corrective action: Vaughn Jordan Planned completion date for corrective action plan: Action already in effect.

2022 ? 006 (Previously 2021-012) Procurement (Significant Deficiency and Noncompliance) Management?s Progress for Repeat Findings: The City plans to review the controls in place to ensure that our federal procurement guidelines are clear on City process and the need for retention of proper supporting documentation. In addition, we will also plan to have the SEFA completed well before the deadline to allow sufficient management review and major programs can be identified earlier in the audit process. The additional time will allow City departments to provide requested audit documentation within the Auditor?s deadlines. Management Response: The City respectfully disagrees with the finding. The two exceptions noted above are, on the contrary, examples of good fiscal management by the City. The statewide price agreement and the cooperative education services contract were both competitive. The uniform grant guidance in to ? 200.318(e) below encourages state and local intergovernmental agreements. To foster greater economy and efficiency, and in accordance with efforts to promote cost-effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements. In addition, the City did compete the temporary employment services. The request for bids awarded contracts in October 2016. Three (3) years, three (3) months into the five (5) year term of the contract, the first COVID case was reported in the United States and the President declared a public health emergency on January 31. New Mexico and the City of Albuquerque soon followed with their declarations. The City made the decision to extend the existing contract with the existing rates. There is nothing in City policy that prevents extension of contracts for a specific length of time. Extending the contract most likely was a cost savings to the City because the rates would most likely would have increased. Auditor?s Response: We were not provided supporting documentation, as identified in management?s response, during our testwork over procurement to apply the necessary procedures to resolve this exception. Timeline and Responsible Position: June 2023 ? Chief Procurement Officer

Lack of Documentation of Procurement Planned Corrective Action: Ongoing training will be provided to help ensure staff complies with procurement rules, timelines, and accurate filing of documentation. Person Responsible for Corrective Action Plan: Ashley Green, VP of Business Administration and CFO Anticipated Date of Completion: Correction action steps are in place now and training is ongoing.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jennifer Farley Contact Phone Number: 765-292-2626 View of Responsible Official: I concur with the finding. COVID -19 Procurement and suspension and debarment: 1. I was unaware of these requirements at the time the money was spent. In the future I will make sure this is done correctly. Anticipated Completion Date: Done

FINDING 2022-003 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over Procurement, Suspension and Debarment. After this review, we will implement a system to ensure that all procurement methods are followed properly and that suspension and debarment checks are completed prior to awarding of contracts. Some measures have already been implemented, such as a procurement pack is being prepared for each procurement that is completed using federal funds. This process started in July 2022. Anticipated Completion Date: We expect this Corrective Action to be implement by the end of April 2023 to allow for a full review of all internal control processes and procedures.

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Amanda Bilbrey, Food Service Assistant Contact Phone Number: 574-831-2188 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Food Service will review bid packets to ensure documentation was provided as proof that the vendors were not suspended or debarred. If such evidence is not provided, the Food Service Director will verify and request appropriate documentation. Anticipated Completion Date: March 24, 2023

Finding No. 2022-002 Compliance Requirement ? Procurement ? Significant Deficiency and Noncompliance Planned Corrective Action The University will ensure that all procurement decisions comply with the Stevens Procurement Policy and are properly documented, including the procurement method used (e.g., competitive bidding or sole source justification). The Director of Procurement will ensure that all Stevens employees responsible for making purchasing decisions at the University are familiar with the Procurement Policy and the need to ensure full compliance even when making purchasing decisions during emergency situations (e.g., COVID pandemic). The Director of Procurement will ensure compliance with the Stevens Procurement Policy. Timing of Completion This corrective action has been implemented in FY23. Responsible for Corrective Action Joseph Cassidy, Associate Vice President for Finance (201) 216-5287 and Brian Seabold, Director of Procurement (201) 216-8722.

Finding Number: 2022-002 Planned Corrective Action: See Below Anticipated Completion Date: 01/05/2023 Responsible Contact Person: Brian Haines, Treasurer 1. The Treasurer will educate all responsible parties (Director of Curriculum, Assistant Superintendent, Accounts Payable, Superintendent) in the District regarding to Federal Procurement requirements. 2. The Treasurer will ensure that all requests follow the Districts Purchasing Procedures, as well as the Federal Procurement Requirements.

Corrective Action Plan - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-001 Improve Controls over 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: $358,390 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: We acknowledge this finding, however the School District relied on the advance, written approval of Georgia Department of Education Federal Programs staff that our request was a proper use of federal funds and that we had all the documentation needed for this cost to be allowable. It was pointed out to us during the audit that the contract with the custodial staff did not have the language needed to cover the bonus to our custodial contract staff in the view of the Department of Audits. The Department took this position even though both parties agreed to these payments, the Board of Education voted to approve this expenditure, the agreement was documented and the Board of Education General Counsel concluded this was permissible under the Contract. In order to accommodate the Department?s concerns, the School District will monitor contracts to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures as well as compliance requirements for the ESSER program. Estimated Completion Date: May 2023 Contact Person: Jennifer Houston Telephone: 770-867-4527 Email: Jennifer.houston@barrow.k12.ga.us

Finding 2022-006 Eligibility Significant Deficiency ? Internal Control over Compliance Other Matters (Noncompliance) Description of Finding The student files were not reviewed separate from preparer to determine eligibility. Statement of Concurrence or NonConcurrence Management agrees with this finding. Corrective Action The Town is in process of developing a formal policy. Name of Contact Person John Wilcox Projected Completion Date June 30, 2023

Finding 2022-005 Reporting Significant Deficiency ? Internal Control over Compliance Other Matters (Noncompliance) Description of Finding The Town's Program Status Reports were not reviewed separate from preparer prior to submission. Statement of Concurrence or NonConcurrence Management agrees with this finding. Corrective Action The Town is in process of developing a formal policy. Name of Contact Person John Wilcox Projected Completion Date June 30, 2023

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.