Corrective Action Plans

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.

2022-006 Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursement funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District has created a sams.gov account to verify any company that is paid with Federal money. Implementation Plan: The Interim Business Administrator will work closely with the new Food Service Director to verify and record any company/vendor that is paid with Federal money. Implementation Date: November 2022. Person Responsible for Implementation: Interim Business Administrator - Brenda Leitt.

Finding 2022-004 Procurement Suspension and Debarment Significant Deficiency ? Internal Control over Compliance Other Matters (Noncompliance) Description of Finding The City?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or NonConcurrence Management agrees with this finding. Corrective Action The City has updated the policy to be in line with Uniform Guidance. Name of Contact Person Robin Stanziale Projected Completion Date January 30, 2023

RE: Finding 2022-001: Internal Control over Compliance The following is the Corrective Action Plan (CAP) related to the noted finding. Corrective Action Plan Agency: Colorado Department of Education Audit Period: FY21-22 Audit Finding Number: 2022-001 Audit Finding Title: Internal Control over Compliance Specific Steps to be Taken: Mountain BOCES currently utilizes a mostly decentralized purchasing system. Improved documentation and trainings relating to procurement policies and procedures as well as increased internal controls were put into place during the second half of 2022 and will continue in 2023. Mountain BOCES has been re-writing these policies to include required language and alignment with 2CFR ?? 200.317 through 200.327, particularly the requirements discussing the allowable procurement methods, dollar thresholds, and the requirements for each allowable method. The procurement policy is undergoing a major rewrite in 2023 by the Executive Director and newly hired Business Manager to ensure sufficient internal controls and overall improved efficiencies. Anticipated Completion Date: Ongoing Name(s) and Title(s) of Contact Person Wendy Wyman Executive Director responsible for Correction Action: If you should have any questions or comments, please do not hesitate to contact me at wwyman@mtnboces.org.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Katie King, Director of Child Nutrition Contact Phone Number: 812-866-6254 Contact Email: kking@swjcs.us Views of Responsible O?cial: We concur with this audit finding. Description of Corrective Action Plan: Action taken in an e?ort to remedy finding 2022-007 includes, but is not limited to, the following: ? Informal procurement methods (small purchase procedures) will be followed for any purchases made by, or on behalf of, the Nutrition Services Department exceeding $10,000.00 up to $150,000.00. Quotes from at least three qualified vendors/contractors will be required. Any purchases made on behalf of the Nutrition Services Department (for example, Maintenance contracting work for kitchen appliance repairs) will need prior approval from the Director of Child Nutrition. ? Wilson Education Center was not an approved co-op for school year, 2020-2021, but was retroactively approved to be a co-op for school year 2021-2022. Therefore, the correction has been made. Anticipated Completion Date: February 1, 2023

While we did not have the wording "not to exceed a specific amount" on the contract in question, we did have a set amount of time to not exceed. This amount of time and the cost per hour was figured into the budget. The budget was reviewed prior to making expenditures and monitored on at least a monthly basis to not exceed the amount budgeted. However, we now realize the need to include such wording. Moving forward, we will amend the current contracts to add a "not to exceed a specific amount" and continue to monitor the budget to not exceed the budget for the 2022-2023 fiscal year. We will also add the wording "not to exceed a specific amount" on all contracts for the 2023-2024 school year.

CRITERIA: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients ?must maintain records 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? 2 CFR section 200.318(i). The Center?s procurement procedures include the requirement to maintain sufficient documentation of the history of procurement. The Center also has procedures to identify procurement transactions requiring competitive bids or proposals. RECOMMENDATION: We recommend the Center ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. CORRECTIVE ACTION PLAN: The Center will review its procurement policies and internal control and ensure timely action is taken when noncompliance is identified. PERSON RESPONSIBLE: Laci Herbst, Finance Department TIMELINE: Current date through succeeding reporting period.

U.S. Department of Housing & Urban Development 2022-002 Continuum of Care ? Assistance Listing No. 14.267 Recommendation: We recommend that polices and procedures are implemented and that appropriate documentation is maintained when entering into transactions with covered entities as defined by 2 CFR section 180.220.Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Agency?s procurement policy will be updated to reflect the current federal guidelines under 2 CFR section 180.220 and 48 CFR 52.209-6 and procedures will be implmented to ensure that all covered transactions over $25,000 do not include venders that have been debarred, suspended, or proposed for debarment. Name(s) of the contact person(s) responsible for corrective action: Chris Willis, CFO Planned completion date for corrective action plan: 12/12/2022

U.S. Department of Housing & Urban Development Cocoon House respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 to June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing & Urban Development 2022-001 Continuum of Care ? Assistance Listing No. 14.267 Recommendation: We recommend the Agency's procurement policy is updated to reflect the current federal guidelines and that policies and procedures are implemented to ensure that the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price is documented as applicable (2 CFR section 200.318(i) and 48 CFR Part 44 and section 52.244-2). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Agency?s procurement policy will be updated to reflect the current federal guidelines and procedures will be implemented to ensure that the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract prices is documented as applicable (2 CFR section 200.318(i) and 48 CFR Part 44 and section 52.244-2). Name(s) of the contact person(s) responsible for corrective action: Chris Willis, CFO Planned completion date for corrective action plan: 12/12/2022

Finding 2022-002 (50000) Program: Child Nutrition Cluster CFDA Number: 10.555, 10.553 Federal Agency: U.S. Department of Agriculture Pass-through: California Department of Education Award Year: 2021-2022 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Significant Deficiency, Instance of Noncompliance Management?s or Department?s Response We concur. View of Responsible Officials and Corrective Action: Name of Responsible Person: Dr. John Pappalardo, Chief Financial Officer Correction Action Plan: We will perform revision of procurement procedures to incorporate the applicable requirements identified in sections 200.318 through 200.327 of the Uniform Guidance. Implementation Date: Fiscal Year 2022-2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Stephanie Haynes- Clifford, Food Service Director Contact Phone Number: 260 665 2854 Extension 1202 Views of Responsible Official: 1. Procurement: The School Corporation did not obtain price or rate quotes for milk, bread, or food exceeding $10,000.00 from an adequate number of sources, as required under the small purchase procedures. 2. Suspension and Debarment: The School Corporation did not verify that vendors with contracts over $25,000.00 were not excluded or disqualified from participation in federal award programs. Description of Corrective Action Plan: 1. Food Service will maintain additional prices for like items and/or services. Documentation will be maintained regarding why each vendor is being utilized. Said documentation will be reviewed, initialed and dated by the Food Service Director and an additional staff member. 2. Food Service will maintain annual vendor certificates to ensure that they were not suspended or debarred from participation in federal programs. Anticipated Completion Date: February 10, 2023

PROCUREMENT, SUSPENSION AND DEBARMENT Federal Agency: U.S. Department of the Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery (SLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2889, 2022 Compliance Requirement Affected: Procurement, Suspension and Debarment Award Period: Year Ended December 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Recommendation: It is recommended the County adhere to its procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will ensure the procurement policy is followed. Name of the contact person responsible for corrective action plan: Jackie Traut, Accounting Supervisor Planned completion date for corrective action plan: December 31, 2023

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

FA 2022-001 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 COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U2120012 (Year: 2021), S425W210011 (Year: 2021) Questioner Costs: 99,748 Prior Year Finding: No 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 work with all entities to confirm that all existing internal controls are adhered to by developing and implementing an improved monitoring process. This process will ensure that all expenditures are compliant with all applicable policies and regulations. Estimated Completion Date: June 30, 2023 Contact Person: Tammy McDonald, Executive Finance Director Telephone: 770-748-3821 Email: tammy@polk.k12.ga.us

FINDING 2022-002 Contact Person Responsible for Corrective Action: Tiffany Deakins Contact Phone Number: 260-248-3176 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Whitley County will make sure that moving forward we will verify there is proper verbiage in contracts over $25,000 stating that the vendor is not suspended or disbarred. Our Attorney has already been made aware of this and will immediately implement this step. Anticipated Completion Date: Immediate

CORRECTIVE ACTION PLAN Finding No. 2022-001 Procurement Federal Program: Crime Victim Assistance Assistance Listing Number: 16.575 In response to the Single Audit Finding referenced in the 2022 independent audit conducted by Donavon CPAs, Prevail will institute the following action steps to remedy the finding: ? The Interim Executive Director of Prevail, working in collaboration with Prevail?s Director of Operations, will generate a first draft of a Procurement Policy for board input and review. ? The draft will be reviewed by the Prevail Finance Committee on April 25, 2023, for input and suggestions. The Interim Executive Director will make edits in response to recommendations by the Finance Committee. ? The Procurement Plan will then be presented for board approval at the Prevail Board of Directors meeting scheduled for May 10, 2023. ? After approval, it will be the responsibility of the Director of Operations, under the oversight of the Interim Executive Director, to implement and maintain compliance with the plan. When a new Executive Director is hired, plan maintenance and compliance will become the responsibility of this role. ? On an annual basis, the Finance Committee will review the Procurement Plan to ensure Prevail maintains compliance.

Information on Federal Programs: U.S. Department of Agriculture Child Nutrition Cluster (COVID-19 National School Lunch Program and COVID-19 School Breakfast Program and Food Distribution, Federal Assistance Listing No. 0.553 and 10.555) passed through the New York State Education Department. Findings and questioned costs related to Federal awards which are required to be reported in accordance with the Uniform Guidance 2 CFR 200.516(a): Criteria: CFR Section 200.318 stipulates that a non -Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws, and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 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 ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of the major program, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Cost: None. Repeat Finding: No Perspective Information: As part of testing of compliance over procurement, a selection of vendors charged to the major program was selected for testing of compliance. Of the District?s vendors charged to the program, none were suspended or debarred from participation in Federal assistance programs and activities. Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District has reviewed the requirements of 2 CFR Section 200.213. The District is in agreement with the recommendation to implement a procedure to document the process used to verify the eligibility of potential vendors to participate in Federal assistance programs. The verification of excluded parties will be accomplished by accessing the System for Award Management (SAM.gov) website and selecting the ?Excluded Entity? filter on the ?Exclusions? search page to search for exclusions by Unique Entity ID or CAGE/NCAGE code as follows: 1) Select ?Search? from the header menu from any page on SAM.gov 2) In the filters, under ?Select Domain?, select ?Entity Information?, then select Exclusions 3) Use the filters or keyword box to enter the search criteria and view the results 4) Document the results in the vendor file. Other alternatives for verification may include collecting a certification from the entity or adding a clause or condition to the covered transaction or contract with that entity. The Purchasing Agent is charged with the responsibility of monitoring and ensuring compliance with the suspension and debarment procedures and maintaining documentation that contracts expected to equal or exceed $25,000 have been verified on the System for Award Management (SAM) website before purchases are made. Responsible Person(s): Kristin Chotkowski, Purchasing Agent Deadline for Completion: On or before 4/1/23 for covered transactions with contracts or purchase orders meeting the threshold during the time period 7/1/22 - 1/31/23. Prior to contract approval or purchase order issuance for contracts or purchase orders meeting the threshold on or after 2/1/23.