Corrective Action Plans

The County?s Procurement Policy is being updated to include a Federal Procurement Checklist to be used for purchases using Federal funds.

Department of Health and Human Services FINDING ? FEDERAL AWARD PROGRAMS AUDITS 2022-002 Policies and Procedures Material Weakness Recommendation: The Organization should adopt a formal written procurement policy in the format and with the elements required by 2 CFR Sections 200.318 to 200.326. Action Taken: The Organization adopted a ?Fiscal Policies and Procedures Manual? on October 1, 2022.

Contact Person ? Maureen Storstad ? Finance Director Corrective Action Plan ? The City is in the process of updating its procurement policy to include verbiage related to the suspension and debarment requirement. Completion Date - Immediately

Contact Name: Barbara Staggs, CFO Contact Phone Number: 870-863-8194 Audit Period Ending: June 30, 2022 Audit Firm: FORVIS, LLP Federal Program: Child and Adult Food Care Program, Assistance Listing No. 10.558 Federal Agency: U.S. Department of Health and Human Services Starting in August 2023, SADCCF will notify potential bidders of the opportunity to bid on the USDA meal program by radio announcement.

Material Noncompliance Material Weakness in Internal Control over Compliance 2022-002 Procurement and Suspension and Debarment Recommendation: Recommend the Town review its formal procurement policies and revise with the criteria in 2 CFR sections 200.318 and 200.326. Action taken in response to finding: 1. Review and update existing Purchasing Guidelines to conform with Uniform Guidance. 2. Revise procedures for adding new vendors, implement a check for Suspension and Debarment. 3. Recommend to Board of Selectmen a revised Procurement Policy. 4. After acceptance and approval of revised procurement policy provide training to staff on new policies and procedures surrounding procurement. Name(s) of the contact person(s) responsible for corrective action: Mandi Moore, Finance Director Planned completion date for corrective action plan: 6/30/23 If anyone has questions regarding this plan, please call Mandi Moore at 860.627.1449 option 4

FINDING NUMBER: 2022-002 Condition: The Organization is either lacking or has non-conforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial Management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 5. Competition ? 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Planned Corrective Action: Management agrees with the finding and plans to review Uniform Guidance, modify and create policies and procedures where necessary to meet administrative Uniform Guidance requirements. The adopted policies and procedures will be reviewed and approved by the School Board of Directors at the organization?s next scheduled Board meeting. School Representative Responsible for Corrective Action: Carlos Perez, Executive Director Anticipated Completion Date: June 14, 2023

2022-005 - Finding Condition We noted during testing procurement, suspension, and debarment that the County doesn't have a procurement policy that follows Uniform Guidance. We also noted during testing for suspension and debarment that 3 of our 4 vendors tested were not reviewed to ensure they were not suspended or disbarred from federal funds. Corrective Action Plan per Debbie Nelson, Auditor We agree. A procurement policy is being drafted for approval by the Grand Forks County Commission. Anticipated Completion Date Fiscal Year 2023

2022-002 ?Procurement Procedures Corrective action plan: Program directors and other employees involved with procurement will be retrained on the procurement policy. A sole source justification form will be created in conjunction with the procurement policy update that is currently in process. The Tribal Programs Administrator and Chief Financial Officer will be more diligent in ensuring program directors follow the procurement policy. Personnel responsible for corrective action: Tribal Programs Administrator (Herman Sanchez) and Chief Financial Officer (Sharon Ulibarri) Estimated corrective action completion date: September 30, 2023

View of Responsible Officials and Planned Corrective Action: EC3 agrees with the recommendation of its auditor, Maher Duessel, that the EC3 Finance Department must ensure that EC3 follows the approved and compliant purchasing practices. However, in the beginning, the College was still in a start-up mode and most of its essential purchases from Vendors could not meet EC3?s aggressive timetable to get the College up and running. So being practical, the College needed to act fast to get its provisions in place to get the College up and running, and although this was an informal process, the Management team diligently reviewed, justified, and approved all the purchases based on the supporting documentation. As of August 2022, the Finance Department has recognized the lack of internal control over the financial purchasing process and has informally enforced the purchasing policy. The Finance Department will be reviewing all EC3 financial policies, including its purchasing policy and will be making recommendations to the EC3?s Cabinet and Board of Trustees. The Finance Department will and must enforce the purchasing policy, once approved, update the policy online and ensure the policy is followed by EC3 staff and its compliant with the Commonwealth of Pennsylvania Policies.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Amy Copeland Contact Phone Number: (812) 689-6311 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Ripley County Auditor, Amy Copeland, has already been in contact with the Auditors in the State of Indiana to help with a Procurement Policy they already have in place. This is so the Ripley County Attorney and I can work on getting Ripley County a Procurement Policy in place as soon as possible. Ripley County will also be writing a Suspension and Debarment Policy for any checks written over $25,000.00 to any subrecipient or contracts. The new polices will address procedures for procurement and suspension and debarment to ensure there is a review and approval process in place to ensure compliance. Anticipated Completion Date: 8/30/2023

FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.4250 - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) S45U210012 (Year: 2021) Questioned Costs: $116,610 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 concur with the auditor?s reasoning that the contract terms for services should have been modified to reflect the one-time retention payments for contracted custodial personnel. Retention of contracted custodial staff members was deemed by the District to be an essential part of its effort to ensure clean, sanitary facilities in response to COVID-19 pandemic. ? The District has several internal controls in place to determine and verify the allowability of ESSER expenditures, which include: ? Authorization by the Hall County Board of Education. ? Authorization by the Georgia Department of Education through the ESSER program?s consolidated application. ? Approval of all ESSER payments and purchase orders by relevant personnel familiar with the allowability requirements of the ESSER program. ? Approval of all ESSER contract agreements by relevant personnel familiar with the allowability requirement of the ESER program. ? Documented protocols for determining District personnel eligible to be paid through ESSER funds. The District will conduct a review of its contract with third party service providers to ensure compliance with Uniform Grant Guidance. The District currently has no further plans for the provision of additional retention payments to contracted personnel using ESSER funds, and no additional corrective action is anticipated to be required for the isolated instance. Estimated Completion Date: March 31, 2023 Contact Person: Jonathan C. Boykin Telephone: 770-534-1080 Email: jonathan.boykin@hallco.org

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2022 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2022-001 Procurement Description of Finding The City is required to utilize a sealed bidding process for expenditures in excess of the $250,000 threshold per Uniform Guidance. As a result of our testing, we noted two vendors with expenditures in excess of the threshold which did not utilize the sealed bidding process. Statement of Concurrence or Nonconcurrence Management agrees with this finding. Corrective Action Corrective action will be taken to ensure the correct procurement procedures are followed. Name of Contact Person Lynn Boisvert, Director of Finance and Operations Projected Completion Date June 30, 2023

Finding Number: 2022-007 Finding : Premium Pay Corrective Action Taken or To Be Taken: Recommend the City create internal controls to ensure that they review federal and state regulations prior to disbursements to ensure costs are allowable. We also recommend the City work with elected officials to create a corrective action plan to recoup the federal funds. Agency Response: Does agency agree with finding? If no or partially, please explain reason(s) why? Initially premium payments were only made to paid staff. Management was unaware of the provisions in reference to elected officials not being able to receive premium pay so they requested premium pay for the elected officials at a later date. The City Manager has sent an email to all elected officials requesting that the funds be reimbursed to the City. At this time (4) four of the (6) six elected officials have reimbursed the City and the others have committed to do so as well. Additional Comments:

2022-001 PROCUREMENT Federal Assistance Listing Number: Higher Education Emergency Relief Fund (HEERF) 84.425F Criteria A non-Federal entity must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. The College must use its own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Observation/Condition/Context The College did not follow its procurement policy in one identified instance out of six tested. It was noted that the College did not solicit competitive price quotations for a purchase exceeding policy thresholds under the HEERF program. Questioned Cost There were no questioned costs associated with this finding. Cause/Effect Following the established procurement policy allows for cost comparison and the ability to evaluate whether a vendor is reputable and if the contract has all the required provisions. By not following the policy, the College opens itself up to higher costs and riskier transactions. Recommendation We recommend that the College implement a review process to identify potential instances of noncompliance with the College?s procurement policy. Planned Corrective Action ? The Business Office and Purchasing teams will amend our current procurement policy to reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. ? The Business Office and Purchasing teams will work with the college?s internal Administrative Information Systems staff to implement an additional review step in the Workday requisition process for the following qualified purchasing thresholds: o Micro-purchases under $10,000 would suggest sought out competitive vendors o Small purchases over $10,000 and less than $250,000 would require quotes o Formal procurement methods for purchases over $250,000 would require sealed bids Implementation Date Beginning July 1, 2023 Responsible Personnel Jacquelyn Craddock, Purchasing Manager Contact Information Email: jcraddock@cca.edu

Condition: In 2 of 4 sample selections of vendor purchases, the City was not able to provide evidence of properly following the procurement policy for federal awards. In 1 of the 2 failed instances, the City inappropriately designated a vendor as sole source. In 1 of the 2 failed instances, the City was unable to produce documentation for the simplified acquisition threshold related to small purchases to show procurement by sealed bids and competitive proposals. Cause: Failure to follow Federal procurement regulations. Effect: Procurement support was unavailable to demonstrate the procurement policy was followed for a vendor and an inappropriate use of sole source designation for a vendor. Recommendation: We recommend the City adhere to Federal procurement policies for federal awards to ensure proper procurement standards are followed and adhere to allowable sole source designations.

2022-001 Procurement, Suspension, and Debarment In accordance with2022-001 Procurement, Suspension, and Debarment In accordance with 2 CFR 200.318, management will adopt documented procurement procedures that reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards in 2 CFR 200.318 through 200.326. The Board adopted a procurement policy on January 12, 2023. 2 CFR 200.318, management will adopt documented procurement procedures that reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards in 2 CFR 200.318 through 200.326. The Board adopted a procurement policy on January 12, 2023.

2022-002 Procurement United States Department of Education? ALN 84.425F Education Stabilization Fund - Institutional Portion Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Law School could not provide sufficient documented rationales for sole source awards for 2 out of 2 vendors selected for testing. Cause: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 was not adopted by the Law School until June 15, 2022. As such, the Law School did not have adequate policy during fiscal 2022. Effect: Sole source awards were not properly documented. Questioned Costs: None Context: See condition above. Recommendation: The Law School should ensure that they have sufficient documentation to support rationale for sole source awards and are in compliance with the federal procurement standards. Corrective Action: Effective June 15, 2022, the procurement policy will be adhered to and purchases will be adequately documented. Responsible Persons: Stephanie Vullo, Chief Compliance Officer, 718-780-0605, stephanie.vullo@brooklaw.edu; Herberth Melendez, Associate General Counsel, 718-780-7952, herberth.melendez@brooklaw.edu

FA2O22-001 Improve/Strengthen 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: 5425D2000L2 (Year: 2020), 5425U2L0072 (Year: 202L) Questioned Costs: $61,000.00 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 concur with this finding. The process used to pay retention pay to staff has been reviewed and will only be a paid to staff employed by the Atkinson County Board of Education. Estimated Completion Date: 3/13/2023 Contact Person: Lessie Youngblood Telephone: 912- 422-7878 Email: lyoungblood@atkinson.k12. ga.us

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action; Brian Tomamichel, Chief Financial Officer Contact Phone Number: 317-867-8013 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Westfield Washington Schools will be hiring a Director of Food Service to oversee our current food service management company. With this hire the district will ensure that this individual is routinely trained on procurement, contract approval, and any other necessary items to ensure that all Federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contract. Anticipated Completion Date: June 2023

2022-001: Procurement Requirements Criteria: The Organization is required to establish a procurement policy in accordance with Uniform Guidance requirements, as specified in the compliance supplement. Condition: The Organization did not establish a procurement policy in accordance with Uniform Guidance 2 CFR 200.318 ? 200.327, as required for the major program. The Organization developed and implemented a policy during 2022 but it was not in effect for the whole organization for the entire year. Questioned costs: None Cause and Effect: By not having an updated procurement policy the Organization could expense funds that are not in accordance with the procurement policies established by Uniform Guidance. Corrective Plan: Midwest Food Bank NFP established a procurement policy in accordance with Uniform Guidance in 2022 to be fully implemented across the Organization with an effective date of January 1, 2023, led by Lisa Martin, CFO.

SEE ATTACHED

The City has identified federal grants subject to the Uniform Guidance and will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.

The City will develop written standards of conduct in that satisfy the requirements of 2 CFR § 200.318(c)(1).

The Grants Finance Department, Purchasing Department along with the Federal Grants Department will review_vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and_Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached._At the initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document_from SAM.GOV verifying eligibility of vendor will be attached to the vendor file.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Grant Transit Authority January 1, 2022 through December 31, 2022 This schedule presents the corrective action planned by the Authority for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The Transit Authority’s internal controls were inadequate for ensuring compliance with federal procurement, suspension and debarment requirements. Name, address, and telephone of Authority contact person: Stephanie Guettinger PO Box 870, Moses Lake, WA 98837 (509) 766-1663 Corrective action the auditee plans to take in response to the finding: Suspension and Debarment – The Grant Transit Authority (GTA) currently and during the audit period has measures in place for searching SAM.gov for all purchases $25,000 and greater when using Federal funds prior to entering a purchase contract. The GTA has now implemented a process of date stamping the printout from Sam.gov when the search results documents are printed. Additionally, the GTA will ensure that the document is saved in their documents on the date ran, to further verify the date the document was obtained. As a third verification, WSDOT now requires agencies to submit the SAM.gov printout in the approval package submitted to them so that they can verify and ensure the search was completed prior to their approving the agency procurement. Procurement – The Grant Transit Authority (GTA) is currently in the process of updating its written procurement policy to conform with Uniform Guidance (2 CFR 200.318-327) for all procurement activities. Included within the updated policy are procedures to follow for each procurement type to ensure all GTA Management and/or staff have written procedures to reference to and follow when conducting the various procurement types. The updating of the procurement policy with included procedures, shall provide guidance and assist in ensuring that the GTA is procuring goods and services in accordance with federal regulations, state law, as well as its own policies and procedures. Anticipated date to complete the corrective action: 4/01/2024. The Suspension and Debarment recommendation is currently being followed by the GTA with the corrective action already implemented. The GTA is diligently working on the procurement policy updates with established procedures and will submit to the Board of Directors for Board approval, prior to April 1, 2024.