Corrective Action Plans

The District concurs with the recommendation to adopt a written conflict of interest policy and is in the process of adopting a policy.

Corrective Action Plan: We have taken proactive measures within the Purchasing Department to enhance training and awareness among our staff. Additionally, the Grant division has been reinforcing the importance of adhering to Federal grant guidelines regarding procurement. We will continue to monitor and improve our processes to ensure compliance with established guidelines. Anticipated Completion Date: December 2024

Plan of Action: Provide policy F2.0 Materials Management, F2.01 Vendor Selection & Discount, and F2.03 Inventory and Supplies, which were not provided to the auditor due to the organization’s operational error in financial policy classification. Additionally, the F2.02 Capital and Equipment policy was drafted in 2021 but needs to be signed by the organizational board on May 24, 2024. The organization acknowledges that the procurement policy was not followed for one vendor procurement in 2022 due to an administrative error. Going forward this policy will be strictly followed. Date of implementation: F2 policies was implemented on 6/1/21 and updated on 6/1/2024

Views of Responsible Officials and Planned Corrective Actions: Astraea created a best practice procurement policy in December 2021 that was implemented in February 2022 (i.e. Q3 of FY2022). Prior to December 2021, procurement practices were not standardized across the organization. Since implementation of the current procurement policy, all staff members have been trained on the procurement policy, and the Finance and Operation teams have developed internal processes to ensure that all procurement flows through the organization are documented and in compliance with 2 CFR 200. With the policy in place, we recognize that implementation across teams is critical and are actively training people managers to improve oversight and improve implementation. Anticipated Completion Date: January 31, 2024 Responsible Official: Associate Director, Grants Management and Compliance; Director of Program Operations

US Department of the Treasury - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Recommendation: We recommend that the City establish procedures to ensure that their purchasing policy follows Uniform Guidance procurement standards. Action Taken: The City does follow Uniform Guidance procurement standards. In this instance, a vendor was selected under an emergency contract basis utilizing our waiver of bids policy. The entire country was awarded ARPA funds with water and sewer lining replacement being an allowable use of these funds. Due to the fact that there are a very limited number of vendors who provide this service, and the fact that there would be a significant number of municipalities seeking this service with the influx of ARPA dollars, as well as the fact that due to supply and demand, the cost for these services were escalating rapidly, the City wanted to be one of the first to engage with a contractor in order to secure a vendor in a timely manner before we would be unable to do so since the projects are long term projects and there was a time limit on when this money would need to be spent. Therefore, we knew it would not be possible to conduct our own bid. We choose a vendor off the COSTARS contract. I have attached a copy of the ordinance where we explained to Council our concern for our securing a vendor and our need to act quickly, which is why we originally initiated the purchase from City funds, before ARPA funds were distributed, and then replaced the City funds with ARPA funds once they were received.

Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation. Corrective Action Plan: The City will continue to address this finding through updating of policies and procedures for City-wide use. Update: in November 2023 the City updated the policies and procedures manual that was accepted by the DOJ in December 2023. Planned Implementation Date: June 30, 2024 Responsible Person: Finance Department

Action Taken: The Organization is generally identified and approached by Federal agencies, or prime contractors having or considering federal agencies, to utilize grant funding for NFFCMH contracts. The Organization works with trusted partners, each having a unique or specialized forte within the grant requirements, to assemble a joint team of providers. Many of these partners are, due to repeated utilization and unique recognition within their field, uniquely qualified, or the true only option, for their areas of expertise. The Organization has revised the procurement policy to comply with Uniform Guidance, as opposed to the Federal Acquisition Regulations.

a. Name of Contact Person Responsible for Corrective Action: Christy Harbin, City Clerk, and Ken Sunseri, Mayor. Phone Number: (205) 486-3121 b. Corrective Action Planned: The City of Haleyville will maintain a written policy for conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. c. Anticipated Completion Date: Immediately

Planned Corrective Action: Team Rubicon will institute policies and procedures to ensure compliance with applicable procurement guidelines when accepting federal awards. These will include prohibition against contracts which could be influenced by a perceived or actual conflict of interest, documentation of a search for suspended and debarred parties, and guidelines for approved methods of procurement (including specific situations where noncompetitive procurement may be appropriate, and documentation to be required if so).

2022-005 a. Name of Contact Person Responsible for Corrective Action: Jeff Burks, General Manager, and Cynthia Fowler, Office Manager & Comptroller Phone Number: (256) 356-8622 b. Corrective Action Planned: The Water Works and Gas Board of the City of Red Bay will maintain a written policy for conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. c. Anticipated Completion Date: Immediately

Correction Action Plan (Concerning Finding 2022-002) (Procurement, Suspension & Debarment): Contact Person Responsible for Corrective Action: Beverly White, Chairman of the Selectboard. Corrective Action: The Town of Brownington will take the following actions to address finding 2022-002. The Town of Brownington has added the changes that Kimberly Wall and Cathy Markavich suggested in their email dated March 26, 2024, to the Procurement Policy to have it meet FEMA guidelines. The Town of Brownington has drafted our policy to include the changes and this was adopted at the April 10, 2024 Selectboard Meeting. Anticipated Completion Date: April 30, 2024.

The County will develop written policies and procedures for procurement, including the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions. Management will evaluate the need to contract with local government consultants to perform control procedures where County personnel are not available or qualified to perform.

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

Contact Person – Pattie Solberg, City Auditor; Corrective Action Plan – The City will implement a written procurement policy that follows Uniform Guidance and will review vendors for suspension and debarment before entering into covered transactions. Completion Date – April 30, 2024

Material Weakness in Internal Control over Compliance Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review potential contractors to determine they arenot suspended or debarred. These procedures should include documenting the date that suspension and debarment verifications are made. In addition, we recommend The Organization formally adopt a Procurement, Suspension and Debarment policy in accordance with Uniform Guidance. There is no disagreement with the audit finding. Action taken in response to finding: Since Fall/Winter 2023, we have reviewed the Organization’s controls for procurement, suspension, and debarment, including the process for reviewing potential contractors for suspension and debarment. We have expanded our controls and increased training to improve control strength, and we have formally adopted a Procurement, Suspension and Debarment policy in accordance with Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 04/01/2024

Action Taken: Range Mental Health Center, Inc. and Subsidiaries will adopt a documented procurement policy consistent with the standards of 2 CRF section 200.317 through 200.320 to use procurement of the acquisition of property or service required under federal awards or sub-awards.

Finding 2022-003 Procurement The auditors recommended the following: 4. Management adhere to its written policy and maintain documentation to support all management decisions related to federally funded procurements to comply with federal regulations. SDA should consider creating a checklist form to document its procurement decisions and related approvals, as required. Also, we recommend SDA develop procedures to identify federally funded contracts let/awarded during the fiscal year. Context Two contracts were identified that required documentation to validate that the entire RFQ process from RFQ formulation to advertisement to receipt and evaluation were completed. One of the said contracts could not provide the backup documentation to validate that the evaluation process had been completed. There was no evidence that debarment/suspension verification checks were performed prior to awarding the contract. Staffing Corrective Actions In September 2023, SDA hired a permanent Director of Business Growth Services with experience in federal grant funding. In November 2023, SDA hired a permanent Director of Finance and Administration for additional support in management and oversight. Both Directors are responsible for overseeing procurement processes and reviewing documentation of the process. Process Corrective Actions The SDA has created a checklist and training materials on procurement processes and decisions. Mandatory training sessions for Program Directors and other appropriate staff will be held to ensure that the guidelines are understood. All procurement decisions and information will be filed in the password protected e-filing system. Policy Corrective Actions The SDA maintains active written policies on procurement that adhere to federal guidelines. In June of 2023, the SDA board approved an enhancement of the SDA Fiscal Policy to make the procurement policy more accessible to all members of the organization. The Director of Finance and Administration will continue to conduct periodic quality compliance checks to ensure that all procurement follows SDA policy. All procurement decisions and information will be filed in the e-filing system, Google Drive.

Management concurs with this finding. Management is reviewing and revising its procurement policies to comply with state and local laws, the standards of the CFR, as well as reflect current operating procedures.

Coronavirus State and Local Fiscal Recovery Funds- Assistance Listing No. 21.027 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followeed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures will help ensure compliance ith Compilance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: there is no disagreement with the audit finding. Action taken in response to finding: The Organization will develop a written procurement policy and will develop controls to monitor when expenses approach the various procurement thresholds to help us complete the appropriate procurement procedures in compliance with out policy. Name(s) of the contact person(s) responsible for corrective action: Frank Caruso, Director of Finance and Operations. Planned completion date for corrective action plan: Sarted in January 2024. If the the U.S. Department of the Treasury has questions regarding this plan, please call Frank Caruso, Director of Finance and Operations at (602) 241-4645.

Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Federal Agency Name: Department of Treasury Pass‐Through Entity: North Dakota Office of Management and Budget Assistance Listing Number: 21.027 Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Finding Summary: In the testing of procurement, suspension, and debarment it was identified that the City did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Corrective Action Plan: The City has adopted a procurement policy satisfying the requirements of 2 CFR sections 200.318 through 200.326 as of January 8, 2024. Responsible Individuals: Dustin Scott, City Administrator Anticipated Completion Date: January 8, 2024

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirements: 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 Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2022) Questioned Costs: $21,440.00 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Corrective Action Plan: The Harris County SNP will review internal controls and apply correct procedures to all purchases made. Estimated Completion Date: June 30, 2024 Contact Person: Meghan L. Ceja Telephone: 706-628-4206 Email: ceja-m@harris.k12.ga.us

2022-009: Significant Deficiency and Noncompliance – Procurement Documentation Statement of Condition/Criteria: Delta County is not following its procurement policy and is therefore not meeting the requirements of 2 CFR section 200.318 to use documented procurement procedures. The County does not have controls in place to ensure that written records are maintained sufficient to detail the history of procurement including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Planned Corrective Action: County management will develop control to ensure the procurement policy is followed. Contact person responsible for corrective action: Ashleigh Young, County Controller/Administrator Anticipated Completion Date: March 2024

FA 2022-002 Strengthen Controls over Procurement Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Numbers: 225GA324N1199 (Year: 2022) Questioned Costs: None Identified Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement procedures were followed. Corrective Action Plans: The Hancock County School District has implemented the bid process to ensure that the School District’s procurement procedures are followed. Estimated Completion Date: June 30, 2024 Contact Person: Matthias Jones, Finance Director Telephone: (706) 444-5775 Ext. 125 Email: mjones@hancock.k12.ga.us

Type of Finding: Material Weakness in Internal Control over Compliance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.243 Federal Award Identification Number and Year: H79TI081935 – 2022, H79TI080298 – 2022, H79TI085517 – 2022 Pass-Through Agency: Pierce County Pass-Through Number(s): SC-107323, SC-105454, SC-110121 Award Period: May 31, 2022 through May 30, 2023, September 30, 2017 through September 29, 2022, September 30, 2022 through September 29, 2027. Criteria or specific requirement: 2 CFR 200.320 requires non-federal entities to have and use documented procurement procedures. 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". 2 CFR 180.300 states that before entering into a covered transaction with another person at the next lower tier, an entity must verify that the person with whom they intend to do business with is not excluded or disqualified. This can be done by “(a) Checking SAM exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person”. Condition: The Alliance does not have a written procurement, suspension and debarment policy nor procedures in place at the time of the audit in compliance with Uniform Guidance. For procurement, CLA tested all purchases exceeding $3,500 (the minimum micropurchase threshold before it was increased by the FAR to $10,000 for those with an established policy). For the 5 sampled procurement selections, documentation was not retained for the adequate number of price comparisons prior to exercising the procurement, as required by 2 CFR 200.320. For suspension and debarment, CLA tested all payments to vendors exceeding $25,000 as established by Uniform Guidance. Of the 3 tested, there was no documentary evidence that procedures were performed prior to entering into the covered transaction using the allowable methods as described at 2 CFR 180.300. Questioned costs: Undeterminable. Context: Procurement: A sample of 5 was made from a population of 16 procurement transactions charged to the major program that exceeded $3,500 (the minimum micropurchase threshold before it was increased by the FAR to $10,000 for those with an established policy), amounting to $48,099. Of the 5 sampled costs, all were found to be out of compliance with the Procurement requirements, as a written procurement policy was not in place and documentation was not retained for the adequate number of price comparisons. Suspension and Debarment: A sample of 3 (entire population) was made from a population of 3 vendors who received payments exceeding $25,000. Of the 3 sampled vendors, there was no documentary evidence that procedures were performed prior to entering into the covered transaction using the allowable methods as described at 2 CFR 180.300. Cause: Management believes procurement, suspension and debarment standards apply only to the awarding agency, and not to the Alliance. Effect: Purchases may occur that do not follow the procurement, suspension and debarment standards as required by Uniform Guidance, and contracts to vendors that had been suspended or debarred could be awarded and not detected. Repeat Finding: No. Recommendation: We recommended that the Alliance design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred. These procedures should include documenting the date that suspension and debarment verifications are made. In addition, we recommended the Alliance to formally adopt a Procurement, Suspension and Debarment policy in accordance with Uniform Guidance. The Alliance followed this recommendation, pairing prior (non-federally implicated) procurement processes and expenditures. Views of responsible officials: Pierce County Alliance has enjoyed the a decades long relationship with its prior firm. At no time during that relationship has the need for a Procurement, Suspension and Debarment policy been noted as a deficiency, nor has a finding been issued. Corrective Action: Pierce County Alliance will continue to revise its policies and procedures and controls related to Procurement, Suspension and Debarment, including procedures to review potential contractors for suspension or debarment and to achieve full compliance with the Uniform Guidance.