Corrective Action Plans

Although sole source and competitive bid information were obtained, they were not located in a centralized location and the written supporting approvals were not maintained. By the end of October 2023, Management will update, enforce, and retrain team members on procurement policies to include competitive bid documentation and record retention requirements. The required supporting documentation will also be housed in a centralized location and Management will perform periodic reviews to ensure it is properly maintained. To further expand training, by the end of October 2023, all key finance and program personnel will also complete Federal Grants Management training offered by the CDC Foundation.

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 - 84.425D - Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020) Questioned Costs: $129,375.00 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: The Whitfield County School District does not concur with the finding; therefore, no corrective action is necessary. Estimated Completion Date: The expense was approved and paid in the fiscal year 2022. Contact Person: Kelly Coon Telephone: 706-217-6704 Email: Kelly.coon@wcsga.net

FINDING 2022-001 Contact Person Responsible for Corrective Action: Brian Leitch, Chief Finance & Operations Officer / Treasurer 260-347-2502 ext.: 10017 Roger Urick, Interim Food Service Director 260-347-2502 ext.: 10011 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Procurement: East Noble School Corporation will attempt to solicit (3) quotes for purchases between $10,000 and $150,000. In the event we are unable to acquire the (3) quotes we will document our attempt and state the reason for which vendor we select. Suspension and Debarment: For any contract in excess of $25,000 we will solicit information from said vendor stating, ?They are not suspended or debarred from receiving Federal Funds?. This will be included in the contract or requested to be with the quote. Anticipated Completion Date: April 2023

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT SIGNIFICANT DEFICIENCY 2022-003: Continuum of Care Program CFDA 14.267 Grant period: Year Ended June 30, 2022 Condition and Context: The Organization does not have a written procurement policy to properly implement all the requirements of 2 CFR Section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Criteria: In accordance with 2 CFR Section 200.319(c), non-federal entities must have written procedures for procurement transactions. Such policy should incorporate all requirements within 2 CFR 200.318 through 200.326 of the Uniform Guidance. Cause: The Organization?s procurement policy does not incorporate all the requirements of 2 CFR Section 200.318 through 200.326 of the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures that are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program compliance requirements. Recommendation: Management should continue to develop comprehensive written policies and procedures to administer all federal programs. Current written policies should be evaluated for inclusion of and compliance with the Uniform Guidance requirements. Grantee Response: Management agrees with the finding and will adopt written policies to comply with Uniform Guidance requirements.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Yelm January 1, 2022 through December 31, 2022 This schedule presents the corrective action planned by the City 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: 2022-002 Finding caption: The City did not have adequate internal controls in place to ensure compliance with federal procurement requirements. Name, address, and telephone of City contact person: Stephanie Nanavich, Finance Director 106 Second St, Yelm, WA 98597 (360) 458-8403 Corrective action the auditee plans to take in response to the finding: The City of Yelm holds its responsibility for enabling internal controls to ensure compliance with federal requirements in the highest regard. Management is committed to ensuring the City has internal controls and procedures in place designed to ensure that it complies with all requirements governing the administration of federal grant programs. The City contracted with a CPA firm in August 2022 to assist with developing a Procurement Policy that ensured compliance with all Federal, State, and Local laws and regulations regarding City Procurement. Together with Finance and Department Director?s input, the policy was refined and adopted by City Council via Resolution #629 on December 13, 2022. The development of this policy was communicated to the auditors in the prior audit. The policy is required to be followed by all departments during the procurement process. Anticipated date to complete the corrective action: 12/13/2022

COVID-19 Coronavirus State and Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: We recommend the City implement controls to ensure its procurement policies and procedures are followed prior to entering into contracts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City acknowledges supply chain issues as a result of COVID-19 which limited purchasing options in one instance. The city will adjust business processes to provide additional review when making purchases to ensure compliance with the procurement policy and proper documentation is included for any exceptions. This will be incorporated immediately. Name of the contact person responsible for corrective action: Tiffany Hooten, Finance Director. Planned completion date for corrective action plan: July 18, 2023

The University reviewed and evaluated our current procurement policy and procedure and identified the deficiency on not clearly defining criteria, missing detailed steps, and ensuring ways to maintain proper documentation. Of the purpose of procurement policy, the University updated the following sections: ? Maximizing the university?s purchasing power by focusing on strategic sourcing and obtaining the best value. ? Leveraging its expertise in contract negotiations and supplier management to advantage the university. ? Streamlining processes and investing in new technologies to provide administrative efficiencies. ? Ensuring that purchases are made in accordance with all applicable university bylaws, laws, regulations, codes and ordinances. The updated procurement policy and procedure thoroughly states under ?Procure-To-Pay Process?, listing competitive bid process by 1. Submit specifications 2. Solicit bids a minimum of three bids 3. Evaluate proposals 4. Negotiate the agreement and make the award. Updated procurement policies and procedures will be properly followed and documented for all general disbursements paid for by federal funds. Person Responsible for Corrective Action Plan: Sheng Wang, Chief Financial Officer Anticipated Date of Completion: June 30, 2023

Procurement Policy: Resolution No. 22-16 Passed and Approved October 4, 2022 A resolution establishing an administration procurement policy to be followed by the governing body of the Town of Lusk.

FINDING 2022-003 Contact Person Responsible for Corrective Action: John Szabo, Director of Business Affairs Contact Phone Number: 812-443-4461 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: When appropriate, the Food Services Director will employ a minimum three vendor rotation for Micro Purchases, and use effective reasoning when applicable. Director of Human Resource will review the use of these vendors on an ongoing basis. For intermediate purchases between $10,000 and $150,000, the Asst. Food Services Director will solicit at least three quotes. Once a vendor is selected, a contract will be executed and signed by the Asst. Food Services Director and the Director of Human Resources or another designated Director. For purchases over $150,000, formal bidding procedures including proper advertising and formal Board of Trustees approval. Once a vendor is selected by the Board of Trustees a contract will be executed and signed by the Asst. Food Services Director and the Director of Human Resources or another designated Director. Anticipated Completion Date: August 1, 2023

Finding 2022-004 ? Significant Deficiency Assistance Listing: 21.027 ? Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Federal Grantor: Department of the Treasury Compliance Requirement: Procurement and Suspension and Debarment Condition: The District used a sole source authorization for the procurement of a Type-1 Fire Engine but a competitive bid process should have been used to comply with Uniform Guidance. Recommendation: We recommend the District work with FEMA to obtain written approval for the sole source procurement, which is one of the exceptions to noncompetitive procurements. Management Response and Corrective Action Plan: The District shall revise policies and procedures to incorporate the requirements in the Uniform Guidance in its sole source approval process when it comes to selecting and approving vendors for expenditures that relates to a federal grant. The District will also work with the awarding agency to ensure written approval are obtained for sole source purchases.

FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-002 U.S. Department of Environment Protection ? Assistance Listing # 66.468 Capitalization Grants for Drinking Water State Revolving Fund (Drinking Water State Revolving Fund Cluster) Lack of Required Written Policies & Procedures ? Compliance Condition & Criteria: The Authority does not currently have all the written policies and procedures in place as required by the Uniform Guidance as it relates to financial management and determining allowability of costs for the federal program (Title 2 U.S. Code of Federal Regulations (CFR) 200.302 & 200.305). In addition CFR sections 200.318, 200.319, and 200.320 require there to be written policies and procedures regarding procurement and conflicts of interest. Planned Corrective Action: This is the Authority?s first time subject to the requirements of the Uniform Guidance as we have not had any significant grant funding since 2004. The Authority does have a set of informal policies and procedures that are followed as it relates to financial management, allowability of costs, procurement, and conflicts of interest, and have been very careful to carry out all federal program activities in accordance with established regulations; however, the Authority was simply not aware of the requirement that these polices and procedures be documented in writing. The Authority will begin immediately to get these policies and procedures as they relate to federal programs documented in writing. The Authority is currently working with their consultants to have the written polices established and plan to have this completed within the next fiscal year. If the U.S. Department of Environmental Protection has questions regarding this plan, please contact: Mr. Kenneth Bost, Authority Chairman Alexandria Borough Water Authority PO Box 336 Alexandria, PA 16611 Phone: 814-669-4441

Finding Number 2022-001 Planned Corrective Action The county administration wholeheartedly agrees that the finance staff should receive government specific accounting training. Finance department personnel will attend Government Finance Officers Association (GFOA) as provided by the Oregon chapter of GFOA. Finance personnel will also attend the annual Caselle user?s conference. Additionally, when GASB specific training is offered, Curry County personnel will attend as workshops become available. Anticipated Completion Date December 31, 2023 Responsible Contact Person Frank Jerome, Finance Director Finding Number 2022-002 Planned Corrective Action Curry County updated its procurement policy January 2023 to conform with procurement standards and establish internal controls. Anticipated Completion Date January 1, 2023. Responsible Contract Person. Anthony Pope, County Counsel.

2022-004: Written Debarred, Suspended Vendors & Federal Standards of Conflict Finding Condition ? The Town of Dayton did not have written controls in place to ensure that vendors were not suspended or debarred or included on the list of vendors prior to entering into a contract with the Town. The written standard of conduct covering conflicts of interest and governing the performance of its employees and contractors must be documented when engaged in the selection, award, and administration of Federal grants contracts. Corrective Action Plan ? Even though the Town didn?t have a formal written policy in place regarding the search for suspended or debarred vendors/contractors, the Town did do the SAM?s search before signing agreements with contractors on each of the Federal Grant projects that were engaged in during the year. That being said, the Town will develop a written internal control plan and a policy on procurement for debarment in the coming months.

FA 2022-001 Improve 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 Federal Award Number: S425D210012 (Year: 2021) Questioner Costs: $119,600 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 Superintendent and HR Director have contacted the temporary placement vendor (ESS) to obtain an amendment for the additional bonuses that were paid. The new amendment has been received. In addition, an amendment will be obtained for any future payments that are given in addition to the original contracted amount. Estimated Completion Date: Completed May 24, 2023 Contact Person: Tomecka Woody, CFO Telephone: 706-441-0601 (x1007) Email: tomecka.woody@mcssga.org

FINDING 2022-003 Contact Person Responsible for Corrective Action: Karen Scalf, Chief Financial Officer Contact Phone Number: (765)973-3406 Views of Responsible Official: Richmond Community Schools agrees with this finding as this information was unknown and the purchases made were at separate times throughout the year, were cumulative totals, and were due to unexpected equipment breakages. Suspension and Debarment and appropriate contractual controls are important to RCS and routine internal controls are in place. The one sample noted was verified in INBiz at the Indiana Secretary of State?s office as we were unaware that only Sam.gov was permissible as the verification tool. It is routine practice for RCS to verify both areas, however documentation did not exist for the Sam.gov check on this particular sample during the audit period. Description of Corrective Action Plan: The Chief Financial Officer will review with the Business Office and RCS Administrators the necessity for Suspension and Debarment compliance as well as the appropriate processes. Vendors will be checked in Sam.gov prior to any new acceptance of vendors and any new receipt of W-9 Forms. Verifications of this check will be screen prints of the Sam.gov page, dates, and initials of the employee who verified Sam.gov. Vendors who are not in good standing and are not active in Sam.gov will not be accepted for transaction in any federal fund. RCS will also try our best to coordinate contracts with vendors on purchases between $50,000 and $150,000 during the budget year. These contracts may be approved after the purchase as purchases such as this occur due to unexpected breakages or emergencies. Anticipated Completion Date: April 7, 2023

2022-002 Higher Education Emergency Relief Funds Recommendation: We recommend the College document suspension and debarment procedures going forward for any vendors with federal expenditures over $25,000. We also recommend a procurement policy be implemented that meets the requirements of Uniform Guidance as well as the conflict of interest policy is updated to conform with Uniform Guidance. Lastly, we recommend documentation be retained as it relates to the methodology chosen for procurement in accordance with the procurement policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A procurement policy will be developed to include appropriate procedures to meet Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Michele Peterson Planned completion date for corrective action plan: 06/30/23

FINDING 2022-003 Person responsible for corrective actions: Courtney Halloran, Food Service Director Contact Phone Number: 765-647-4128 Views of Responsible Official: As Director of Food Service, I concur with the finding that an effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Description of Corrective Action Plan: Suspension and Debarment requirements will now be met with the use of the West Indy Co-op for use of dairy products. The Food Service Director will ensure that all vendors used for purchasing will be compliant and accessible. Milk procurement will now be done in assistance with the West Indy Co-op. Proper quotes will be documented and will reflect applicable state and local laws and regulations. Records will be maintained to include method of procurement, contract type, vendor selection and/or rejection, prices, and other quotes. The Food Service Director will ensure compliance before signing the bid agreement for the following school year. The purchasing group agreement will not be signed if procurement, suspension and debarment requirements are not met. Anticipated Completion Date: March 16, 2023 Courtney Halloran Director of Food Services March 16, 2023

Finding 2022-003 Contact Person Responsible for Corrective Action: Jennifer Anderson, Student Services/Special Education Director. Contact Number: 812-876-6325 View of the Responsible Official: Richland-Bean Blossom C.S.C. concurs with finding 2022-003. Description of Corrective Action Plan: The School Corporation will develop Internal Control procedures over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The School Corporation will develop and maintain an effective internal control system, which would include segregation of duties and would ensure compliance with requirements related to the grant agreement as well as following compliance requirements for Procurement and Suspension and Debarment. The School Corporation will have a control in place to ensure that proper procurement requirements regarding the Small Purchases threshold are met. The School Corporation will retain the appropriate amount of quotes needed and document if there is a unique situation with a vendor where quotes cannot be received. This information will be reviewed and implemented by the Corporation Treasurer, Student Services/Special Education Director or another authorized staff member. Anticipated Complete Date: Implementation of Corrective Action Plan will be set in places as of March 2023.

Our Katahdin will implement necessary policies and ensure appropriate oversight and compliance with those policies. Our Katahdin will develop and implement a written procurement policy in accordance with Uniform Guidance to ensure compliance. This policy will be adopted and approved by the Board of Directors and reviewed at least annually. Responsible official: Nancy DeWitt, Treasurer (207) 618-9187 Expected completion date: October 31, 2023

Description of Finding: There were two vendors that did not have the documentation to substantiate the use of the vendors, or the necessary pricing quotations. Corrective Action Plan: In the case of these two vendors, there were items ordered directly by a University department. These vendors were familiar vendors in the work of the department, so the standard vetting and documentation by the Purchasing department was not performed and documented. To correct this, all new vendors for purposes of Federal Awards will not be added into the system until reviewed and approved by the Purchasing department. The responsible parties are Lori Gordien Case at lgordien@laverne.edu, Xochitl Martinez-Eckel at xmartinez@laverne.edu, and Debbie Deacy at ddeacy@laverne.edu . This was corrected in November 2022.

Response: Management notes that, as this is their first time receiving significant federal funding and this was one-time emergency funding rather than an ongoing award, they do not have procurement procedures in writing which adhere to 2 CFR Part 200.318(a). However, they adhered to their internal written procurement procedures and conflict of interest policies, followed the award guidelines, and obtained multiple bids in the selection of vendors for contracted services. Action to be taken: Management notes that, as this was one-time emergency funding rather than an ongoing award, they do not anticipate receiving federal funding in the future. As such, they do not intend to document these procedures in writing at this point. However, if they apply for federal funding again in the future, they will develop written procedures at that point. Responsible Person: Andrew Edwards, Executive Director

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 followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. These procedures will help ensure compliance with Compliance 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: Management will create a formal, written procurement policy. Management will also review the noncompetitive procurement procedures and will document how and why our vendor(s) meets these requirements, if applicable. Additionally, HTHF will improve internal processes increasing the foundation?s work with our accounting support staff moving to a monthly service from quarterly with expenses entered into QuickBooks each month. Once expenses are entered, they will be reviewed by management and by the board treasurer. Name(s) of the contact person(s) responsible for corrective action: Joseph Holmes Planned completion date for corrective action plan: 10/31/23

Finding 2022-010 Lack of Internal Control over Procurement Name of Contact: Roxanne Peele, Office Manager Corrective Action: HCA will adhere to financial policies and procedures and maintain documented procurement action and methods in selecting vendors for major purchases. Proposed Completion Date: 08/31/2023

Recommendation: We recommend the University revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: EOU is currently reviewing the institutional procurement process to determine if a single set of guidelines should be in place, rather than federal vs non-federal funding. Using a single set of guidelines would create a uniform procurement process, no matter the funding source, however additional options are currently being investigated. Name(s) of the contact person(s) responsible for corrective action: Haley Evans, Controller Planned completion date for corrective action plan: October 2023

Finding: 2022-02 Finding Summary: Utah Food Bank verified that contractors were not suspended, debarred, or otherwise excluded from System Award Management (?SAM?), but did not document the procedure and did not retain documentation of this action. Responsible Individuals: Jennifer Pratt, Chief Financial Officer Corrective Action Plan: Utah Food Bank will continue to enhance internal controls over written procurement policies and monitoring vendors to ensure its compliance with the Code of Federal Regulations, including keeping documentation of SAM compliance on each vendor before the work starts and upon each disbursement. Anticipated Completion Date: February 24, 2023