Corrective Action Plans

Condition: The Organization does not have a documented procurement policy that conforms to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Context: During the year, the Organization made a purchase of property that was greater than the Simple Acquisition Threshold of $250,000. As part of the audit procedures, we requested the Organization's documented procurement policy. The Organization did not have a documented procurement policy. Prior to making purchases in excess of the simplified acquisition threshold, the Organization performed a price analysis in a manner consistent with 2 CFR Part 200. Cause: The Organization was not aware that a documented procurement policy was required. 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. Effect: Without documented procurement policies, the Organization could procure assets in a manner that is not consistent with 2 CFR Part 200. Recommendation: We recommend that the Organization familiarize themselves with the requirements of 2 CFR sections 200.318 through 200.326 and develop a documented procurement policy that conforms to applicable federal statutes and procurement requirements. Management Response: In responding to the findings of the audit regarding the absence of a documented procurement policy that aligns with federal statutes and procurement requirements as outlined in 2 CFR Part 200, Sigma Beta Xi, Inc. acknowledges the criticality of this oversight. We understand the importance of having formal, documented policies in place to guide our procurement processes, ensuring they are transparent, equitable, and in full compliance with federal regulations. The absence of such documentation represents a missed opportunity for our organization to institutionalize best practices and safeguard the integrity of our procurement activities. Corrective Actions and Commitments: To address this finding and prevent future occurrences, Sigma Beta Xi, Inc. is taking the following steps: 1. Policy Development: We are in the process of developing a comprehensive procurement policy that will be fully documented and accessible. This policy will outline the procedures for all procurement activities, ensuring they are consistent with the requirements set forth in 2 CFR sections 200.318 through 200.326. It will reflect applicable state and local laws and regulations, as well as conform to applicable federal statutes and procurement requirements. 2. Stakeholder Engagement: Recognizing the importance of stakeholder buy-in, we will involve key personnel from various departments in the development of the procurement policy. This collaborative approach ensures the policy is comprehensive, practical, and adheres to the diverse needs of our organization while maintaining compliance with federal regulations. 3. Training and Implementation: Upon completion and approval of the procurement policy, we will conduct training sessions for all relevant staff. These sessions will cover the details of the policy, emphasizing the importance of compliance with federal statutes and the procurement requirements identified in 2 CFR Part 200. This will ensure that all team members are knowledgeable about the policy and understand their roles and responsibilities within the procurement process. 4. Monitoring and Compliance: We will establish mechanisms for monitoring compliance with the new procurement policy. This includes regular audits of procurement activities and ongoing reviews of the policy to ensure it remains current with federal regulations and best practices. 5. Documentation and Transparency: All procurement activities, especially those exceeding the simplified acquisition threshold, will be thoroughly documented, including the rationale for the procurement method used, selection of contract type, contractor selection or rejection, and the basis for the contract price. This documentation will ensure transparency and accountability in our procurement processes.

Views of responsible officials and planned corrective action: The Town Treasurer is working on updating the current purchasing policy. Within this policy, the Town Treasurer will implement language to reference the Uniform Guidance procurement standards.

FA 2022-001 Improve Budgetary Controls over Expenditures Compliance Requirement: Activities Allowed/Unallowed Allowable Costs/Cost Principles Internal Control Impact: Material Weakness Compliance Impact: Material 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 – Elementary and Secondary School Emergency Relief Fund Federal Award Number: S4250200012 (Year: 2020), S4250210012 (Year 2021), S425U210012 (Year 2021), S425W210011 (Year 2021) Questioned Costs: $279,314.22 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: Thomasville City Schools has amended any contracts with companies that provide services to allow the District to pay ESSER retention supplements when the Thomasville City Schools employees receive them. Estimated Completion Date: August 10, 2023 Contact Person: Stella M. Smith, CPA Telephone: (229) 225-2600 Email: smiths@tcitys.org

FA 2022-003 Improve Controls over Procurement Compliance Requirement: Procurement 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 AL Numbers and Titles: 84.027 - Special Education Grants to States 84.173 – Special Education Preschool Grants Federal Award Numbers: HO27A200073(Year: 2021), HO27A210073 (Year: 2022), HO27X210073 (Year: 2022), S371C190016-19A (Years: 2017-21) Questioned Costs: None Identified Description: A review of expenditures charged to the Special Education 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: [Insert Corrective Action Plan(s) Here] Estimated Completion Date: A review of costs and expenditures for all purchases and contracts involving rates of pay for the purpose of education students with disabilities will be completed prior to the approval of purchases and contractual agreements. A minimum of 2 quotes per expenditure and/or contracted service agreement will be procured prior to approval of the expenditure and/or contractual agreement. For contractual agreements, the student services director will be responsible for obtaining quotes, and the individual requesting the purchase of required items will be responsible for obtaining and providing quotes to the director prior to approval. These records will be kept on file within the student services department. Contact Person: Angela Williams, Superintendent Telephone: 706-554-5101 Email: amwilliams@burke.k12.ga.us

FA 2022-002 Improve Controls over Procurement Compliance Requirement: ‘Procurement Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.371C – Comprehensive Literacy Development Federal Award Number: S371C190016-19A (Years: 2017-21) Questioned Costs: ‘$177,213.73 Description: A review of expenditures charged to the Comprehensive Literacy Development program 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 Comprehensive Literacy Director will review and update the current procedures to ensure that the required procurement methods are properly identified and followed, and that required procurement documentation is properly identified, safeguarded, and retained. Estimated Completion Date: May 1, 2024 Contact Person: Angela Williams, Superintendent Telephone: 706-554-5101 Email: amwilliams@burke.k12.ga.us

Finding caption: The City did not have adequate controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of City contact person: Josh DeLay, Finance Director 271 9th Street N.E. East Wenatchee, WA 98802 (509) 886-4507 Corrective action the auditee plans to take in response to the finding: In 2023, the City Council passed a robust procurement policy that meets all the federal grant requirements (Resolution No. 2023-38); however, it was passed after 2022 and wasn’t in place during this particular audit period. Anticipated date to complete the corrective action: Already complete

Finding 2022-006: Procurement, Suspension, and Debarment – Material Weakness. The buying policy ordering process has been updated to include blocking GSA (Government Services Administration) & HHS (Health & Human Services) disbarred sellers in accordance with SAM (System of Award Management) system. The overall Procurement policy, contracts and forms will be updated to include suspension and debarment language.

FINDING 2022-002 Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The School Corporation had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchases were followed. There was no oversight, review, or approval process in place and documented at the School Corporation to ensure proper procedures were followed and price or rate quotations were obtained, or documentation to support limited procurement procedures conducted. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000 per Indiana Code. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micropurchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation did not obtain price or rate quotes for the five vendors tested that was less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micropurchase threshold. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. The School Corporation also did not follow procurement requirements for contracted services which exceeded the simplified acquisition threshold of $150,000. The School Corporation did not correctly procure a contract for the one vendor that exceeded the simplified acquisition threshold. Additionally, the School Corporation did not adequately maintain documentation of the procurement history or rationale. Finally, the School Corporation did not verify that this vendor was not excluded or disqualified from participation in federal assistance programs or activities. Contact Person Responsible for Corrective Action: Matthew Miles, CFO Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will obtain 3 quotes or do a bid process in the future. If there is limited availability, we will document the reason 3 quotes are not possible. Additionally, the District INDIANA STATE BOARD OF ACCOUNTS 34 will check for suspension and debarment, create a write-up of our findings, and obtain Board approval for the contract. Anticipated Completion Date: The School District will implement changes described in the Corrective Action Plan February in 2024.

Planned Corrective Action: We will expand our existing purchasing procedures into a fully documented procurement policy that meets the standards set out in 2 CFR Part 200. Name of Contact Person: Rachel Watson, Business Office Director/Controller, watson.rachel@occ.edu Anticipated completion date: June 30, 2024

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Clarkston 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 for ensuring compliance with federal procurement requirements. Name, address, and telephone of City contact person: Steve Austin, Clerk Treasurer 829 5th Street, Clarkston, WA 99403 (509) 758-5541 Corrective action the auditee plans to take in response to the finding: The City updated the policy regarding federal procurement to ensure compliance with usage of federal funds in November 2022. This audit determined that additional levels of internal control needed to be implemented to comply with Uniform Guidance and federal regulations. The City plans to update the procurement policy and standards of conduct policy to ensure that federal standards are being maintained. The City will strengthen internal controls to ensure that procurement of goods and services will comply with Uniform Guidance, the federal regulations and the City’s procurement policy. Anticipated date to complete the corrective action: Completed before the 2024 year-end.

(A) Colorado School of Mines will ensure appropriate reviews of expenditures occur to ensure they are within the period of performance for the federal award, and ensure that staff have an appropriate understanding of the related period of performance requirements or obtain clarification from the federal grantor, as appropriate. (B) Mines did not update published Procurement Policies specific to approval limits by position to accurately reflect the delegated approval authority. Mines will update the published policies to accurately reflect delegated approval limits and review the procurement approval process.

(A) Going forward, the Director of Purchasing will perform all Sam.Gov searches. The secondary reviews to ensure compliance for the System's procurement and suspension and debarment procedures will be conducted by the Vice President of Administration and Finance. (B) The corresponding documents supporting procurement transactions and suspension and debarment checks will be scanned and filed along with the Purchase order. (C) Training will be provided to fiscal and grant staff for identifying when suspension and debarment must be checked for vendors of federal programs, processes and websites to access, and methodology for documenting with the purchase documentation.

(A) Otero College has adopted the system offices Sole Source justification form that will be posted to the State procurement site, requires supervisory approval, and has put that into place as of August 2022. (B) Otero College will ensure they maintain supporting documentation for procurements. (C) Otero College has a new procurement official that has attended various trainings regarding procurement rules.

(A) Beginning in October 2022, the duty was moved from the Principal Investigator or instructional staff previously responsible for this step to the Director of Purchasing to ensure compliance for all grant transactions. (B) Training will be provided for identifying when suspension and debarment must be checked for vendors of federal programs, processes and websites to access, and methodology for documenting with the purchase, to fiscal and grant staff.

2022-002 U.S. Department of Agriculture, Food, and Nutrition Service Emergency Food Assistance Program CFDA Number: 10.568/10.569 Passed Through: The Arizona Department of Economic Security Pass Through Number: CtR052634 Award Period: July 1, 2021 ? June 30, 2022 Condition/Context ? Internal control procedures over procurement requirements did not ensure compliance with federal awards. For 1 of 8 vendors tested, there was no documented evidence that the vendor was reviewed and approved in accordance with the Organization?s procurement policy. Contact Person ? Megan Montalvo, Chief Financial Officer Corrective Action Plan ? United Food Bank follows the set procurement policy. Quotes are obtained for all vendors who meet a certain dollar threshold. For the instance that occurred, quotes were obtained and reviewed. A meeting was held to discuss the quotes received, and it was decided to use the service of all of the vendors that quotes were obtained from, not just a single vendor. The failure occurred due to not documenting the selection of using multiple vendors for the same service on the Organization?s Vendor Selection Form. The Vendor Selection Form will be completed for all procurement services, even if multiple vendors are selected for the same type of goods or services.

Easterseals Southeast Wisconsin has a policy which clearly outlines approval authorities. While we follow that policy properly, we understand that the policy lacks some elements required by the Uniform Guidance. None of our purchases made during the year under audit would have violated Uniform Guidance, but we are committed to compliance and therefore have already started to draft policies which will adhere to Uniform Guidance. We will finalize, communicate, and follow our updated Policies and Procedures to ensure that Uniform Guidance is followed and to resolve the finding from this audit.

Finding: 2022-003 Federal Agency Name: Department of Health and Human Services Program Name: National Bioterrorism Hospital Preparedness Program Federal Financial Assistance Listing #93.889 Compliance Requirement: Procurement, Suspension and Debarment Finding Summary: No independent secondary level of review or approval is performed relating to compliance. One employee is involved in preparing, reviewing and approving information. Additionally, 15 instances identified in our sample of expenditures in which the transaction exceeded the Coalition?s micro-purchase threshold, requiring a price analysis, however, the price analysis was not documented or completed. Further, the Coalition?s procurement policy does not include all the required elements as outlined in the Uniform Guidance. Lastly, five vendors were not verified against the central contractor registry prior to the expenses being incurred to ensure that the vendor was not suspended or debarred. Responsible Individuals: Greg Santa Maria, Executive Director Corrective Action Plan: The SDHCC Executive Director is currently revising the Coalition procurement policy to ensure that it appropriately reflects all elements required by the Uniform Guidance. The SDHCC Executive Director is updating the current review process to ensure that moving forward, all transactions that will exceed the Coalition?s micro purchase threshold include a documented price analysis. This will be reflected in the revised procurement policy. In an effort to ensure full compliance with vendor regulations. All outside vendors will be verified against the central contractor database before the SDHCC enters into any purchase agreements. This will be reflected in the revised SDHCC procurement policy. Anticipated Completion Date: Projected completion of procurement policy revision first draft to Board is Friday April 7, 2023

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? ALL FEDERAL PROGRAMS AWARDED UNDER THE UNIFORM GUIDANCE 2022-001 Internal Controls Over Compliance With Cash Management, Allowable Costs, Standards for Financial Management, and Procurement Finding Summary During our audit, we noted that Universal Academy?s (the Academy) written internal control policies over compliance with the U.S. Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) did not include adequate written controls over compliance with cash management, allowable costs, financial management standards, and procurement. Corrective Action Plan Actions Planned ? The Academy has implemented an updated version of its written policies and procedures relating to cash management, allowable costs, financial management standards, and procurement for its federal programs to ensure compliance with the Uniform Guidance effective for fiscal year 2023. Official Responsible ? The Academy?s Executive Director, Farhiya Einte. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The Academy agrees with this finding. Plan to Monitor ? The Academy?s Executive Director, Farhiya Einte, will ensure appropriate written internal controls and procedures are updated and in place for future federal grants.

Rural eConnectivity Pilot Program ? Assistance Listing No. 10.752 Recommendation: We recommend the Commission establish and document procurement policies and procedures in conformity with the Federal requirements ?? 200.317 through 200.327. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will adopt a written procurement policy in accordance with the federal requirements. Since the inception of the Rural eConnectivity program, the Commission has followed the Town of Easton Charter Article IV, Section 2(e) when contracting with third party vendors. The Commission now recognizes compliance with the Charter does not satisfy the necessity for a separate procurement policy to fulfill federal requirements. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: April 30, 2023

Finding 2022-01 Federal Program Title: Education Stabilization Fund ?Higher Education Emergency Relief Fund Compliance Requirement: Procurement, Suspension and Debarment Name of Contact Person: Lynn Feeken, Financial Controller Corrective Action: The College developed and implemented a procurement policy which addressed Uniform Guidance Procurement, Suspension and Debarment requirements. Date of Completion: January 5, 2023

2022-001 Higher Education Emergency Relief Funds (Procurement/Suspension and Debarment) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Crown College will review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. The Chief Operating Officer and the Controller will collaborate in this effort. Name(s) of the contact person(s) responsible for corrective action: Ron Straka Planned completion date for corrective action plan: May 31, 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Sue Hart Contact Phone Number: 812-752-8921 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Each vendor who has received payment from the school district from federal Child Nutrition funds, or is expected to in the future, shall be required to have at least one of the following filed with the school district each year: 1) SAM Exclusions without the vendor being listed as excluded or disqualified; or, 2) Certification of the vendor not being excluded or disqualified; or, 3) Including a clause or condition on any and all contracts or invoices confirming the vendor is not excluded or disqualified. The Director of Food Services shall maintain files with evidence of the above documentation and it shall be updated at least annually and no fewer than once per calendar year. In addition, the Director shall ensure price or rate quotes are acquired from all vendors the Director reasonably expects to pay more than the micro-purchase threshold and contracts shall be executed with vendors when purchases are between $50,000 and $150,000. Such contracts shall also be Board approved with copies uploaded to the Gateway system for ease of access by SBOA or the district in the future. Anticipated Completion Date: June 2023

REFERENCE # 2022-001 PROCUREMENT SUSPENSION AND DEBARMENT ? MATERIAL WEAKNESS- NON-COMPLIANCE Program Name/ALN Emergency Solutions Grant Program (ALN # 14.231) Criteria: As per ? 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. (d) The Non-Federal entity 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. Condition/Context: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR ? 200.318 General procurement standards. We selected two (2) vendors for procurement Suspension and Debarment compliance testing of total population of 2 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: ? To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. ? To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Questioned Costs: Cannot be determined Recommendation: We recommend that the Division must: (1) document procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. (2) The Division?s documented procurement procedures must conform to the procurement standards identified in ?? 200.318 through 200.327. . Corrective Action Plan: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. Step 1 Action Date: Ongoing Final Implementation Date: 9/30/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

FINDING 2022-002 Contact Person Responsible for Corrective Action: Greg Hopkins Contact Phone Number: 812-967-3926 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Small Purchases The Food Service Director of the local School Food Authority will work with the Food Service Management Company to ensure all items purchased are procured properly using the correct thresholds set by the state and federal government. Suspension and Debarment The Corporation is now contracted with a Food Service Management Company (Aramark). The Food Service Director reviews all agreements/contracts related to Food Service to ensure that they meet the requirements related to suspension and debarment. Once contracts/agreements are reviewed, the Food Service Director signs off. Anticipated Completion Date: Effective Immediately

FINDING 2022-001 Contact Person Responsible for Corrective Action: Stacie Light, Director of FNS Daniele Raber, Corporation Treasurer Contact Phone Number: 574-371-5098 ext. 2408 574-371-5098 ext. 2451 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: WCS was fully operating during a pandemic and had to do whatever it took to get products for our students and families. Although we feel we followed the proper procedures for these purchases, we will take your recommendations to make sure we're following protocol. During the pandemic, due to supply chain issues, we had to utilize vendors outside of the co-op in order to meet these needs which resulted in higher total expenditure costs for these vendors. Supply chain issues are not as prevalent as the pandemic has lessened. These purchases to outside co-op vendors are decreasing. We will do payment history checks on the vendors our Child and Nutrition program is utilizing throughout the year to ensure they are under the small purchase threshold and will receive contracts with vendors should they exceed this threshold. We will continue to follow our already established process of checking SAM.gov when new vendors are entered into our system for use. We will begin to do an annual check of vendors that our Child and Nutrition program utilizes to ensure that previously established vendors are not on the suspension or debarment listing. Anticipated Completion Date: We will begin these corrections immediately for the remainder of the school year and will more fully implement these corrections as of the beginning of the 2023-2024 school year.