Corrective Action Plans

Procurement and Suspension and Debarment - Public and Indian Housing ? Assistance Listing No. 14.850 Recommendation: We recommend that the Authority reviews it?s procurement policy and active contracts and future contracts to ensure that all policies and procedures regarding procurement of contracts are properly followed and documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Name(s) of the contact person(s) responsible for corrective action: Ivra Amacker, VP Affordable Housing Planned completion date for corrective action plan: September 30, 2023

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Todd Pritchett Contact Phone Number: 317-889-4060 Views of Responsible Official: The finding is not disputed. The corporation experienced turnover during the audit period in the cafeteria manager's positon which may have contributed to inability to provide documentation of three quotes for the specified purchase. Description of Corrective Action Plan: On-going training and additional and more experience will continue to address proper documentation procedures. Anticipated Completion Date: Immediate

Lack of Purchase Order Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles We will make sure that we follow our SOP and that proper controls are in place to ensure the policies and procedures are being followed. We also have a new E.D. who checks and approves every purchase order. The proper controls are now in place.

2022-004 Coronavirus State and Local Recovery Funds ? Assistance Listing No. 21.027 - Procurement Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Finance Manager will implement a Federal Procurement Checklist. The Finance Manager will provide the checklist to the finance committee to complete and approve for federal spending. Name of the contact persons responsible for corrective action: Jill Johnson, Finance Manager, and Department Heads and Elected Officials Planned completion date for corrective action plan: December 1, 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Food Service Director Billie Jo Russell Contact Phone Number: 812-755-4872 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Procurement ? The School Corporation has established internal controls to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment requirement. The Food Service Director will obtain information from the Wilson Service Center for any necessary documentation pertaining to this requirement. The School Corporation has procured any food and supply purchases that exceed $150,000 and will maintain documentation for procurement procedures for purchases under $150,000. Suspension/Debarment ? Procedures will be implemented to ensure our procurement agent is an approved procurement agent. Anticipated Completion Date: Immediately

2022-001 Methods of Procurement Recommendation: We recommend that the County review their policies and procedures to ensure that they are operating in a manner that follows federal procurement requirements and the County?s procurement policy. The creation and use of a standard procurement checklist would assist the County in documenting all requirements for each procurement that is entered into. Management Concurs with the Finding and Recommendation Action Plan Taken in Response to Finding: The Finance Department will work with County Management and Board Departments to ensure familiarity and understanding of the County?s procurement policies and procedures. Additionally, the County is working towards the implementation of a financial system which will improve the controls in place to help ensure compliance with procurement requirements. The Finance Department is also working on a financial policies document and will would with County Manager on a review of the County?s procurement policy. Name(s) of contract person(s) responsible for corrective action: Tasha Morgan, Finance Director Planned completion date for corrective action plan: We anticipate the finding will be address by September 30, 2023

SINGLE AUDIT FINDINGS: Finding 2022-001: Procurement and Suspension and Debarment Description of Finding: The City?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence: The City concurs. Corrective Action: The City will enhance their existing policies for procurement to be in accordance with Uniform Guidance Procurement Standards and plans to be adopted by June 30, 2023. Name of Contact Person: Henry Dachowitz, Chief Financial Officer Projected Completion Date: June 30, 2023

The University will review the specified requirements of the Office of Management and Budget Guidance for Grants and Agreements with the University?s grant professionals in Finance and the Office of Sponsored Programs to recommend an appendix for federal grants expenditures to the University?s procurement policy as part of the upcoming annual review.

Views from Responsible Officials: Management agrees with the finding. Management will design and implement a procurement policy which will be reviewed annually to ensure that any changes in laws and regulations are reflected in internal procedures. Contact Person: Natisha Dawson, Director of Finance and Operations. Anticipated Date of Completion: December 2023.

U.S. Department of Treasury 2022-004 COVID-19 ? Coronavirus State and Local Relief Funds (CSLRF)? Assistance Listing No. 21.027 Recommendation: The Town should review and enhance controls and procedures to ensure that it follows procurement policy for all goods and services charged to the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Town's procurement policy will be reviewed and updated to ensure compliance with federal requriements. Name(s) of the contact person(s) responsible for corrective action: Steven Repole Planned completion date for corrective action plan: 6/30/2023 If the U.S. Department of Treasury, Office of Recovery Programs has questions regarding this plan, please call Steven Repole at 410-398-4170.

CORRECTIVE ACTION PLAN Year Ended June 30, 2022 Mechanicsburg Area School District respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule of findings and questioned costs. Finding 2022-001 - Procurement Federal Agency: U.S. Department of Agriculture Pass-through agency: Pennsylvania Department of Education Assistance Listing Number: Child Nutrition Cluster ? 10.553/10.555/10.559 Corrective Action Planned: The District will establish processes to ensure that the procurement policy is followed when applicable and necessary. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of this finding. Contact Person Responsible: Greg Longwell, Director of Business Operations/CFO If there are any questions regarding this plan, please call Greg Longwell, Director of Business Operations / CFO, at 717-506-0869 or email at glongwell@mbgsd.org

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