Corrective Action Plans

Finding 2022-002: Procurement Policy (Material Weakness) Information on the Federal Program: U.S. Department of State ALN 19.040 Criteria or Specific Requirement: 2 CFR Section 200.318 requires that 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. Condition: FCE does not have a formal written procurement policy that conforms to the requirements of the Uniform Guidance. As a result, no procurement files were maintained to document FCE's procurement actions. Cause: FCE has no accounting policies and procedures in place to provide guidance to management on the documentary evidence requirements in accordance with proper internal controls and the Uniform Guidance. Effect or Potential Effect: Without either a procurement policy or procurement documentation, there is a risk that FCE did not perform a proper evaluation of each potential vendor whose costs were charged to federal programs. Recommendation: FCE should develop accounting policies and procedures to provide guidance to management regarding the proper internal controls over both financial reporting and compliance with federal awards. Included in those policies and procedures should be a procurement policy that conforms to the requirements of the Uniform Guidance. Furthermore, FCE should maintain documentation in its files to provide evidence to support that it followed the procurement policy. Action Taken: FCE acknowledges the requirements of the Uniform Guidance and the non-compliance implication for Federal awards. FCE is in the process of developing and implementing a procurement policy to ensure proper competitive procedures are followed with respect to its procurements, specifically its vendors. FCE will ensure that proper documentation is maintained in its files in accordance with the policy to be implemented.

UNITED STATES DEPARTMENT OF EDUCATION 2022-002 Education Stabilization Fund: Higher Education Emergency Relief Fund Student Portion and Institutional Portion ? Assistance Listing No. 84.425E, 84.425F Recommendation: We recommend that the University 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 planned/taken in response to finding: The University has reviewed and will continue to monitor procurement and suspension and debarment policies and update procedures as needed to ensure compliance with federal requirements. Name(s) of the contact person(s) responsible for corrective action: John Nisbet, Interim Vice President of Administration & Finance Planned completion date for corrective action plan: April 2023

Finding 2022-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2022-002. A Sams.gov account has been activated in order to verify that entities that are being utilized for County business are not excluded from or are ineligible for participation in Federal programs or activities. Also, the County is currently drafting a Procurement Policy for Washakie County to utilize for the use of Federal funding as well as in an everyday manor of purchasing and maintenance of county facilities in order to satisfy above finding.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jessica Secrease Contact Phone Number: 765-456-2804 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County will establish a federally-compliant conflict of interest policy in addition to the County?s current conflict of interest policy. The County Attorney will be notified again that this policy still needs to be created. Anticipated Completion Date: 10/31/2023

Finding Number: 2022-001 Condition: The College did not have a policy in place to ensure it was complying with "Never Contract with the Enemy" and verifying that a contractor is not debarred, suspended, or otherwise excluded from doing business with federal assistance programs or activities. In addition, the College's policy does not include all provisions in 2 CFR Section 200.318-327. Planned Corrective Action: An Albion College ?Never Contract with the Enemy? policy will be put into place and have the following conditions within the policy: The ?Grants and Foundation Relations Grants Manual? will be updated to include policy information about this federal regulation and how to determine whether a subcontractor/vendor is prohibited under this policy from being paid with federal grant funds. The Grants and Foundation Relations team (?GFRT?) will include the federal regulation in every ?Grants Kickoff Meeting? checklist and will discuss with the Principal Investigators (?PI?s) during grant development so that issues can be addressed at the beginning of federal grant application process. PI?s of the federal grants will be responsible for checking the SAM excluded vendor list as they are finalizing their budget and/or planned expenditures to confirm all subcontractors/vendors are allowed and in good standing, before any contract over $50,000 is executed or any invoice greater than $20,000 is paid. The Business Office will verify that the vendors or subcontractors for federal grants have been checked against the SAM excluded vendor list during the expenditure approval process. In addition, the College with develop a procurement policy that conforms to provisions in 2 CFR Section 200.318-327 and all federal grant recipients should review and adhere to that policy for all purchases and expenditures made with federal grant funds. Consult with GFR or the Business Office if there are questions about these standards and how they may impact federal grant expenditures. Contact person responsible for corrective action: Amy Routhier-Chief Advancement Officer for Grants and Foundation Relations & Albert Hammond-Staff Accountant-Gifts and Grants Anticipated Completion Date: The GFRT has added a ?Never Contracts with the Enemy Policy? to the Grant Manual, which is presented at all ?Grant Kickoff? meetings. The team also discusses with each (?PI?) in grant development what the policy expectations are.

2022-003 - Procurement Corrective Action Planned: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget., its own existing Board Policies, and has developed administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Guidance procurement methods. Effective for the 22-23 fiscal year and going forward the District will fully deploy the administrative procedures and controls to all applicable District stakeholders and monitor all such procurements for compliance purposes. Anticipated Completion Date: Action has already been taken by the District to resolve the underlying issue of the finding in the current fiscal year . Contact Person Responsible: Kenneth L. Medina, MBA, Business Manager/Board Secretary

DHS agrees with the finding and recommendation. DHS will remind staff via electronic memoranda to ensure compliance with federal and County procurement requirements and maintain records sufficient to detail the history of the procurement.

Finding ref number:2022-001. 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: Holly Beller P.O. Box 548, Ilwaco WA 98624 (360) 642-3145. Corrective action the auditee plans to take in response to the finding: The City will develop and adopt written policies and procedures that conform with Uniform Guidance (2 CFR 200.318-327) for procurement activity and conflict of interest requirements. Anticipated date to complete the corrective action: January 1, 2024.

2022-003 ? Procurement, Suspension, and Debarment Corrective action plan: The Tribe will amend its Financial Management System, to increase the micro-purchase procurement threshold from $2,000 to $10,000, set by the Federal Acquisition Regulation. When processing Purchase Orders, the Purchasing Clerk will verify that a minimum of three bids or quotes have been submitted with the Purchase Order request, for those items costing $10,000 or more. This requirement will help ensure that goods and services are being obtained at a fair price. The Tribe will amend its Financial Management System to include a policy on suspension and debarment. For purchases exceeding $25,000, the Finance Manager will perform a search of the vendor on the Systems for Award Management (SAM) website, to verify that the vendor receiving payment has not been suspended or debarred. Personnel responsible for corrective action: Finance Manager (Lisa Donham) Estimated corrective action completion date: December 31, 2023

HEERF Procurement, Suspension and Debarment ? Assistance Listing No. 84.425F Recommendation: We recommend that the College review their procurement policy to ensure a process is in place to follow it in the future. We also recommend a policy be drafted surrounding suspension and debarment that includes all federal requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will review their procedures around HEERF reporting and ensure someone is designated to review prior to uploading the reports. Name(s) of the contact person(s) responsible for corrective action: Kelly Flege Planned completion date for corrective action plan: update plan

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number: 317-485-3100 Views of Responsible Official : We concur with the finding Description of Corrective Action Plan: The Food Service Director (FSD), with assistance from the CFO, will develop a plan to secure a third vendor for kitchen equipment repairs, both for emergencies or regular maintenance repairs. The FSD and CFO will also develop a plan to solicit service plan proposals from qualified providers. The FSD and CFO will utilize approved service agreements through purchasing cooperatives, if available or, solicit responses through the public works bidding process. If a responsive responsible bidder can be secured, the service contract will be approved by the school board of trustees. Anticipated Completion Date: 7/1/2023

View of Responsible Officials and Planned Corrective Actions: FamilyForward was responsive and provided requested information to the awarding entity at each stage of the appropriation, single source determination, contracting, and payment process. FamilyForward relied upon the awarding entity?s single source determination that activities undertaken in our role as subrecipient were conducted in accordance with all required policies and procedures, including procurement. FamilyForward will implement procurement policies and procedures to ensure that we meet requirements of Uniform Grant Guidance in advance of soliciting or securing federal funds for projects.

The District will monitor vendors to ensure they are able to accept federal monies. Samantha Schweizer, Business Administrator by 6/30/2023.

Charter Schools ? AL #84.282 2022-003 Noncompliance ? Procurement and Suspension and Debarment (Repeat Finding 2021-003) Significant Deficiency Recommendation: The Auditor recommended the Organization develop a system of internal controls aligned with the applicable compliance requirements to sufficiently document procurements and to ensure suspension and debarment is considered prior to entering into future covered transactions. Planned Corrective Action: While procurement requirements are followed, management concurs that the documentation of procurement activities does not always occur. The reorganization of the Business Office described above in 2021-002 will allow the Controller to oversee procurement of purchases with federal funds and to ensure all compliance requirements are followed and appropriately documented. If the U.S. Department of Education has questions regarding this plan, please call Juli Woodrum, Vice President & Chief Financial Officer at 317.231.0010 x16109.

2022-004 INTERNAL CONTROL OVER COMPLIANCE AND COMPLIANCE WITH PROCUREMENT, SUSPENSION AND DEBARMENT The National Trust has a Procurement SOP that is fully responsive to CFR ?200.318, and the sampled expense complied with that policy when procured in April 2022. Federal funds were awarded in July 2022 permitting reimbursement of costs incurred as early as March 2021. At the direction of pass-through entity Westchester County, these one-time coronavirus relief funds were applied to reimburse the National Trust for expenses selected by that entity even though the vendors were contracted prior to the award of relief funds. To remedy any gaps in our process, the National Trust will modify the Procurement SOP to clarify that multiple contracts with a single vendor must be treated as a single contract for purposes of the small purchase threshold and will ensure that all expenses are subject to the more stringent requirements under CFR ?200.318. Additionally, the National Trust will modify the procurement procedures to ensure that suspension and debarment screening occurs prior to entering contracts. Individual(s) Responsible for Corrective Action Plan: Thompson Mayes Chief Legal Officer and General Counsel 202-588-6182 Anticipated Completion Date: June 30, 2023

When using federal funds the County Board Administrator will retain documentation recording the details of procurement and also complete suspension and debarment procedures for a vendor when the procurement is over $25,000.00.

Finding 2022-001: Significant deficiency in internal control over procurement. Summary: There was no documented evidence that a contractor was required to comply with the prevailing wage requirement of the Federal Award agreement in one contract under the Federal Award. Corrective Action Planned: Written policies and procedures regarding procurement and grant compliance will be updated and implemented to ensure compliance with procurement terms and conditions of Federal Awards. Anticipated Completion Date: By Sept 30, 2023. Name of Contact Person Responsible for Corrective Action: Tammy Rash, Administrative Services Director

2022-003 PROCUREMENT, SUSPENSION AND DEBAREMENT ? COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Recommendation: We recommend the county align their county wide policies to address any necessary modifications to the process if procurement transactions are federally funded. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their internal procurement policies to better align with federal requirements for purchases that fall under these requirements. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

2022-004 PROCUREMENT, SUSPENSION AND DEBAREMENT ? STATE ADMINISTRATIVE MATCHING GRANTS FOR SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP CLUSTER) Recommendation: We recommend the county align their county wide policies to address any necessary modifications to the process if procurement transactions are federally funded. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their internal procurement policies to better align with federal requirements for purchases that fall under these requirements. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Jim Evans Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This finding has been corrected by discontinuing purchases from the vendor in question for the remainder of the 2022-2023 school year. In future years, future purchases from this vendor will be limited to $9,000.00 per fiscal year. The purchases will be monitored by the Food Service Director and the Food Service Managers in each building. Anticipated Completion Date: This finding has been corrected.

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Brook Cleaver Contact Phone Number: (765) 675-2147 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Superintendent and Treasurer will work to ensure that bids are sought and kept on file for projects exceeding the simplified acquisition threshold. Once a vendor is selected, Treasurer will search exclusions in the Sam.gov portal for vendors that may be suspended or debarred from participation in federal assistance programs and keep said documentation on file. Anticipated Completion Date: Immediately.

U.S. Department of Transportation 2022-001 Formula Grants for Rural Areas ? Assistance Listing No. 20.509 Recommendation: We recommend that current policies and procedures over covered transactions be updated to include one of the following procedures related to suspension and debarment: - Searching for the person or entity within the Excluded Parties List System; - Collecting certification from the person or entity; or - Adding a clause or condition to the covered transaction with that person or entity Additionally, all contracts should be maintained and kept on file to ensure records are complete. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VAC management has drafted a policy to ensure that a check of the excluded parties list system is completed and documented prior to entering any covered transaction over $25,000. Name(s) of the contact person(s) responsible for corrective action: Justin Dooley, Finance Director Planned completion date for corrective action plan: 2/15/2023

Recommendation: We recommend the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Action taken: The district entered into a shared services agreement with Capital Region BOCES in March of 2022 for management of the School Nutrition program. It was assumed that this was a procedure they followed; however, documentation was not provided and the external auditors included it as a finding. Todd Barker is the new School Nutrition Director with BOCES and he will provide documentation to the district that due diligence has been done to meet this requirement. Anticipated completion date: 11/1/2022

March 10, 2023 Federal Audit Clearinghouse Re: Corrective Action Plan for Community Action Partnership of Mercer County To whom it may concern: Views of Responsible Officials and Planned Corrective Actions: 2022-01 There is no disagreement with the audit finding regarding our procurement policies and the lack of documentation in the Weatherization file that was reviewed. The Organization will review the Procurement policies and make necessary adjustments to how we acquire services from contractors and what the thresholds are. We will also be reviewing our documentation policies in Weatherization and making the adjustments to what documents go into the consumer file. Employee Responsible for Corrective Action: Michelle Clarke Completion Date: May 31, 2023 Respectfully Submitted, Michelle Clarke VP/CFO

October 14, 2022 U.S. Department of Education 400 Maryland Avenue, SW Washington, D.C. 20202 Re: Corrective Action Plan Finding 2022-002: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds, Procurement, Suspension and Disbarment Program: COVID-19 Education Stabilization Fund (ESF) - Institutional Portion Assistance Listing Number (ALN): 84.425F Federal Agency: U.S. Department of Education Federal Award Identification Number: P425F201693 Federal Award Year: June 30, 2022 Condition: The College?s policies and procedures over procurement generally conform to the requirements outlined by the Uniform Guidance with an exception bonding requirements, contracting with small and minority businesses, and items from Appendix II to Part 200. The auditors compared the College?s policies and procedures to the applicable sections of the Uniform Guidance by reviewing two vendors of a total of four vendors with expenditure for the ESF funds and obtained the associated supporting documentation for our selections. Additionally, the auditors noted that the Institution?s procedures were not followed with regard to ensuring full and open competition, obtaining bids/quotes for the items above the micro-purchase threshold, or retaining documentation for the requirement for verifying for vendor suspension or debarment prior to contracting. The College did check for suspension/disbarment following our identification of the finding and there were no issues. The sample was not a statistically valid sample. Corrective Action Plan Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. Members of the College did not appropriately follow federal procurement guidelines related to costs that were included in the institutional reimbursement portion of HEERF funding. This was an oversight and occurred as a result of the timing of when the purchases were made, or the contracts were entered into, and when the HEERF funding and applicable guidance was communicated by the Department of Education. At the time the contracts were entered into, members of the College did appropriately review all contracts and the related costs for reasonableness to ensure that the College was being prudent with its financial resources, whether from the federal government or not. Members of the College have also reviewed SAM to ensure that these vendors were not suspended or debarred. The College?s federal procurement policies and procedures will be updated to ensure that all items from the Uniform Guidance are included and followed for all federal grants. Nathan Engle Controller