Corrective Action Plans

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2022 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2022-003 Description of Finding Procurement and Suspension and Debarment 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. EASTCONN should have internal controls designed to ensure compliance with those provisions. EASTCONN?s procurement standards do not include the required elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action EASTCONN?s Executive Director and the Board of Directors will review, revise, and approve an updated procurement policy to incorporate required elements of the Uniform Guidance related to expenditures funded with Federal Grants. Name of Contact Person Eric S. Protulis, Executive Director Projected Completion Date November 2023

Assistance Listings number and program name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Fund Contact: Maryn Belling Anticipated completion date: June 30, 2023 Corrective Action Plan: The County procurement officer will, in collaboration with responsible departments, follow County policies and procedures for determining and documenting each sole-source procurement including documenting the good-faith search for available sources, concluding a single source, and including the related documentation in the contract file. The Procurement Officer and departments responsible for procurement will participate in annual training about County policies and procedures regarding the determination and documentation of sole-source procurement.

2022-002 PROCUREMENT ? STATE ADMINISTRATIVE MATCHING GRANTS FOR SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP CLUSTER) Recommendation: It is recommended the County ensure they follow their countywide policies regarding federal procurement and retain documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will ensure they follow their federal procurement policy for purchases. Name of the contact person responsible for corrective action plan: Lindsey Meyer, Finance Director Planned completion date for corrective action plan: December 31, 2023

Finding 2022-002 Procurement Description of Finding The Town?s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326 and purchases were made that did not follow these requirements. Statement of Concurrence or Nonconcurrence Management agrees with this finding. Corrective Action: Corrective action will be taken to ensure the policy is updated and the correct procurement procedures are followed. Name of Contact Person: Edward B. St. John (475) 473-3352 Projected Completion Date: June 30, 2023

Finding No. 2022-007: Procurement Policy - Material Weakness in Internal Control Over Financial Reporting U.S. Department of Health and Human Services, Health Center Program Cluster; CDFA No. 93.224 Condition: There is no formal documentation or evidence to support that competitive price analysis for vendors selected by CCI several years ago or that suspension and debarment verifications were performed for vendors, as required by the general procurement standards of the Uniform Guidance. Recommendation: Marcum recommends that CCI update its existing procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. Marcum also recommend that a review of all vendor contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Action Taken: CCI is recommending to the board to update its procurement policy by obtaining at a minimum-three separate bids for anything above $50,000.00. We are also in the process of hiring a full-time purchasing manager to oversee procurement policy and strategy. Anticipated Completion/Implementation Date: End of fiscal year 2024.

Finding 2022-001 ? Suspension and Debarment Recommendations: The Board of Directors, the Director and key positions of management should re-assess the current board policy and potentially add encompassing compensating controls. The Board should then periodically check that all procedures agreed upon are operational and effective, and adjust procedures as needed. Action Taken: We agree with the recommendation and are set to re-address the board policy with board members, Business Director, Federal Funds Director, and Superintendent. Our targeted implementation date is March 2023.

Findings: 2022-003 Significant Deficiency in Internal Control over Compliance Personnel Responsible for Corrective Action: Kerry Romero, Director of Accounting Anticipated Completion Date: December 31, 2023 Condition: The Organization had not adopted a procurement policy and no procurement procedures were performed in selecting contractors. Corrective Action Plan: The Organization will develop and adopt a procurement policy that will include procedures for receiving competitive bids for the acquisition of property and/or services. The policy will include screening vendors to ensure eligibility. The Organization will ensure contracts include a conflict-of-interest clause.

Findings: 2022-002 Significant Deficiency in Internal Control over Compliance Personnel Responsible for Corrective Action: Kerry Romero, Director of Accounting Anticipated Completion Date: December 31, 2023 Condition: The Organization had not adopted a procurement policy and no procurement procedures were performed in selecting contractors. Corrective Action Plan: The Organization will develop and adopt a procurement policy that will include procedures for receiving competitive bids for the acquisition of property and/or services. The policy will include screening vendors to ensure eligibility. The Organization will ensure contracts include a conflict-of-interest clause.

Kittitas Reclamation District P.O. Box 276 Ellensburg, WA 98926 Phone: (509) 925-6158 Fax: (509) 925-7425 CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kittitas Reclamation District January 1, 2022 through December 31, 2022 This schedule presents the corrective action the District is planning to take for findings included 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: 2022-001 Finding caption: The District?s internal Controls were inadequate for ensuring it complied with federal procurement requirements. Name, address, and telephone of District contact person: Stacy Berg PO Box 276 Ellensburg, WA 98926 (509)925-6158 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Upon receiving the guidance on the current audit, the District would like to move forward by reviewing the procurement policy and making any necessary changes while working under the guidance of the SAO Procurement Specialist to ensure that an updated procurement policy continues to meet the needs of the District and the federal guidelines for federal funding. Anticipated date to complete the corrective action: September 30, 2023

Finding # 2022.001 Procurement and Suspension and Debarment Response Management acknowledges the condition related to following the organization?s procurement policy guidelines. Management is taking steps to correct this condition and has identified areas in the system that will be corrected in order to follow all Federal requirements related to procurement. For example, a member of the Finance department will complete procurement training at least once a year. The Finance Department will also train all Project Managers in Procurement Policies and Procedures as needed. Responsible Party David Ayala, CFO Estimated Completion 12/31/2023

FINDING 22-2: PROCUREMENT POLICIES AND PROCEDURES Condition The Institution?s procurement policies and procedures did not include certain aspects of the applicable federal regulations and other procurement requirements specific to the HEERF program, including the various thresholds for vendor selection and purchases (micro - purchase, small purchase, sealed bid, and simplified acquisition methods) and conflict of interest policies related to procurement. (See attachments)

Finding # 2022-001 Response Management agrees with the finding and recommendation and will update its procurement policy to comply with 2 CFR 200.318 through 2 CFR 200.327. Responsible Party Bobby Splinter Estimated Completion December 31, 2023

FEDERAL PROCUREMENT Name of contact person: Mayor and Clerk Corrective Action: The City understands and agrees that it must order a rule which governs the spending of federally procured recovery funds and grants. More specifically, said rule shall create a standard of conduct which prevents the bestowal of federally procured recovery funds based upon relationship rather than merit. See, Mont. Code Ann. ? 2-2-301. To that end, the City shall draft and pass via majority vote of City Council Members a resolution to address this issue which complies with State and Federal regulation of said funds. Said resolution will be passed in 2023 prior to the conclusion of the City's fiscal year. Proposed Completion Date: Fiscal Year 2023.

The Board will communicate procurement requirements to purchasing agents in order to avoid future misinterpretation and noncompliance. In most instances, evidence of procurement requirement compliance was observed, but not documented appropriately for compliance requirements.

Finding Number: 2022-001, 2021-001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Business Manager and Human Resources Manager Anticipated Completion Date: June 30, 2023 Planned Corrective Action: Vendors will go through the suspension and debarment process and business office staff will assist with the process. Sealed bids will be conducted in accordance with the School policy, and the Human Resources Manager will keep documentation of the sealed bid process. The School?s procurement policy over quotes will be refined and followed. The Business Manager will review the process with business office team and department supervisors.

Finding No. 2022-001: Procurement and Suspension and Debarment ? Significant Deficiency (Program Level) Finding: During testing the Federation?s controls on compliance over procurement and suspension and debarment, the Federation could not provide a procurement policy that is in compliance with prescribed standards in the Uniform Guidance. Corrective Actions Taken or Planned: Management will update its procurement policy to ensure it is in compliance with Uniform Guidance requirements and will take the additional steps of updating the policy as changes in the Uniform Guidance requirements occur. Review and monitoring is effective immediately and will be on-going beginning January 2023 and is expected to be completed by February 2023

Recommendation: We recommend the County management establish internal controls to ensure compliance with federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finance department has met with the IT department to discuss federal procurement requirements and possible checklists. Name of the contact person responsible for corrective action: Lisa Malinski, Finance Director

The Fremont County Clerk is responsible for paying the bills for the county and was not aware that we should be verifying the vendors that they were not debarred, suspended, or otherwise excluded per 2 CRF 200.318(h) and 2 CFR 180. We will set a policy to use going forward, that will be attached to the voucher for these vendors showing that we have done our due diligence in these matters. The proposed policy is to work with the Commissioners (who approve contracts), accounts payable department and Treasurer on steps to verify the companies upon the receipt of their contract. Contracts are approved by the County Attorney, and once they are approved, I will add a step to have a member of our staff do the verification and attach a form stating the date and outcome of the verification prior to accepting the contract by the vendor.

Finding No. 2022-004: Procurement Policy ? Material Weakness in Internal Control Over Financial Reporting; U.S. Department of Health and Human Services, Rare Disorders: Research, Surveillance, Health Promotion, and Education; Assistance Listing Number 93.315 Condition There is no evidence of a documented formal procurement policy with regards to federal grant awards and expenditures, no documented support that a competitive price analysis for vendors and organizations funded with federal grant funds were performed and no evidence that suspension and debarment verifications were performed for certain vendors and organizations, as required by the general procurement standards of the Uniform Guidance. Recommendation It was recommended that the Association establish a written procurement policy governing contracts with vendors that will be reimbursed by federal grants to incorporate all of the provisions included in the general procurement standards of the Uniform Guidance Section 200.318 and the debarment and suspension regulations of Uniform Guidance Section 200.214. It was also recommended that a review of all existing vendor or sub-awardee contract files be performed to ensure that the documentation as required under the Uniform Guidance is maintained in the files. Action Taken The Spina Bifida Association will take action to ensure an up-to-date Procurement Policy is approved by the Board of Directors. Anticipated Completion Date December 2023

The responsible officials within the Foundation acknowledge the findings from the 2022 audit related to our procurement practices under 2 CFR section 200.320. We understand the gravity of the situation, particularly considering that the Foundation did not have a formal procurement policy in place. To address the deficiencies identified in the audit, our planned corrective actions are foundational. Firstly, we will develop and implement a comprehensive procurement policy that adheres to the federal regulations specified in 2 CFR sections 200.318 through 200.326. This policy will provide clear and specific guidance on both competitive and noncompetitive procurement methods, establishing a framework for future procurement activities. Secondly, we recognize the paramount importance of robust documentation. Therefore, we will institute rigorous documentation procedures that mandate the thorough recording of the historical context and rationale for procurement decisions at the time of contract execution. This documentation will be meticulously maintained, adhering to the stringent requirements mandated by the federal regulations. Additionally, we will prioritize staff training to ensure that all personnel involved in the procurement process are well-informed about the new policy and are capable of consistently adhering to the documentation standards. These measures, including the creation of a procurement policy from the ground up, will enable us to rectify the audit findings promptly, establish compliance with federal regulations, and uphold the integrity of our federal award programs.

Significant Deficiency in Internal Controls ? Procurement, Suspension and Debarment Funding Agency: Department of Treasury Program: Emergency Rental Assistance Program Assistance Listing Number: 21.027 Criteria or Specific Requirement: Criteria or specific requirement: 2 CFR 200.318(i) states that "the non-Federal entity must maintain record sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price". In addition, 2 CFR 200.320(a)(2)(i) states that "... If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity". Per the Organization's written procurement policy, the adequate number of sources is determined to be three. Condition: For the entire population (two disbursements from one procurement), documentation was not retained for the adequate number of price comparisons prior to exercising the procurement, as required and stated in the Organization's written procurement policy. Context: A sample of two disbursements from a population of one procurement transaction charged to the major program that exceeded the Organization's established micropurchase threshold of $10,000. The transaction was found to be out of compliance with the Procurement requirements, as documentation was not retained for the adequate number of price comparisons. Questioned Costs: Undeterminable Cause/Effect:. An employee charged with the procurement process for these transactions misinterpreted the aggregation rules between capitalization and procurement thresholds, and therefore did not obtain nor retain three contemporaneous quotes. Without adequate records retained, the Organization is at risk of noncompliance with the standards of Procurement. Recommendation: Opportunity Council has already taken steps to communicate the error with the applicable employee and is currently implementing an additional level of fiscal review earlier in the procurement process to ensure that documentation exists prior to procurement and that it is retained with the accounting record. We recommend moving forward with the additional layer of review and emphasizing the importance of the procurement standards and established policy to all authorized purchasers within the Organization. View of Responsible Official and Corrective Action Management accepts the finding and is taking the following corrective action to prevent recurrence: ? Updating Organizational Policies to clearly permit a higher small purchases threshold, combined with annual certification of eligibility, to sharply decrease the likelihood of recurrence of the underlying cause of the finding. ? Implementing accounting system-level controls that will require an additional approval from assigned fiscal staff to transactions exceeding the small purchase threshold prior to payment, ensuring accountability for monitoring of required documentation for procurements in excess of the threshold. ? Procurement training planned throughout the agency to ensure that personnel authorized to initiate procurement transactions are aware of organizational policies and have the guidance necessary to comply with procurement rules.

SINGLE AUDIT FINDINGS: Finding 2022-002: Procurement and Suspension and Debarment Description of Finding: The Town?s procurement standards included an incorrect threshold for small purchases as outlined in 2 CFR sections 200.318 through 200.326 ($25,000 versus $10,000). Statement of Concurrence or Nonconcurrence: There is no disagreement with the audit finding. Corrective Action: The Town will review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Name of Contact Person: Susan E. Hale, Municipal Finance Officer Projected Completion Date: June 30, 2023

Finding Number: 2022-005 Condition: The Corporation's procurement procedures does not fully conform to the procurement standards identified in ?? 200.317 through 200.327. Planned Corrective Action: The procurement policies will be revised and additional education will be conducted for those individuals responsible for the procurement process. Contact person responsible for corrective action: Kristen St. Peter Anticipated Completion Date: June 2023 Management Response: Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.

Higher Education Emergency Relief Fund ? Assistance Listing No.: 84.425F Recommendation: We recommend that the University establish a process where when the SAM.gov check is performed, evidence is retained to show that this was completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The procurement policy for Federal Grants will be revised to include the process of how to have a SAM.gov check performed and documented for evidence, as well as include procedures for the procurement of goods over $250,000. At this time, with the HEERF grant completely spent, there are no other Federal grants in place where the SAM.gov check would be required. However, the revised policy will be communicated to department managers for future federal grant awards. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: June 1, 2023

U.S. DEPARTMENT OF TREASURY 2022-001 Coronavirus State and Local Fiscal Recovery Funds- ALN No. 21.027 Recommendation: We recommend the Town design and document a procurement policy in accordance with the compliance requirements outlined in Title 2 of the U.S. Code of Federal Regulations part 200.318. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We agree with the auditor?s findings. Management will design a formal procurement policy. Name(s) of the contact person(s) responsible for corrective action: Sue Nickerson, Town Accountant. Planned completion date for corrective action plan: Immediately.