Corrective Action Plans

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action; Brian Tomamichel, Chief Financial Officer Contact Phone Number: 317-867-8013 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Westfield Washington Schools will be hiring a Director of Food Service to oversee our current food service management company. With this hire the district will ensure that this individual is routinely trained on procurement, contract approval, and any other necessary items to ensure that all Federal Uniform Guidance requirements such as suspension and debarment checks are performed prior to awarding contract. Anticipated Completion Date: June 2023

2022-001: Procurement Requirements Criteria: The Organization is required to establish a procurement policy in accordance with Uniform Guidance requirements, as specified in the compliance supplement. Condition: The Organization did not establish a procurement policy in accordance with Uniform Guidance 2 CFR 200.318 ? 200.327, as required for the major program. The Organization developed and implemented a policy during 2022 but it was not in effect for the whole organization for the entire year. Questioned costs: None Cause and Effect: By not having an updated procurement policy the Organization could expense funds that are not in accordance with the procurement policies established by Uniform Guidance. Corrective Plan: Midwest Food Bank NFP established a procurement policy in accordance with Uniform Guidance in 2022 to be fully implemented across the Organization with an effective date of January 1, 2023, led by Lisa Martin, CFO.

SEE ATTACHED

The City has identified federal grants subject to the Uniform Guidance and will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.

The City will develop written standards of conduct in that satisfy the requirements of 2 CFR § 200.318(c)(1).

The Grants Finance Department, Purchasing Department along with the Federal Grants Department will review_vendors that are issued requisitions at each approval level to assist in catching $25K or more for Suspension and_Debarment. A printed document from SAM.GOV verifying eligibility to Requisitions over $25K should be attached._At the initial setup of new vendors, the Purchasing Department will review vendors in SAM.GOV. A printed document_from SAM.GOV verifying eligibility of vendor will be attached to the vendor file.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Grant Transit Authority January 1, 2022 through December 31, 2022 This schedule presents the corrective action planned by the Authority 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: 2022-001 Finding caption: The Transit Authority’s internal controls were inadequate for ensuring compliance with federal procurement, suspension and debarment requirements. Name, address, and telephone of Authority contact person: Stephanie Guettinger PO Box 870, Moses Lake, WA 98837 (509) 766-1663 Corrective action the auditee plans to take in response to the finding: Suspension and Debarment – The Grant Transit Authority (GTA) currently and during the audit period has measures in place for searching SAM.gov for all purchases $25,000 and greater when using Federal funds prior to entering a purchase contract. The GTA has now implemented a process of date stamping the printout from Sam.gov when the search results documents are printed. Additionally, the GTA will ensure that the document is saved in their documents on the date ran, to further verify the date the document was obtained. As a third verification, WSDOT now requires agencies to submit the SAM.gov printout in the approval package submitted to them so that they can verify and ensure the search was completed prior to their approving the agency procurement. Procurement – The Grant Transit Authority (GTA) is currently in the process of updating its written procurement policy to conform with Uniform Guidance (2 CFR 200.318-327) for all procurement activities. Included within the updated policy are procedures to follow for each procurement type to ensure all GTA Management and/or staff have written procedures to reference to and follow when conducting the various procurement types. The updating of the procurement policy with included procedures, shall provide guidance and assist in ensuring that the GTA is procuring goods and services in accordance with federal regulations, state law, as well as its own policies and procedures. Anticipated date to complete the corrective action: 4/01/2024. The Suspension and Debarment recommendation is currently being followed by the GTA with the corrective action already implemented. The GTA is diligently working on the procurement policy updates with established procedures and will submit to the Board of Directors for Board approval, prior to April 1, 2024.

Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. Name and Title of Responsible Official: Michael Stock, Board Chairman Planned Completion Date: Immediately.

U.S. Department of Health and Human Services Passed through Health Research & Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity, and Security Finding Summary: The Organization’s procurement policy does not contain all provisions required by Appendix II to 2 CFR Part 200. Additionally, there was no documentation retained supporting a price analysis over the transactions tested. Management’s Response and Corrective Action Plan: We are working to implement additional controls where policies are reviewed in depth and are current in order to ensure procurement, suspension, and debarment policies are properly complied with and documented. Responsible Individuals: Rufus Glasper, President and CEO, and Cynthia Wilson, Vice President for Learning and Chief Impact Officer Anticipated Completion Date: January 2024

We agree with this audit finding. Sallal developed, and the Board of Trustees adopted a procurement policy in December 2022 that complies with procurement standards established in 2 CFR sections 200.318 through 200.326. The procurement policy will be in place going forward.

Views of Responsible Officials and Planned Corrective Actions: USTTI will formalize a compliance process to be in compliance with 2 CFR 200. USTTI management will then distribute and communicate the policy with all USTTI employees. USTTI management will ensure the policy is properly enforced and that all procurement actions are documents in writing in vendor and contractor files.

2022-009 – SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM CLUSTER – SUSPENSION AND DEBARMENT U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Passed Through Minnesota Department of Human Services Pass Through Number: H55210010 Award Period: 2022 Recommendation: We recommend that the County ensure it is either checking sam.gov and documenting that check or has a contract in place with the required self-certification language for each vendor paid over $25,000 for a type of service or item that was paid for in whole or in part by federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: This is now a standard practice in the contracting process that is managed by the Community Services Contracts Department. Any contract that EEA may need to enter in to must flow through the contracts team and as such, it will follow this recommendation. Name of the contact person responsible for corrective action: Daren Nyquist, Administration Manager Planned completion date for corrective action plan: December 31, 2023

The Town will be updating the Town's procedures and policies to incorporate the requirements of Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Responsible Individual: Patricia Chaffee, Executive Assistant. Anticipated Completion Date: January 30, 2024.

Criteria: In accordance with CFR 200.318(i), 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. In addition, in accordance with CFR 200.318(a) the nonfederal entity must have and use documented procurement procedures consistent with federal procurement standards. Condition: Expenditures tested that met the small purchase threshold (purchases with a cost between $10,000 and $250,000) did not have documentation detailing the history of procurement. Cause: The School does not have procurement policies that follow federal guidelines, specifically 2 CFR 200.320 Methods of procurement to be followed. Effect: Property and equipment additions made using federal funds during the year did not have appropriate a support showing procurement policies were followed. Questioned costs: $83,864 Context: Two out of two purchases tested for procurement did not follow federal procurement methods. Recommendation: We recommend that the School institute procurement policies whereby acquisitions follow appropriate procurement steps as required by 2 CRF 200.350 and documentation of procurement decisions is maintained. Action Plan: The School will develop a Procurement Policy that follows the formal bid process and ensures that the school is able to acquire goods based on the most advantageous balance of price, quality, and performance. The School will maintain procurement decision records in vendor files. Person Responsible: Yvonne Bullock, CEO/Head of School Policies are approved by the Board of Directors

FINDING 2022-005 Craig Wright (765)747-4828 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: Correcting the audit findings is ongoing. The city has implemented monitoring procedures to review and prevent reoccurring errors. Anticipated Completion Date: The internal control monitoring and checks and balances will be implemented immediately and continue going forward.

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation did not retain documentation to support performance of a price analysis nor provide the opportunity for open competition. Additionally, the Foundation did not review for suspension or debarment and required contract provisions were not followed. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will retain and catalog documentation related to price quotes for certain Foundation expenditures. We will update our procurement policy to be consistent with federal guidelines to assist in streamlining the procurement process. We have hired a Grant Administrator and Analyst who is responsible for reviewing contractors against the System for Award Management for suspension or debarment, including subrecipients. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: January 2024

The Council began a building renovation project before it became aware that funds were available to support the project. Therefore, the Council was not able to comply with regulations at the time of project design, bidding, planning, and construction. In addition, the Council’s project was only partially funded by the Coronavirus Recovery Funds, the majority of the project was funded through the Council’s fundraising efforts. Management agrees with the finding and is in the process of implementing the recommended procedures for future projects.

Our Associate Director, Business Director and Operations Director will attend procurement, suspension, and debarment training to better learn the 2 CFR sections 200.318 through 200.326. Upon training completion, the team will provide the Finance Committee of the Board of Directors suggested updates to our current policy.

Management Comments and Corrective Action: During the course of the single audit for the year ending August 31, 2022, it was noted that SWK "legacy" contracts did not follow the established procurement policy and procedures which requires SWK to obtain quotes from at least three sources and/or did not document the quotations in the procurement file for one expenditure between $25,000 to $100,000. This instance of noncompliance noted was for a consumer goods (i.e., clothing, and personal healthcare). Due to the growing need to adequately care for the minors at SWK’s shelters coupled with the limitations of access to vendors caused by COVID-19, SWK utilized an existing vendor to minimize significant disruptions to operations. The Organization is aware they are operating under contracts that were procured in previous years that may not have all the records maintained. Reprocuring all of these contracts at once would potentially cause disruptions in operations due to the products/services related those vendors playing an important role in the Organization’s day-to-day operations. In April 2021, the Organization, hired new procurement leadership and invested Full Time Employees (FTEs) to develop a robust procurement department. As a result of this procurement revamp, Procurement adopted a hybrid model, and Desktop Protocols were established to provide universal procedures to fulfill policy. Protocols instruct staff on obtaining three quotes and provided tools for the selection of the vendor. In addition, quality protocols and tools are currently in development to verify a random sample of procurement transactions and files. The Organization still has several active contracts procured under the old policies that they are working on reprocuring as these contracts’ renewal dates arise, if not earlier. Proposed Implementation Date of Corrective Action: In process and to be completed by December 31, 2023. Person Responsible for Corrective Action: Fred Muniz, CFO 2023

Item: 2022-004 Assistance Listing Number: 21.027 Programs: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: Arizona State Office of the Governor; Maricopa County Pass-Through Grantor Identifying Number: Unknown Award Year: January 1, 2022 to December 31, 2024; January 28, 2022 to June 30, 2023 Criteria: In accordance with 2 CFR § 200.318 - General procurement standards - the entity must use its own documented procurement procedures which reflect applicable. State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in 2 CFR § 200.318. Condition: The entity does not have a documented procurement policy and procedures that address the provisions of 2 CFR § 200.318 Name of Contact Person: Doug Taylor, CFO Phone Number: (602) 230-1116 Anticipated Completion Date: Completed Views of Responsible Officials and Corrective Actions: Special Olympics Arizona, Inc. will document in writing its previously unwritten policies and procedures to ensure adherence to the procurement policies that conform to 2 CFR § 200.318.

The County Council and County Executive will work through the Audit Committee and Policy Review Committee to review, update, and strengthen policies and internal controls related to County and Federal procurement policies. The County will provide sufficient training and resources for staff to make sure all County and Federal procurement policies are followed correctly. The County will also monitor these processes through internal audit procedures

Views of Responsible Officials: SAMU had a workshop for procurement practices together with Project Hope back in October/November 2022. The procurement process of Services and (nonrecurring) Goods has been updated in May/June 2023. Therein all the requirements were explained to fulfill the procurement standards established by 2 CFR 200.318. In the meantime, all procurement specialists have been advised to request a minimum of three formal quotes for procurements above $10,000, once those have been received and a proposal with an explanation (via email) of why a certain vendor has been preselected to provide the services and goods in question. With this information, the MD and Finance/Admin head are asked for internal approval and process the procurement of the Services and Goods. The approval is provided by email. An updated procurement policy is in preparation, the procurement process will be discussed again in another workshop in Q1 2024.

Views of Responsible Officials: A detailed Procurement process currently exists; however, due to staff attrition we were unable locate all the procurement documentation requested. We will continue to reinforce our Procurement policy (detailed below as it relates to documentation) and now require all documentation be stored in a Central location for all applicable Finance staff. E. Procurement Records and Files: 1. Mary's Center will establish and maintain procurement records and files. The records will be kept in the office of the Chief Executive Officer and/or Finance office and virtual copies will be stored on the Finance shared folder. 2. Mary's Center will document in the procurement files some form of cost or price analysis made in connection with every procurement action. 3. For any contracted service (other than equipment-specific technical support), Mary's Center procurement file will include:  Basis for selection of the contractor,  Justification for lack of competition when competitive bids or prices are not obtained, and  Basis for award cost or price. 4. These records and files will be kept in accordance with Mary's Center's Record Retention and Document Destruction Policy.

Compliance Finding The City's procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. In Fiscal 2023, policies and procedures for expending federal funds were updated to include requisite review and documentation of said review during the awarding of contracts and prior to submitting invoices for approval.

FA 2022-002 Strengthen Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1199; 225GA324N1199 Questioned Costs: $474 Description: A review of expenditures charged to the Child Nutrition 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: The School District has returned to following its approved procurement procedures. Estimated Completion Date: July 1, 2023 Contact Person: Chris Johnson, CGFM, Director of Financial Services Telephone: 478-994-2031 Email: chris.johnson@mcschools.org