Corrective Action Plans

FEDERAL AWARDS – CORRECTIVE ACTION PLAN 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. (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: Condition: 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 five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 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) Use documented 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 must maintain records sufficient to detail the history of procurement. These records should 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. 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: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Denise Watters, CEO Anticipated Completion Date: December 2023 Planned Corrective Action: The Club will take immediate steps to strengthen its internal controls related to procurement of goods and services. This includes the revision of our written procurement standards to align them with federal regulations and guidelines. Additionally, we will establish procedures for maintaining adequate supporting documentation that demonstrates compliance with federal procurement standards. To ensure compliance with the prohibition on contracting with suspended or debarred parties, we will verify the status of entities with whom we enter into covered transactions using methods such as checking the System of Award Management (SAM) or collecting certifications. Responsible officials will oversee the plan's implementation, and we will maintain comprehensive records to demonstrate our commitment to adhering to federal procurement regulations and guidelines. This corrective action plan is vital to achieving and sustaining compliance with federal procurement standards.

Finding ref number: 2022-001 Finding caption: The District’s internal controls were inadequate for ensuring compliance with federal requirements for procurement, and suspension and debarment requirements. Name, address, and telephone of District contact person: Mark Prugar, President P.O. Box 2593 Friday Harbor, WA 98250 (317) 509-5952 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). CPWD will revise the District’s Policy 005 “Bids and Purchase” to add a specific section for all procurements that utilize Federal Funds to also include references to 2 CFR 200.318-327. Furthermore, Policy 005 will be revised to ensure that the District employs procedures (e.g. SAM investigation, contractor certification, or contractual clauses) to verify that perspective contractors are not suspended, debarred, or otherwise excluded from participating in federal programs when contracting for Goods and Services in excess of $25,000 in value. Anticipated date to complete the corrective action: Formally adopt revised Policy 005 at next Commissioners’ meeting – 18 October 2023

Action taken in response to finding: A Federal Procurement Checklist which addresses the above finding has been distributed to all County departments who receive grant funding. The County will implement this Checklist into its internal County Procurement Ordinance, Procurement policies & Procedures, and Grant Administration forms. Name(s) of the contact person(s) responsible for corrective action: Eric Black, Chief Deputy Auditor. Planned completion date for corrective action plan: November 30, 2023

Action taken in response to finding: We will supplement our procurement policy to address requirements specific to federal awards. Name of the contact person responsible for corrective action: Renee La Fleur Planned completion date for corrective action plan: October 2023 If the U.S. Department of Health and Human Services has questions regarding this plan, please call Renee La Fleur at 414-930-9210.

Corrective Action Plan for the Calendar Year Ended December 31, 2022 In response to the finding from the Federal single audit for the fiscal year ended December 31, 2022. Major Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) (G2022-09) Finding: 2022-002 - Reporting and Procurement (Material Weakness and Material Non-Compliance) Management Response: Management will strengthen its processes and internal controls to ensure the report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. In addition, Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards. Christopher Caulfield, Executive Director of Financial Operations, will implement the corrective action plan, which is anticipated to be completed by December 31, 2023. caulfieldc@sihmc.org 973-754-2016

The District is committed to following all State and Federal procurement standards in its solicitation to secure goods and services. As indicated in the District response, the procurement of both items presented unique circumstances that affected the solicitation of a contractor for the renovation (project size) and a vendor to supply the specialty good. The District believes due diligence was followed in each procurement action through thorough research and cost benefit analysis prior to making a vendor selection. The District will ensure staff participate in the recommended State sponsored procurement training. Estimated time for completeion is May 31, 2024. Update its procurement policy to ensure compliance with state requirements. Estimated time for completion November 30, 2023.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Renton 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: 2022-001 Finding caption: The City’s internal controls were inadequate for ensuring compliance with procurement and suspension and debarment requirements. Name, address, and telephone of City contact person: Kristin Trivelas, Fiscal Services Director 1055 S Grady Way, Renton WA 98055 (425) 430-6929 Corrective action the auditee plans to take in response to the finding: • The City will strengthen its policy and procedures that govern the use of federal funds to ensure they reflect local, state and federal procurement requirements; compliance to these guidelines shall be organization wide and will seek to ensure that there is a uniform understanding across multiple departments who may have federal funding resources. • When possible, the City will get approval from awarding agencies of all contracts and procurement processes prior to entering contracts that will or may be funded by federal grants. • Procedures will be updated to ensure that contractors and consultants working on federally funded projects are not suspended or debarred by requiring documentation in the form of one or more of the following: documentation of City staff search results for suspension and debarment status, stand-alone certification from the contracting entity, and/or a certification clause within the contract with the entity. • The City will conduct federal grant training workshops to educate staff on uniform guidance, to include the varying levels of federal procurement and associated requirements and documentation; the City will mandate completion of training before employees are authorized to seek or manage federal grants Anticipated date to complete the corrective action: 09/30/2024 and ongoing

Vendors will be reviewed and documented that they are not debarred, suspended, or otherwise excluded from participation in federal award programs by use of the System for Award Management (SAM), the Official U.S. Government system. [New procedure implemented]

Department of Housing and Urban Development and Department of Veterans Affairs Federal Program Name: Emergency Solutions Grant Program and VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 14.231 and 64.024 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has developed and implemented a formal written procurement policy aligned with applicable federal requirements and organizational purchasing practices. The policy includes required procurement methods, thresholds, documentation standards, conflict-of interest provisions, and approval authority levels. In addition, the Organization has implemented internal monitoring controls to track cumulative vendor spending throughout the fiscal year and to ensure that procurement procedures are properly initiated when vendor costs approach or exceed established procurement thresholds. Staff responsible for purchasing and vendor management have been trained on the updated requirements and documentation expectations. Name(s) of the contact person(s) responsible for corrective action: Ryan Ross, Executive Director Planned completion date for corrective action plan: March 31, 2026

Stevens County January 1, 2021 through December 31, 2021 This schedule presents the corrective action planned by the County 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: 2021-001 Finding caption: The County’s internal controls were inadequate for ensuring compliance with federal procurement requirements. Name, address, and telephone of County contact person: Lori Larsen, County Auditor (509) 684-7511 215 S Oak St. Colville, WA 99114 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 non-concurrence). Stevens County will review and update the County's procurement policies to be compliance 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). Anticipated date to complete the corrective action: December 1, 2022

CONDITION: The City of McKeesport contracted with Applied Concepts, Inc. for police trailers, and A&H Equipment for the purchase of a vactor truck. These contracts individually exceeded the Uniform Guidance micro purchase threshold of $10,000, but did not exceed the Simplified Acquisition Threshold of $250,000. Both of these purchases were procured through a cooperative purchasing group (COSTARS). The City was unable to 1) provide records sufficient to detail the history of procurement for these two contracts and 2) provide documentation to verify that price or rate quotations were obtained from an adequate number of qualified sources.CRITERIA: Section 2 CFR 200.320(a)(2)(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a non-federal entity whereby the cost exceeds certain dollar thresholds as adjusted periodically. In instances where the cost incurred exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, price or rate quotations must be obtained from an adequate number of qualified sources. In addition, as specified in 2 CFR 200. 318(i) of the Uniform Guidance, the City must maintain sufficient records to detail the history of procurement. • MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will review and update as necessary its procurement policies to ensure In instances where the procurement cost incurred for goods and/or services exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, that 1) price or rate quotations are obtained from an adequate number of qualified sources, and 2) sufficient records are maintained to detail the history of procurement. The timeframe for completion of this review will occur during the first nine months of calendar year 2025 with the intention of having the City be in full compliance with Sections 2 CFR 200.320(a)(2)(i) and 2 CFR 200. 318(i) of the Uniform Guidance.

Persons responsible for corrective action: Bob Harmon, Superintendent Corrective Action: The School implemented an electronic procurement system. This system provides clarity with the documentation and approval of procurements. The transition from paper to digital formats will provide enhanced internal controls to ensure that procurement transactions are documented and approved. Training will also be provided to staff involved with the procurement process to ensure that all are informed with the Federal and School requirements. Implementation date: June 30, 2025

Preparation of written federal procurement procedures for compliance purposes

2021-002 Special Education Cluster - CFDA No. 84.027 and 84.173 Recommendation: We recommend procedures to maintain records sufficient to detail the history of all procurements be strengthened. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As of 7/1/2022, Framingham Public Schools will no longer claim the Massachusetts Chapter 30B SPED exemption (Appendix A. #8 & #22) for any SPED contracts being paid with federal funds. Instead, these contracts will be subject to the standard Chapter 30B procurement policies. FPS Executive Director of Finance and Operations, Lincoln Lynch IV, will meet with Director of SPED, Laura Spear, and City of Framingham Chief Procurement Officer, Jennifer Pratt, to make them aware of this finding and request that 1) all SPED grant funded contracts going forward will follow standard Chapter 30-B procurement policies and 2) City of Framingham updates their accounting procedures/procurement policies to reflect this change by 7/1/2022. Name(s) of the contact person(s) responsible for corrective action: Lincoln Lynch, IV - Executive Director of Finance and Operations Framingham Public Schools Planned completion date for corrective action plan: In progress with a start date of 7/1/2022.

Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Management Response: We acknowledge the finding and provide the following corrective action plan. Corrective Action Plan: PDA worked with Clark Nuber team to revise and update the procurement policy to be in-line with the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards procurement standards. Anticipated completion date: Third quarter 2024 Name(s) of the contact person(s) responsible for corrective action: Co-Executive Directors, Directors, Finance team

Finding ref number: 2021-002 Finding caption: The Town did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of Town contact person: Randy Kilmer, Clerk Treasurer PO Box 278 Twisp, WA 98856 (509) 997-4081 Corrective action the auditee plans to take in response to the finding: The Town of Twisp agrees with the findings as presented and has committed to adopting policy as recommended by the State Auditor’s office in accordance with the BARS manual, implementing internal controls for federal expenditures and annual reporting. As this audit occurred in the 2023/24 fiscal year, it will not be possible to have these changes in place in at the time of this audit. Anticipated date to complete the corrective action: No later than 12/31/24

In each of our districts we will practice oversight and due diligence over the documentation of Disaster Grant expenditures. We will review documents to ensure labor rates and equipment rates were those approved FEMA. We will acknowledge our review by signing the documents.

Finding No.: 2021-037 AL Program: 97.030 - Community Disaster Loans Area: Procurement and Suspension and Debarment Questioned Costs: $18,353,963 Contact Person(s): Ryan Camacho, Sr. Financial Analyst / Pam Marigmen, Sr. Financial Analyst, SOF Office / Brien Nicholas, Procurement Services Corrective Action Plan: Condition 1: The Department of Finance – Procurement Services agrees with this finding. For 709918-000 OP - Gov's Executive Order #2022-04 was issued renewing the declaration of State of Public Health Emergency establishing response, quarantine, and preventive containment measures concerning Corona Virus Disease 2019 (COVID-19) and renewing the order directing the CNMI Homeland Security & Management Office, through the CNMI COVID-19 Task Force, and in partnership with CHCC. The Emergency Contract does not require the PS Director’s signature. The Emergency Contract was created by HSEM and is a template being used when an Emergency Declaration is in effect. The person who prepared the Emergency Contract made an error in selecting the procurement method as it should have been selected as Emergency Procurement instead of Competitive Sealed Proposal. This PO was issued to exercise the option to extend performance provided for in COVID19-0163 and provide the Commonwealth with 40,800 square feet of warehouse space for staging and distribution of supplies, equipment, and other necessary support items including electricity (power) as well as other amenities in the initial contract. For 719000-000 OP / 723730-000 OP - Gov's Executive Order #2022-04 was issued renewing the declaration of State of Public Health Emergency establishing response, quarantine, and preventive containment measures concerning Corona Virus Disease 2019 (COVID-19) and renewing the order directing the CNMI Homeland Security & Management Office, through the CNMI COVID-19 Task Force, and in partnership with CHCC. The Emergency Contract does not require the PS Director's signature. The Emergency Contract was created by HSEM and is a template being used when an Emergency arises. The person who prepared this contract should have selected the Emergency Procurement instead of Competitive Sealed Proposal. For 714181-000 OP - Payment for Blocked rooms needed for Medical Referral Patients in San Diego, California. No justification was provided as it was approved by former Governor Torres. For 707002-000 OP - Gov's Executive Order #2022-04 was issued renewing the declaration of State of Public Health Emergency establishing response, quarantine, and preventive containment measures concerning Corona Virus Disease 2019 (COVID-19) and renewing the order directing the CNMI Homeland Security & Management Office, through the CNMI COVID-19 Task Force, and in partnership with CHCC. The Emergency Contract does not require the PS Director's signature. The person who prepared this contract failed to select any procurement method on the emergency contract. For 698865-000 OP - Gov's Executive Order #2022-04 was issued renewing the declaration of State of Public Health Emergency establishing response, quarantine, and preventive containment measures concerning Corona Virus Disease 2019 (COVID-19) and renewing the order directing the CNMI Homeland Security & Management Office, through the CNMI COVID-19 Task Force, and in partnership with CHCC. The Emergency Contract does not require the PS Director's signature. For 698605-000 OP / 698865-000 OP - Gov's Executive Order #2022-04 was issued renewing the declaration of State of Public Health Emergency establishing response, quarantine, and preventive containment measures concerning Corona Virus Disease 2019 (COVID-19) and renewing the order directing the CNMI Homeland Security & Management Office, through the CNMI COVID-19 Task Force, and in partnership with CHCC. The Emergency Contract does not require the PS Director's signature. Condition 2: The Department of Finance – Procurement Services disagrees with this finding. For 715112-000 OP / 727492-000 OP / 730942-000 OP. These three purchase orders were provided in the list for ALN 97.030 and were available for testing during auditor fieldwork. Auditors failed to perform the required testing. Proposed Completion Date: Ongoing

Finding No.: 2021-032 AL Program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Procurement and Suspension and Debarment Questioned Costs: $2,775,965 Contact Person(s): Ryan Camacho, Sr. Financial Analyst / Pam Marigmen, Sr. Financial Analyst, SOF Office / Brien Nicholas, Procurement Services Corrective Action Plan: Condition 1: The Department of Finance – Procurement Services disagrees with this finding. No procurement documents were provided because these thirty-four transactions were for payments made out for Travel, Medical Referral Patients, etc. Condition 2: The Department of Finance – Procurement Services agrees with this finding. The supporting documents were subsequently located. PO #725713-OP - FUJI Pacific - Office Space Rental. Copy of purchase order is available for inspection. Condition 3: The Department of Finance – Procurement Services disagrees with these findings. For 732176-000 OP $13,440 - No other quotes provided as it was the PS Acting Director's (FC Aguon) discretion, and the purchase requisition was approved by the former SOF (D. Atalig). For 724870-000 OP $8,789 - No other quotes provided as it was the PS Acting Director's (FC Aguon) discretion, and the purchase requisition was approved by the former SOF (D. Atalig). The Emergency Declaration suspended the procurement regulations and authorized the Expenditure Authority to procure any items/procure services exceeding the threshold without obtaining any price quotes. For PO #732176 & 728470, these are not part of the Gov’s Executive Order #2022-04. The Division of Procurement Services will accept the findings as noncompliance with the CNMI Procurement Regulations. Condition 4: The Department of Finance – Procurement Services agrees with these findings. For 726353-000 OP - No quotes were obtained. (FCA) former Acting Director of PS was off island. No DOA given for PS. The former SOF, David Atalig signed the requisition and M. Torres signed the P.O. We weren’t given ample time to seek legal advice from the Attorney General because we were instructed to process this request ASAP. However, moving forward we will advise the Agency to follow the Procurement Regulations regardless of Authority. We will send an LSR to the Attorney General and place the request on hold until we receive legal advice to proceed forward. For 727542-000 OP - No quotes were obtained. (FCA) former Acting Director of PS was off island. No DOA given for PS. M. Torres signed the requisition and the former SOF, David Atalig signed the P.O. For 727113-OC - FCA, the former Acting Director of PS was off-island, and no DOA was given to PS. Both D. Atalig and M. Torres signed the contract. Condition 5: The Department of Finance – Procurement Services agrees with these findings. This transaction doesn't relate to Procurement Services and is not a procurement matter. Donation/Gov's Office - September 2021 Heritage Month. Proposed Completion Date: Ongoing

Finding No.: 2021-020 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Procurement and Suspension and Debarment Questioned Costs: $1,240,465 Contact Person(s): Nerissa Benavente Karakaya, CIP COTR Corrective Action Plan: Condition 1: The Office of Grants Management (with the assistance of Procurement Services) agrees with the finding. The procurement processes are currently being revamped and with the implementation of the Tyler Munis system, procurement related documentation will be uploaded to the system and available for the Auditors to review. Condition 2: The CIP Office disagrees with this finding. The Capital Improvement Program provided information regarding these question costs. Please see the attached bid documents, bid submissions, and advertisement. For 703-OS/32200344 - RFQ20-GOV-084 was provided to the Auditor for their review. Three (3) proposers submitted - SP Dancoe & Associates; Marianas GeoTech Services; TRL Architecture & Pacific Engineering Group & Services. For 702-OS/32200912 - The procurement method for this was processed through a Sole Source. For CUC-WW-18-C032 - Lower Base Sewer Phase 1 - Lift Station and Focemain - This contract was executed by the Commonwealth Utilities Corporation on July 12, 2018. Procurement Services was able to obtain a copy of the contract from CUC to satisfy the audit testing. For 712727-OC (ITB20-DLNR/DOA-098) - Purchase of One (1) 13" Chipper Machine. Two bidders responded to this ITB; Boyer Trading Company & J. & J Company. Boyer Trading was selected as the lowest and responsive bidder. Condition 3: Document #1561570 ($2,500) and Document # 1573947 ($2,500): The Office of Grants Management disagrees with these findings because these are Open Accounts, and this would mean that no price quotations were required during the purchase requisition process in order to obtain the purchase orders. As confirmed by Financial Services and Procurement Services, quotations were not required on an open account. Open accounts were allowed during the JD Edwards period and were discontinued after September 30, 2021. MUNIS was implemented in October 2021. Condition 4: Document #333922 ($1,194,578): The Office of Grants Management (assisting DHSEM) disagrees with the finding because assigned personnel were not made aware of the documents needed; however, OGM is more than happy to provide the following documents to substantiate the purchase of a mobile Covid-19 Biological Safety Lab for the Commonwealth Healthcare Center and for the Alternate Care Site at Kanoa Resort. Per the documentation, the Public Assistance Office and DHSEM followed competitive procurement processing and invoked the Public Health Emergency Executive Order#2020-04 and to which the CNMI Attorney General’s Office approved the purchase. Purchase Order # 708019 was used by the Department of Homeland Security and Emergency Management and the Covid-19 Task Force. Contract number Covid19-0-0626 is attached for your reference. Expenses were later transferred to Department of the Interior CARES Act Funds under D20AP00049 per OGM Memo Number 2021-013. Proposed Completion Date: Ongoing

Finding No.: 2021-013 AL Program: 10.539 - CNMI Nutrition Assistance Area: Procurement and Suspension and Debarment Questioned Costs: $97,850 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: Condition 1: The CNMI-NAP disagrees with the finding. This transaction was supposed to be process in FY 2020 but because of the delay and completion date was done in FY 2021, a Change Order Contract No. 01 was processed, and the funds was carried over to FY 2021 (see attached copies of original contract and the change order. The Account number A1551L is a carryover account number from FY 2020 to FY 2021. Copy of the bid is also attached. The bid summary was not necessary because a change order was processed changing the account from A0551E to A1551L per NAP email dated 1/11/21 (Pending Change Order Contract) - CNC 01/13/21 Change Order #1 to charge $35,989.60 (Contract #707410-OC) to A1551L.64560 to extend the delivery period from thirty (30) days to ninety (90) days. (Researched in JDE and found the remarks made by Ms. Cozy N. Camacho - Financial Management) Condition 2: The CNMI-NAP disagrees with the finding. The Nutrition Assistance Program did follow the proper procurement method by processing Invitation to Bid and obtained the lowest bidder and processed the contract with a notice to proceed, please see attached copy of the Contract and the Summary of the bidders to prove that it went through the proper procurement process. Condition 3: The CNMI-NAP disagrees with the finding. The Nutrition Assistance Program tried to obtain quotations to purchase perforator machines on island and there was none. However, ARMATECH company submitted their price quotation stating that they are able to from off-island and NAP can purchase from them. Proposed Completion Date: Ongoing

CONDITION: The Cambria Heights School District contracted with a third-party vendor (Trafera) for the purchase of technology equipment. The contract with Trafera was procured through a cooperative purchasing group (COSTARS). The District did not obtain an adequate number of price or rate quotations for the technology equipment as required by the Uniform Guidance and 24 PS 8.807.1. CRITERIA: As specified in Section 2 CFR 200. 318(i) of the Uniform Guidance, the District 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, small purchase procedures per Section 2 CFR 200.320(a)(2)(i) for acquisitions between the micro-purchase threshold (currently $10,000) and the simplified acquisition threshold (current $250,000), price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate. Per 24 PS 8.807.1, there should be three quotes that are either written or well documented. The use of COSTARS only constitutes one quotation. RECOMMENDATION: I recommend that the School District update their policies to include those most recent related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i). In addition, I would recommend that District personnel responsible for expenditures related to federal funding receive updated training related to ‘procurement’ policies and procedures as they relate to federal funding. MANAGEMENT’S PLANNED CORRECTIVE ACTION: Management of the School District will review and update as necessary its ‘federal fiscal compliance policies’ to comply with the requirements of the Uniform Guidance. Particularly as it relates to procurement procedures to address the requirements of Section 2 CFR 200.318(i) and 2 CFR.320(a)(2)(i). In addition, management of the District will obtain training where available and applicable to enhance their internal controls over the management of federal program funds. The District’s timeframe for implementation is effective immediately.

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘CJAWS, Inc.’ totaling $140,389. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that the School District update their policies to include those most recent related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). In addition, I would recommend that District personnel responsible for expenditures related to federal funding receive updated training related to ‘procurement’ policies and procedures as they relate to federal funding. MANAGEMENT’S PLANNED CORRECTIVE ACTION: Management of the School District will review and update as necessary its ‘federal fiscal compliance policies’ to comply with the requirements of the Uniform Guidance. Particularly as it relates to procurement procedures, for acquisitions of property or services in which the aggregate dollar amount is greater than the micro-purchase threshold but does not exceed the simplified acquisition threshold, the District will obtain and document price or rate quotations from at least three qualified sources. In addition, management of the District will obtain training where available and applicable to enhance their internal controls over the management of federal program funds. The District’s timeframe for implementation is effective immediately.

While BREC currently does not have any federal expenses identified as unallowable costs applicable to this finding, a written SOP will be developed for determining allowable costs and procurement requirements in accordance with the applicable CFR to guide key finance staff with responsibility for federally eligible expenditures. o Anticipated Completion Date: July 31, 2024 o Responsable Contact Person: Rhonda Williams